IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY,
FLORIDA
CASE NO:
502008CA037319X3OOCMB AB
B.B,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
MOTION TO COMPEL PROPER RESPONSES TO PLAINTIFF'S SUPPLEMENTAL
REQUESTS FOR ADMISSION DATED FEBRUARY 4, 2010
Plaintiff, B.B., by and through undersigned counsel, hereby files this Motion to Compel
Defendant, JEFFREY EPSTEIN, to properly respond to Plaintiff's Requests for Admission
Dated February 4, 2010, and as grounds therefore states as follows:
1. On February 4, 2010, Plaintiff served Defendant with twelve Requests for
Admissions. (Exhibit "A").
2. On March 17, 2010, Defendant responded to each Request identically (Exhibit
"A") — in essence acknowledging that Defendant intends to respond to all relevant discovery but
at the moment is asserting his U.S. Constitutional privileges.
3. Florida Statute § 775.15 prescribes the statute of limitations for the criminal acts
Defendant committed upon Plaintiff. Statute attached hereto as Exhibit "B."
4. Plaintiff is a victim of the second degree felonies prescribed under Florida
Statutes §§ 800.04 ("Lewd or lascivious offenses committed upon or in the presence of persons
EFTA00605559