IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA L.M., CASE NO. 502008CA028051XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. EPSTEIN'S MOTION TO COMPEL ANSWERS TO FOURTH SET OF INTERROGATORIES Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Fla. R. Civ. P. 1.380, moves to compel Plaintiff, L.M. to answer Epstein's Fourth Set of Interrogatories and states: 1. On February 25, 2010, Epstein propounded his Fourth Set of Interrogatories on LM (attached as Exhibit A). 2. On April 1, 2010, LM served Unverified Answers to Defendant's Fourth Interrogatories (attached as Exhibit B). 3. First, Epstein moves to compel LM to provide verified answers to Epstein's Fourth Set of Interrogatories as required by Fla. R. Civ. P. 1.340, which provides that "[e]ach interrogatory shall be answered separately and fully in writing under oath...." 4. Next, Epstein moves to compel LM to provide a better answer to Interrogatory No. 1, which states: List the names, business addresses, telephone and cell phone numbers, dates of employment, immediate supervisor (name and address) and rates of pay regarding all employers, including self-employment, for whom you have worked since you answered the First Set of Interrogatories EFTA01076824