Filing # 64855972 E-Filed 12/01/2017 02:40:38 PM 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, MOTION FOR LEAVE TO PROPOUND LIMITED REOUESTS FOR ADMISSION Counter-Plaintiff, J. by and through undersigned counsel, hereby files this Motion for Leave to Propound Limited Requestifor Admission, and as grounds therefor states as follows: 1. On November 8, 2017,`Ed‘vards filed a Request for Judicial Notice Pursuant to ( Florida Statutes Section 90.202 and 90.203, which asks that the Court take judicial notice of Jeffrey Epstein's New York State Sex Offender registration information. 2. The ilequest for Judicial Notice attached a copy of the New York State Sex 7- Offender registraticyni information at issue, which was pulled from that state's government website. 3. On November 27, 2017, the Court entered its Order on Motion to Reconfirm Existing Pretrial Deadlines and Re: Pretrial Stipulation, in which it ordered that wholesale additional discovery would not be permitted, but individual discovery requests may be allowed on a matter by matter basis, and only if the discovery requests are impacted by the Court's rulings on certain motions currently pending to be heard. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/01/2017 02:40:38 PM EFTA02762639