Electronically Filed 09/24/2013 10:47:13 AM ET *** FILED: PALM BEACH COUNTY. FL SHARON R B IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Case No 50 2009 CA 040800XXXXMBAG Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN individually, J. . individually, Defendant/Counter-Plaintiff. Aliftc / O AS PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN ION TO DEFENDANT/COUNTER-PLAINTIFF MOTION FOR JURY INSTRUCTION REGARDING ADVERSE INFERENCE AND EVIDENCE PRECLUSION ... Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to thi truction at hearing, tiles this Response in Opposition to Defendant/Counter-Plainti (a') untimely Memorandum of Law regarding Adverse Inference and Evidence Preclusion, and states: INTRODUCTION On Juh9V, 2013, Inferen ad 3:3 . 5, 2013, filed his Motion to Determine Entitlement to Adverse and set same for a specially-set hearing on September 16, 2013 at rue and correct copy of same is attached hereto as "Exhibit A." On September filed a letter to Judge M, indicating therein that he intended to rely upon all of the law cited in his July 17, 2013 Motion at the hearing. A true and correct copy is attached hereto as "Exhibit B." On September 9, 2013, Epstein filed his Response and Memorandum of Law in Opposition to Motion, a true and correct copy of EFTA02772430