SHARON BOCK. CLERK.'" Electronically Filed 08/07/2013 02:49:35 PM ET JEFFREY EPSTEIN, IN THE CIRCUIT COURT OF THE 1-11-1EENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff, vs. SCOTT ROTHSTEIN, individually, and J. individually. CASE NO.: 502009CA040800XXXXMBAG JUDGE: Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY E MOTION TO BIFURCATE TRIAL Plaintiff/Counter-Defendant Jeffrey Epstein ("Ep undersigned counsel and pursuant to Rule 1.270‘ Procedure, hereby files this Motion to BifurcS ir., s, A thereof, Epstein states: o) ' "), AS ' and through his Florida Rules of Civil al in this matter. In support ION On December 19, 20 Plaintiff J. Edward onorable Court granted Defendant/Counternafter ` ") Motion for Leave to Assert Claim for Punitive Damage%lc'nst Epstein. This case is currently scheduled on this Court's October 2013 'al Calgndar. has alleged two causes of action in this matter against E ode for malicious prosecution and one for abuse of process. Damages are or each cause of action. efore is permitted to present a case for punitive damages, he must first prove these claims against Epstein. Epstein has denied liability as to these claims and has asserted various affirmative defenses, which include action in both abuse of process and malicious prosecution; plead damages; failure to state a cause of failure to properly inability to overcome the absolute immunity afforded to 1 EFTA02772297