IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XVOIMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN individually, J. individually, and L.M., individually, -n Co) m Defendants. / < ,6>" 1, MOTION FOR LEAVE TO AMEND TO ASSERT A CLAIM FOR PUNITIVE DAMAGES Defendant, J. a, • , ems -.7..- :-. ..... 7.-• • r :.-O t—. •-•--•,.c.: '7, :-•:::- r-—g', F 1/40 C -a T. .C3 --tq cp -do c-, —n , " . Vi -c W 7-: -r (....) _4:23 o 2c. - a Esq., by and through his undersigned counsel and pursuant to Rule 1.190(f), Florida Rules of Civil Procedure, hereby moves for leave to amend to assert a claim for punitive da ges and in support thereof relies upon the following evidence in the record and such additional evidence as is herein proffered*: I. INTRODUCTIO The pleadi4tg that a reaspik iscovery taken to date, and the evidence proffered with this motion show is exists to support the recovery of punitive damages against the Counter- Defendarney Epstein. Not only is there an absence of competent evidence to demonstrate that participated in any fraud against Epstein, the evidence uncontrovertibly demonstrates the propriety of every aspect of involvement in the prosecution of legitimate claims against Epstein and the fact that the sole basis for the assertion of the spurious claims filed against was an attempt to intimidate into abandoning EFTA02769928