IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. ‘ SCOTT ROTHSTEIN individually, J. individually, and L.M., individually, C Defendant, / co -O= 5" r:3 2 ai nn s G GCS CS -4c-Am n=g Co 'o ZEnz -0 • = r-cp an - i z r- Ns SECOND SUPPLEMENTAL RESPONSE TO ; 12 ..." EPSTEIN'S REQUEST TO PRODUCE PURSUANT TO COURT ORDER Defendant/Counterplaintiff, J. a, by and through his undersigned attorneys, files this Second Supplemental Response to EPSTEIN'S Request to Produce in compliance with this Court's Order, and states as follows: r 1. Copies of materials previously produced to counsel for EPSTEIN on May 8, 2012 are attached as • e Exhibit A. Some of the produced documents contain privilege Co• as noted. 2. This duction was culled by electronic search of approximately 28,000 documents released to by the RRA Bankruptcy Trustee. 3. The documents contained within Composite Exhibit A and those documents listed on the privilege log attached as Composite Exhibit B, together comprise the complete universe of responsive documents within a possession, custody and control. EFTA02771176