Filing # 56943818 E-Filed 05/25/2017 03:20:22 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN individually, J. individually, and L.M., Defendant, GU MOTION TO EXPAND INTERROGATORIES J. by and through the under Court pursuant to the provisions of Rule 1.340(a), I:junsel, moves this Honorable ond tules of Civil Procedure, to increase the number of initial interrogatories permitt er additional interrogatories in accordan t ose attached, and in support of this motion, as to allow for the filing of two sets of J. would show: 1. The Supreme C 2. ThiCments of the claims asserted and the nature and complexity of the factual t 16s not approved a form of interrogatories for this type of action. circumstan,c twenty-f,) 3. "I IIIIIT 'N rise to the claims are not susceptible to being adequately covered within the interrogatory limit. The elements of defenses asserted or expected to be asserted are not susceptible to being adequately covered within the twenty-five (25) interrogatory limit. Two sets of additional interrogatories are attached. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 05/25/2017 03:20:22 PM EFTA02776569