IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, No. 50 2009 CA 040800XXXXMBAG Plaintiff/Counter-Defendant, JUDGE HAFELE v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWAFtDS'S FOURTH AMENDED COUNTERCLAIM, REOUEST FOR ORAL ARGUMENT AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, hereby files this Motion for Summary Judgment on the sole remaining count of Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Fourth Amended Counterclaim, Malicious Prosecution. In order to prevail on this count, Edwards must prove that there was an absence of probable cause at the time that Epstein filed suit against Edwards. The threshold of facts sufficient to establish probable cause that will defeat Edwards' claim for malicious prosecution is "extremely low and easily satisfied." Gill v. Kostroff, 82 F.Supp. 2d 1354, 1364. The specific facts cited herein, independently verifiable from news reports and publicly available criminal and civil case filings, are indisputable. They far exceed that minimal threshold, and establish as a matter of law that probable cause for Epstein's suit against Edwards existed at the time Epstein filed suit. Edwards' assertions of Epstein's guilt and Edwards' innocence have absolutely no 1 EFTA00583952