Filing # 66507496 E-Filed 01/12/2018 04:26:17 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800,OOaMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, J. individually, and L.M., individually, cOAS Defendant, RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION TO COMPEL E.W. TO ANSWER QUESTIONS RELATING TO THE CRIME VICTIMS' RIGHTS ACT AND TO REOPEN DISCOVERY Counter-Plaintiff, and through undersigned counsel, hereby files this Response in Oppositions to Jeffrey Epstein's Motion to Compel E.W. to Answer Questions Relating to the Crime Victims' RightsAct and to Reopen Discovery, and as grounds therefor states • / as follows: 1. cinntends that among Epstein's motives for filing and continuing this baseless and Dacus lawsuit was Epstein's desire to intimidate into abandoning his clients' churns' Nin the Crime Victim's Rights Act ("CVRA") proceeding. As the Court is aware, •.ct one potential-ciutcome of the CVRA proceeding is the invalidation of Epstein's Non-Prosecution Agreement ("NPA"), which shields Epstein from criminal liability in the Southern District of Florida. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 01/12/2018 04:26:17 PM EFTA02763893