Filing # 66595023 E-Filed 01/16/2018 03:39:48 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. cos SCOTT ROTHSTEIN individually, J. individually, and L.M., individually, Defendant, I A RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FAR PROTECTIVE ORDER AND IN LIMINE OF UNRELATED SETTLEMENT AGREEMENTS Counter-Plaintiff, J. M, by and through undersigned counsel, hereby files this Response in Opposition to Jeffrey Epstein's Motion for Protective Order and in Limine of Unrelated Settlement Agreements, and aamunds therefor states as follows: 'Introduction One of the underpinnings of Epstein's malicious prosecution against was that had "fabricated," "manufactured" and "ginned up" his clients' claims against Epstein for the express purpose of supporting a massive Ponzi scheme. In furtherance of this patently false charge, EpsteM alleged that the claims being pursued by L.M., E.W. and Jane Dow "were weak and had Minimal value." Complaint at I 42(h), I In fact, Epstein even sued one of his victims, L.M., and charged that she was knowingly furthering Scott Rothstein's Ponzi scheme by seeking a I Allegations that the victims' claims were ginned up are replete throughout Epstein's maliciously-filed complaint. 1 FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 01/16/2018 03:39:48 PM EFTA02763966