IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. JEFFREY EPSTEIN, Plaintiff, V. SCOTT ROTHSTEIN individually and J. individually, Defendants. PLAINTIFF JEFFREY EPSTEIN'S SUPPLEMENT TO MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM DEFENDANT AND FOR SANCTIONS Plaintiff, Jeffrey Epstein, by and through his undersigned counsel, hereby supplements his Motion to Compel Production of Documents from Defendant and for Sanctions with the following argument that based upon the principle of waiver of privilege by issue injection, Defendant can no longer maintain claims of privilege, particularly for work product. As a result, the grounds for this argument are as follows: 1. On November 3, 2011, Defendant Summary Judgment. Beginning on page 4 of the Motion, filed his Renewed Motion for Final alleges that he: "diligently represented three victims of sexual assaults perpetrated by Epstein. As litigation decisions explained in detail below, each and every one of was grounded in proper litigation judgment about the need to pursue effective discovery of Epstein, particularly in the face of Epstein's stonewalling tactics." EFTA02770961