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, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and E., individually, Defendants. Case No. 50 2009CA040800)OOOVIB AG MOTION OF COUNTER-DEFENDANT, JEFFREY EPSTEIN, FOR A MORE DEFINITE STATEMENT AND MOTION TO DISMISS Counter-Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, pursuant to Rule 1.140(b)(6) and Rule 1.140(e), Florida Rules of Civil Procedure, moves this court for an order for a more definite statement or in the alternative dismiss the Counterclaim and as grounds set forth would state: 1. The Plaintiff in this instance has filed a multi-count Complaint against Scott Rothstein, Bradley J. Edwards and M. (a Plaintiff in a pending lawsuit against Epstein), arising out of the Rothstein, Rosenfeldt & Adler, M.'s law firm implosion and the racketeering operation as set forth by the United States of America in its information against Scott Rothstein. 2. Contrary to the Defendant/Counter-Plaintiffs allegations in his Counterclaim, the factual basis for the racketeering conspiracy operated by the firm, Rothstein and others, is factually set forth in other lawsuits which have been filed by investors who in part, have specifically identified Epstein cases as being part of the EFTA00594275