Filing # 67234967 E-Filed 01/30/2018 11:10:40 AM IN THE CIRCUIT COURT OF THE Fwit.ENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO. 502009CA040800X30030 JEFFREY EPSTEIN, PlaintiffiCounter-Defendant, -vsSCOTT ROTHSTEIN individually and J. individually, Defendants/Counter-Plaintiffs. AMENDED RESPONSE TO PLAINTIFF/COU EPSTEIN'S MOTION TO STRIKE DEFEND DAMAGES EXPERT WITNESS. DR. BERNA TES Counter-Plaintiff, NDANT JEFFREY TER-PLAINTIFF'S N. AND TO EXCLUDE HIS by alt through undersigned counsel, hereby files J. this Response to Plaintiff/Counter-Def t Je Dr. Bernard Jansen, and to ExclujdCit y Epstein's Motion to Strike Expert Witness, ony, and as ground therefore states: LEVANT FACTS After having fil responsibility b spurious profe icious action against Epstein attempts to avoid g to exclude expert testimony regarding the massive dissemination of the in his lawsuit against Dr. Bernard Jansen is a tenured full-time e College of Information Sciences and Technology at the Pennsylvania State University and is the Director of Information Searching and Learning Laboratory at the college 1 FILED: PALM BEACH COUNTY. FL. SHARON R BOCK. CLERK, 01/30/2018 11:10:40 AM EFTA02764119