PALM BEACH COUNTY. FL SHARON BOCK. CLE Electronically Filed 09/13/2013 11:47:23 AM ET IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. 04 SCOTT ROTHSTEIN, individually, and J. . individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFIREYE EIN'S MOTION TO FILE AN AMENDMENT TO HIS ANSWE$ AND AFFIRMATIVE DEFENSES TO DEFENDANT/COUNTER-PLAINTIFF'S FOURTH AMENDED COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.190 of the Florida Rules of Civil Procedure, hereby moves this Honorable Court to permit the filing of the accompanying Amended Answer Counterclaim( Affirmative Defenses to Fourth Amended onforlli with the evidence. In support of this Motion, Epstein states: 90(a) of the Florida Rules of Civil Procedure governs amendments to P1 d provides, in relevant part, that "[1]eave of court shall be given freely when justice so requires." Fla. R.Civ. P. 1.190(a) (2013). Here, Epstein specifically reserved the right to amend his affirmative defenses when he filed his Answer and Affirmative Defenses to Fourth Amended Counterclaim. Here, justice requires the amendment of Epstein's Affirmative Defenses because, if properly established, the EFTA02772347