Filing # 66556735 E-Filed 01/16/2018 10:03:25 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800LVOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN individually, J. , individually, and L.M., individually, A. Defendant, RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION F It LEAVE TO DISCLOSE EXPERT WITNESS Counter-Plaintiff, J. S by and through undersigned counsel, hereby files this Response in Opposition to Jeffrey E iein's Motion for Leave to Disclose Expert Witness, and as grounds therefor states as foV ot): .s, The Motion Fails to Meet Court's Requirements to Reopen Discovery 1. 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 6ih and 7th." 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 on a discovery issue-by-discovery issue, deposition by deposition, so as to FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 01/16/2018 10:03:25 AM EFTA02763926