Filing # 75554430 E-Filed 07/26/2018 01:15:40 PM IN THE CIRCUIT COURT OF THE Air 1 bENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO. 502009CA040800X3003/B JEFFREY EPSTEIN, Plaintiff'Counter-Defendant, A -VS- Cos SCOTT ROTHSTEIN individually and J. individually, Defendants/Counter-Plaintiffs. DEFENDANT JEFFREY SUPPLEMENTAL RESPONSE TO PLAINTIFF/CCHEM EPSTEIN'S MOTION FOR COURT TO DECLARE' RELEVANCE AND NONPRIVILEGED NATURE OF DOCUMENTS, AND RI UEST FOR ADDITIONAL LIMITED DISCOVERY EVIDENTIARY HEARING AND APPOINTMENT OF AND THE UPPLEMENTT I THAT M TI N Counter-Plaintiff and through undersigned counsel, hereby files this Supplemental Response to P •er-Defendant Jeffrey Epstein's Motion for Court to Declare Relevance and Non-Pr ture of Documents, and Request for Additional Limited Discovery, Evidentiary t eating ar and Appointment of Special Relevance") andcup pl ("Motion to Declare ent to that motion, and as grounds therefore states: INTRODUCTION has already determined that Epstein may not admit into evidence or otherwise refer to ihbprivileged documents in question. This Court's decision was based upon the fact that Epstein and his counsel had possession of the materials for years, in violation of a federal court order, yet failed to timely list them as exhibits, in violation of multiple court orders and rulings. Epstein also failed to seek a determination before the close of discovery as to the privileged nature 1 FILED: PALM BEACH COUNTY. FL. SHARON R BOCK. CLERK, 07/26/2018 01:15:40 PM EFTA02767344