Filing # 68851713 E-Filed 03/06/2018 12:43:49 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, Defendants. RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION F R COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED NATURE OF DOCUMENTS AND REOUEST FOR ADDITIONAL LIMITED DISCOVERY, EVIDENTIARY HEARING. AND APPOINTMENT OF A SPECIAL Counter-Plaintiff M, ''*' ndersigned counsel, hereby files this Response by and in Opposition to Epstein's Motion V o Documents and Request for A imited Discovery, Evidentiary Hearing, and Appointment of a Special , an on to Declare Relevance and Non-Privileged Nature of support states as follows: rporates by reference the timeline and arguments contained in his Motion to St ISErNin's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference merits Containing Privileged Materials Listed on Privilege Log, filed on March 32018. 2. For brevity, In addition to those arguments, states as follows: shall refer to Epstein's motion as the "Motion for Court to Declare Relevance." FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 03/06/2018 12:43:49 PM EFTA02765465