## 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, raS ## GENERAL OBJECTIONS TO UNTIMELY COMPOSITE EXHIBITS Counter-Plaintiff, J. M, by and through undersigned counsel, hereby files this General Objections to Untimely Composite Exhibitt, and as grounds therefor states as follows: - 1. At the December 5, 2017 special-set hearing, the Court ordered Counter-Plaintiff to produce copies of any exhibits that had not previously been produced by no later than December ( 20, 2017. (12/5/17 Tr. 216, 219, 226, 228). - 2. That ruling memorialized in the Court's January 16, 2018 Order on PlaintifflCounter endant Jeffrey Epstein's Revised Omnibus Motion in Limine Section B ( ,K 1 'bits), as follows: OTBI12/ efore December 20, 2017, shall produce to Epstein all trial exhibits that have not been previously produced in the form to be introduced at trial... - 3. Yet on February 2, 2018, undersigned counsel received letter correspondence from Epstein's counsel, which enclosed a flash drive "containing additional documents for [Epstein]'s trial Exhibit Nos. 18, 35, 48, 323 and 324. We are still obtaining additional public records and will provide those to you upon our receipt." The numbered exhibits are \`catch-ails' as follows: - a. #18 Court docket and all court filings referenced therein for L.M. v Jeffrey Epstein, case no. 50-2008-CA-028051; AA' - b. #35 Court docket and all court filings referenced the ' .W. v. Jeffre Epstein, case no. 50-2008-CA-028058; - c. #48 Court docket and all court filings reference th 2for Jane Doe v. Jeffrey Epstein, case no. 08-cv-80893; - d. #323 All public records and t 8se e cles relating to Scott Rothstein, Rothstein Rosenfeldt Adle iils, J. ME and any witnesses listed by either party; - e. #324 All co QC s and filings in all matters against Jeffrey Epstein relating to s claims. 4. e tests to all such late produced exhibits, whether contained in the February 2, 2018 flash drive or intended to be produced in the future, as violative of the Court's December 5, 2017 ruling and January 16, 2018 order. ii 1. Additionally, the Court has previously ruled that, with regard to any "catch-all" exhibits listed on either party's exhibit list, the party must separately identify and list individually each exhibit sought to be relied upon by the listing party. 1. therefore reserves all objections to all composite exhibits that fail to comply with this order by the Court. I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 6th day of February, 2018. ![](<>)JACK SCAROLA\ Florida Bar No.: 169440\ DAVID P. VITALE JR.\ Florida Bar No.: 115179\ Attorney E-Mail(s): jsx@searcylaw.com and\ mmccann@searcylaw.com\ Primary E-Mail: ScarolaTeam@searcylaw.com\ 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 Plaintiff(s) NOTA CERTIFY **COUNSEL LIST** [REDACTED] J. [REDACTED], Esquire\ staff.efile@pathtojustice.com\ 425 N Andrews Avenue, Suite 2\ Fort Lauderdale, FL 33301\ Phone: (954)-524-2820\ Fax: (954)-524-2822 Jack A. Goldberger, Esquire\ jgoldberger@agwpa.com; smahoney@agwpa.com\ Atterbury Goldberger & Weiss, P.A.\ 250 Australian Avenue S, Suite 1400\ West Palm Beach, FL 33401\ Phone: (561)-659-8300\ Fax: (561)-835-8691\ Attorneys for Jeffrey Epstein Nichole J. Segal, Esquire\ njs@FLAppellateLaw.com; kbt@FLAppellateLaw.com\ Burlington & Rockenbach, P.A.\ 444 W Railroad Avenue, Suite 350\ West Palm Beach, FL 33401\ Phone: (561)-721-0400\ Attorneys for [REDACTED] J. Edwards Scott J. Link, Esquire\ Eservice@linkrocklaw.com; Scott@linkrocklaw.com; Kara@linkrocklaw.com;\ Angela@linkrocklaw.com; Tanya@linkrocklaw.com; tina@linkrocklaw.com\ Link & Rockenbach, P.A.\ 1555 Palm Beach Lakes Boulevard\ Suite 301\ West Palm Beach, FL 33401\ Phone: (561)-727-3600\ Fax: (561)-727-3601\ Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire\ marc@nuriklaw.com\ One E Broward Blvd., Suite 700\ Fort Lauderdale, FL 33301 Case No.: 502009CA040800XXXXMBAG\ General Objection to Untimely Composite Exhibits\ Page 5 of 5 Phone: (954)-745-5849\ Fax: (954)-745-3556\ Attorneys for Scott Rothstein NOT A CERTIFIED COPY