#291874/mep IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800X3OO0N3AG -os T• r crT Fa co-14 JEFFREY EPSTEIN, Plaintiff(s), Act ts nets"' Gy J tin % e. 4:2 es vs. SCOTT ROTHSTEIN individually, individually, and J. L.M., individually, y'`13 C cn • O Defendant(s). MOTION FOR LEAVE DEFENDANT/COUNTERPLAINTIFF, EDWAt ic 'S T 'SJWED T TO ASSERT CLAIM FO J. ED Counter-plaintiff, Order granting him leave to assert a a JEFFREY EPSTEIN, and in the Court in support of prerequisites for the that EPSTEIN' rt S troves this Honorable Court for entry of an unitive damages against the Counter-defendant, of would show that the record evidence presented to Motion for Summary Judgment satisfies the statutory sat n f a punitive damage claim. Specifically, the evidence establishes m 'nt against led in the total absence of evidence to support any allegation of wrongdoing on the part of 2. was filed in the total absence of evidence that EPSTEIN had sustained damage as a consequence of any misconduct other than his own well-established criminal enterprise; EFTA02771210