JEFFREY. EPSTEIN,Plaintiff, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA vs. SCOTT ROTHSTEIN, individually, and J. individually. CASE NO.: 502009CA040800XXXXMBAG JUDGE: Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF RENEWED MOTION FOR LEAVE TO ASSERT CLAIM FOR PUNITIVE DAMAGES AND MOTION FOR SANCTI S AGAINST DEFENDANT/COUNTER-PLAINTIFF Plaintiff/Counter-Defendant Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 1.190(f) of the Florida Rules of Civil Procedure, §768.72 of the Florida Statues, and this Court's prior ruling on July 13, 2011, hereby files this Response in Opposition to Defendant/Counter-Plaintiff Renewed Motion for Leave to Assert Claim for Punitive Damages and Motion for Sanctions > — In suppn o got against Defendant/Counter-Plaintiff Cinf—t" I?, an C :4> zcc-) to Plaintiff/Counter-Defendant Jeffrey Epstein states: PROCEDURAL HISTORY OF PUNITIVE DAMAGES ISSigf: On October 19, 2010, Defendant/Counter-Plaintiff 0 Edwareinafter -n N. "Edwards") filed his first Motion for Leave to Assert Claim for Ptutitive Damages against Plaintiff/Counter-Defendant Jeffrey Epstein thereinafter "Epstein"). ,. This Honorable Court denied that motion on July 13, 2011, after an extensive and lengthy hearing, citing as grounds therefor the glaring procedural deficiencies contained in Motion. A true and correct copy of the transcript of the hearing at which the Motion was denied is EFTA02771369