IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN individually, J. , individually, and L.M., individually, Defendant(s). MOTION TO COMPEL PROPEtANSWER OR TO DEEM UNANSWERED ALLEGATIONS ADMITTED Counterplaintiff, J. EDWARDS, by and through his undersigned counsel, moves this Honorable Court to compel a proper response to the Counterclaims asserted herein, or alternatively to deem admitted the allegations as to which no proper response has been made. In support of this motion, would show: Nft ei as failed and refused to properly respond to material allegations in Paragraph 5 of the Third Amended Counterclaim as ected in the pleadings attached. Epstein has failed to properly identify which parts of Paragraph I I, 12 and 27 are admitted and which are denied. EFTA02771090