Filing # 61091424 E-Filed 08/29/2017 04:11:43 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CIRCUIT CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, JUDGE HAFELE PlaintifVCounter-Defendant, vs. SCOTT ROT_ HSTE1N l_ individually, individually, Defendants/Counter-Plaintiffs. GO MOTION FOR PERMISSION TO TV g, COMES NOW, the Plaintiff/Counter Defen S'tik t his undersigned counsel and makes this his ‘M ettc (now known as C( ( OSITION RY EPSTEIN, by and through e the Deposition of ELIZABETH MOODY), and as grounds would show: I. Pursuant to Florta Ryles of Civil Procedure, Rule 1.310 (a), " The deposition oipso n confmed in prison may be taken only with leave of the Court n su terms as the Court prescribes.". 2. Gadsden Co 3. M dy, who has been listed as a trial witness, is currently incarcerated in the nal Facility. Her current release date is January 18, 2019. The undersigned attorney has been in touch with officials at the Gadsden Correctional Facility and it is anticipated that the Superintendent/Warden will give permission to take the deposition of Ms. Moody at Gadsden's Correctional Facility. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 08/29/2017 04:11:43 PM EFTA02776783