Filing # 61812646 E-Filed 09/21/2017 10:53:55 AM 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, C Defendant(s). MOTION TO COMPEL SUBSTANTIVE RESPONSE TO REQUEST TO PRODUCESERVED APRIL 15, 2011 by and throu ersigned attorneys, moves this Honorable Court to compel Jeffrey Epstein's subsXt e) se to the attached Request to Produce over the J.M, objections asserted by Jeffrey WHEREFORE, tei . dley . provide a subst tive respo se to moves for an Order compelling Jeffrey Epstein to Request to Produce served April 15, 2011. Movant counsel certifies, in good faith, they have conferred or attempted to confer with the person or party failing to make the discovery in an effort to secure the information or material without court action. FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 09/21/2017 10:53:55 AM EFTA02776986