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.: 502009CA04080OOOOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. cos SCOTT ROTHSTEIN individually, J. individually, and L.M., Defendant, RESPONSE IN OPPOSITION TO EPS‘NkS OTION TO REOPEN DISCOVERY TO AICUEPOSITIONS Counter-Plaintiff, J. tzylOpdrjuough undersigned counsel, hereby files this Response in Oppositions to Je Depositions, and as grounds therefor t 1., The Motion Fails to Meet t 1. 's Motion to Reopen Discovery to Take follows: Court's Requirements to Reopen Discovery On November 27, 2017, the Court entered its Order on Motion to Reconfirm Existing Pre-Trial Deadlines', in which the Court ruled that additional discovery will only be permitted if "'the discovery requests are impacted by the Court's rulings on motions currently pending to be heard on November 29'h, December e and 7'h." At the hearing preceding the Order, the Court outlined the standard by which any such additional discovery requests would be considered: So what I am going to do is this. Because there are issues that need to be addressed -- and I'm hoping I will have orders out as soon as possible after those hearings are done -- is that I am going to require motions to be filed A copy of the Court's Order is attached hereto as Exhibit `A'. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 01/12/2018 04:26:17 PM EFTA02763912