Filing # 67114112 E-Filed 01/26/2018 03:59:55 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, , individually, and EMI J. individually, L.M., Defendants. MOTION TO LIFT CONFIDENTIALITY DESIGINA ION OF EPSTEIN'S DISCLOSURE OF CONFIDENTIAL SETTLEMENT INFORMATION Counter-Plaintiff, J. by and through undersigned counsel, hereby files this Motion to Lift Confidentiality Designation of Epstein's Disclosure of Confidential Settlement Information pursuant to the Court's-Order Compelling Epstein to Produce Settlement Amounts dated January 5, 2018, and as grounds therefore states as follows: 1. On January 5, 2018, the Court entered its Order Compelling Epstein to Produce Settlement Amounts, which required Epstein to produce, for attorneys' and client's eyes only, the following information: (a) the number of sexual abuse claims that Epstein settled in the two years prior to December 7, 2009; (b) the aggregate settlement monies paid for the cases settled in the two years prior to December 7, 2009; (c) the number of sexual abuse claims that Epstein settled after December 7, 2009; and (d) the aggregate settlement monies paid for the cases settled after December 7, 2009. A copy of the Court's Order is attached hereto as Exhibit `A'. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 01/26/2018 03:59:55 PM EFTA02764066