Filing # 68938778 E-Filed 03/07/2018 03:19:32 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, A v. Cos SCOTT ROTHSTEIN individually, and J. individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY IN'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PL MOTION IN LIMINE TO LIMIT THE INTRODUCTION OF EVIDENCE ALLEGED TO SUPPORT EPSTEIN'S CL If AVAINST pstein') responds in opposition to the Plaintiff/Counter-Defendant Jeffrey Motion filed by Defendant/Counter-P. of Evidence alleged to support E to Limit Introduction against and states: INTRODUCTION has argu atedly that evidence Epstein discovered after filing suit should not be allowed at triatuse it dots not support what Epstein knew at the time he filed his Complaint. This ar fo is that has disputed Epstein's probable cause for the continuation of the a ugh its dismissal in 2012. Furthermore, a party can obtain evidence through subsequent discovery that supports the party's probable cause. No party must have "all the evidence" at the time he files his lawsuit in order to defend against a claim of malicious prosecution. That simply is not the legal standard. Finally, of proof in this case, and —not Epstein—has the burden has had more than sufficient time in the eight years of this FILED: PALM BEACH COUNTY. FL. SHARON R BOCK. CLERK, 03/07/2018 03:19:32 PM EFTA02765533