Electronically Filed 07/17/2013 11:44:27 AM ET IN THE CIRCUIT COURT OF THE 14 i kENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAO JEFFREY EPSTEIN, Plaintiff(s), 8 6 co 1 2 i:i vs. SCOTT ROTHSTEIN individually, J. individually, and L.M., individually, Defendant(s). / MOTION TO DETERMINE ENTITLE PRECLUDING EPSTEIN FROM OF A Cos c VERSE INFERENCE AND NG EVIDENCE AT TRIAL by and dersigned attorneys, moves this Honorable Court to detennine his entitlement to on to the jury before whom this matter shall be tried, that the jury is entitled Jeffrey Epstein re( ded concl solely on the basis of Epstein's refusal to answer that had thfully to any relevant discovery request as to which he has refused to answer or d upon an assertion of his Fifth Amendment privilege, that all such answers ,.. an ,. a lees would, in fact, have implicated him in the commission of a crime or would othe 'se have disclosed information adverse to Jeffrey Epstein's interests in this lawsuit. further moves this Honorable Court to enter an Order precluding Jeffrey Epstein from offering evidence or testimony as to any matter about which he has declined on the basis of the assertion of privilege to provide pre-trial discovery. EFTA02772280