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. 50-2009CA040800XXJ0CMI3AG JEFFREY EPSTEIN, PlaintiffiCounter-Defendant, A v. Cos SCOTT ROTHSTEIN individually, and J. individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFF FIN'S RESPONSE MOTION TO STRIKE EPSTEINtT ELY SUPPLEMENTAL EXHIBITS AND TO STRIKE ALL EXHIBITS A ANY REFERENCE TO DOCUMENTS CONTAINING PRIVILEGED MATERIALS LISTED ON OEM PRIVILEGE TO Plaintiff/Counter-Defendant Jeffre Plaintiff J. Motio Strike All Exhibits and Any R ("Epstein") responds to Defendant/Counterpstein's Untimely Supplemental Exhibits and to Documents Containing Privileged Materials Listed on Privilege Log. ISSUES TO BE DECIDED BY THE COURT Ae The ' ues for the Court to decide include: (1) are the exhibits identified by Epstein relevant- re the documents, when created, protected by the work product discovery doctrine; and (3) e work-product protection been waived based on (a) production to Razorback, (b) issue injection, (c) crime fraud exception, (d) fraud on the court, and (e) delivery by the Special based on instructions from Mr. Scarola to provide to the Special whatever documents deems producible. FILED: PALM BEACH COUNTY. FL. SHARON R BOCK. CLERK, 03/07/2018 03:19:32 PM EFTA02765538