IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION FOR LEAVE TO AMEND TO ASSERT CLAIM FOR PUNITIVE DAMAGES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel, hereby offers the following response in opposition to Defendant/Counter- Plaintiff EDWARDS' ("Edwards") Motion for Leave to Assert a Claim for Punitive Damages ("motion")" and states: SUMMARY OF ARGUMENT Edwards' latest kitchen-sink motion for leave to add punitive damages is utterly frivolous, obscuring the relevant issues and flatly ignoring the applicable legal standards. It is premature because it attacks a non-existent complaint and no operative complaint was pending. Second, there is no basis for imposing punitive damages based on the mere fact that Epstein did not proceed with certain claims against Edwards that had been included in the initial complaint. Third, claims against him were dropped does not provide a basis for asserting punitive damages for abuse of process. Third, to recover punitive damages. Edwards must show that Epstein's filing of his abuse of process claim against him — which is the gravamen of Edwards' abuse of EFTA00582880