IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA B.B., CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, and MKELLEN, Defendants. DEFENDANT EPSTEIN'S MOTION TO COMPEL TOWN OF PALM BEACH RECORDS CUSTODIAN'S AND POLICE OFFICERS' TO PRODUCE RECORDS SOUGHT PURSUANT TO DEFENDANT'S SUBPOENAS DUCES TECUM Defendant, JEFFREY EPSTEIN (hereinafter "EPSTEIN") by and through his undersigned attorneys, moves to compel the non-parties, TOWN OF PALM BEACH RECORDS CUSTODIAN and TOWN OF PALM BEACH POLICE OFFICERS, to better respond to and produce certain of the records sought pursuant to the cross-notices and notices of depositions with subpoenas duces tecum served upon them. In support of his motion to compel, Defendant states: 1. Defendant JEFFERY EPSTEIN served multiple Cross-Notices for Deposition with Subpoenas Duces Tecum, dated October 26, 2009, and Subpoenas Duces Tecum for Deposition, dated October 26, 2009, and one dated November 3, 2009, directed to the Town Of Palm Beach Records Custodian ("RC"), and certain Police Officers and the Police Captain of Town of Palm Beach ("Police"). The items requested and the Police's and RC's responses and objections thereto are set forth in Non-Party Police Officers' Response And Objection To Subpoena Duces Tecum, dated January 15, 2010, attached hereto as Exhibit A; and in Non-Party Town of Palm Beach Records EFTA01076133