Filing # 68309989 E-Filed 02/22/2018 10:48:29 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN IIMIM J. L.M., individually, ividually, , individually, and Defendant, Th 04 ' REPLY TO EPSTEIN'S RESPONSE IN OPPOSITION TOMMIE MOTION IN LIMINE FILED FEBRUARY 6, 2018 Counter-Plaintiff, ME by and through his undersigned counsel, J. Elle, hereby files this Reply to Epstein's Response in Opposition to ' Motion in Limine filed February 6, 2018, and as grounds therefor states as follows: 1. Epstein's Response offers no case law to support his contention that, despite black- letter law forbidding any such argument, Epstein should nonetheless be permitted to make 7 "comparative ve clear error anclms ff ents to the jury. Epstein instead simply invites the Court to commit him to compare the settlements received by L.M., E.W. and Jane Doe in their civil'molestation cases to the damages sought by counterclaim. Consistent with Wynn and & in this malicious prosecution Millworks, the Court should decline Epstein's invitation. 2. that In addition, Epstein's argument that it is a "fair comment on the evidence" to argue is selfishly seeking more damages than he recovered in the three settlements FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 02/22/2018 10:48:29 AM EFTA02764891