JEFFREY EPSTEIN, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Plaintiff vs. CASE NO. 502009CA040800XXXXMBAG SCOiiitually, and J, individually. C, If Defendants. / r ' 0 r— 71 22. • cit z ti --4e-)c-3 5-, :,..: c, ut It-c3: a) PLAINTIFF'S AMENDED MOTION TO COMPEL DISCOVERY it' EgitoNuEs AND FOR SANCTIONS :t 1 Plaintiff Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 1.380 of the Florida Rules of Civil Procedure, hereby, moves this Court to enter an order compelling the Defendant Edwards, yet again, to provide responses to Plaintiff's Request for Production. Plaintiff likewise requests that this Court order sanctions against Defendant for his direct and flagrant disregard of this Court's previous Order dated April 10, 2012. In support thereof, Plaintiff states: INTRODUCTION On March 9, 2012, Plaintiff Epstein served upon Defendant a Motion to Compel and to Amend and Lift a Protective Order. A true and correct copy of Plaintiff's Motion isattached hereto as "Exhibit A." On April 10, 2012, this Court entered an Order „14/14/14/14/ \ onA aintiff's Motion to Compel, stating that "within twenty (20) days of the date of this Order, the Defendant identified in Paragraph 13 of shall produce any non-privileged documents as ' [sic] Motion to Compel and Amend Protective Order." See Order entered April 10, 2012, a true and correct copy of which is attached hereto as "Exhibit B." The Order further avowed that "[n]othing in this Order shall EFTA02771046