40800XXXXMBAG Response in Opposition to Epstein's Motion to Amend Exhibit List. 3/8/18 Hearing Tr. at 11, 6-14. At the end of the oral argument on Epstein's Motion to Remove Case From Trial Docket, undersigned counsel warned that the hyper-technical argument being raised with regard to Rule 1.440 was merely a ploy to reopen discovery and dela