Filing # 66331996 E-Filed 01/10/2018 08:03:44 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XJDOCMBAG JEFFREY EPSTEIN, A Plaintiff/Counter-Defendant, v. Cos SCOTT ROTHSTEIN individually, and J. individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANTrIEFFR Y EPSTEIN'S MOTION TO REOPEN DISCOVERY TO TAKE DEPOSITIONS stein"), moves the Court for permission Plaintiff/Counter-Defendant, Jeffrey Ep e depositions of two of Defendant/Counter- to reopen discovery fix the limited purpo Plaintiff J. ("Edw clients (LM. and Jane Doe) and states: OU is attem Epstein in the on • 1 ci g to lc ear his name by proving that the individual allegations pled by proceeding against were false. ("[T]his case is my only chance to f t tillKrecord straight.") a' 11/10/17 Tr. 8:19-21.)' Despite his years of practice in 'al litigation, both as a former prosecutor of violent criminals and a member of the plaint! ' bar, including previous litigation where allegations of attorney misconduct were leveled directly against him personally, insists that, in this case above all others, he has experienced anxiety every single day since the Complaint was filed in December 2009 and he is ' Excerpts of Mr. a November 10, 2017, deposition transcript are attached as Exhibit A. FILED: PALM BEACH COUNTY. FL. SHARON R BOCK. CLERK, 01/10/2018 08:03:44 AM EFTA02763847