Electronically Filed 10/30/2013 04:13:26 PM ET IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOOCMBAG JEFFREY EPSTEIN, A Cos Plaintiff(s), vs. 6 SCOTT ROTHSTEIN individually, J. individually, and L.M., individually, Defendant(s). • MOTION TO DETERMINE STATUS OF PUNA&DAMAGE ) DISCOVERY AND APPLICABILITY OF ADVERSE INFERENCE V J. moves this Court to determine the status of the Jeffrey Epstein responses to financial entitlement to an adverse inference based on Epstein's stent refusal to provide evidence of his pecuniary circumstances relevant to In suppo and discov 3/11/13 s' pending punitive damage claim. motion, relies upon the series of Court Orders and Motions s attached, and which are summarized as follows: ourt Order overruling all financial discovery objections other than privilege and requiring "a detailed privilege log" as to all privileges asserted other than selfincrimination. 15 days to file log. 5/17/13 Court Order: "...[A] final determination of the Plaintiff's Fifth Amendment and other non-constitutional claims of privilege will first require [Epstein] to provide EFTA02775248