IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. MOTION FOR LEAVE TO SERVE ADDITIONAL INTERROGATORIES Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Fla. R. Civ. P. 1.340, moves for leave to serve additional thirty (30) interrogatories and states: 1. On February 25, 2010, Epstein propounded his Fourth Set of Interrogatories on (attached as Exhibit A). 2. With respect to interrogatories 3 —12,. objected and stated "beyond the limit of Interrogatories allowed pursuant to FRCP 1.340." See Answers to Interrogatories attached as Exhibit B. 3. As the Court is aware, 1. is seeking significant damages in this case. In addition, is a witness in companion cases filed by other plaintiffs against Epstein. 4. III testified that she went to Mr. Epstein's home anywhere from fifty (50) to more than seventy (70) times and brought more than seventy (70) females, some of whom are plaintiffs in companion cases against Epstein. See 9/24/09 Deposition Transcript of El at 74, 164. 5. Due to the nature of the claims, the number of times In claims to have gone to Mr. Epstein's home and the number of girls ■ claims to have brought to Mr. EFTA01076842