IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), co VS. SCOTT ROTHSTEIN individually, , individually, and J. L.M., individually, O Defendant(s). AS ti DEFENDANT'S MOTION TO PERMIT A'SpI The Defendant, J. NAL INTERROGATORY NIt tFirough the undersigned attorneys, moves this Honorable Court to enter an orde itti g Defendant, Jeffrey Epstein, to propound an additional interrogatory upon Plai y Epstein, and states: 1. The Supreme C s not approved a form of interrogatories for this type of action. 2. circumstance twenty-flvc(2 3. ents of the claims asserted and the nature and complexity of the factual rise to the claims are not susceptible to being adequately covered within the interrogatory limit. The elements of defenses asserted or expected to be asserted are not susceptible to being adequately covered within the twenty-five (25) interrogatory limit. EFTA02769594