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, Defendant, RESPONSE TO NOTICE OF ADDITIONAL AUTHORITY responds to the Notice of Additional Authority filed by Fred Haddad by calling the Court's attention to that portion of the holding in the cited case that recognizes the propriety of addressing the prejudice that arises from access to privileged information in the civil suit in which the improper use would occur. That is precisely the protection is seeking in the pending motion. I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve 7)-to all Counsel on tjttacheti list, this / 2 12. JAC Flo O No.: 169440 -mail: jsx®searcylaw.com S dary E-mail(s): [email protected] Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorney for EFTA02771794