08/23/2011 18:38 FAX 5618845818 SEARCY DENNEY gho01/003 JEFFREY EPSTEIN, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and MI individually, Plaintiff(s), Defendant(s). IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXM BAG MOTION TO DISMISS SECOND AMENDED COMPLAINT Defendant/Counter-plaintiff, BRADLEY J. EDWARDS, moves this Honorable Court to dismiss the Second Amended Complaint against him for failure to state a cause of action and in support thereof would show: 1. the "Introduction" to the Second Amended Complaint is nothing more than coriclusory surplusage apparently intended to defame Mr. Edwards under the protection of the litigation privilege; 2. Except for the filing of a federal complaint that did not name Epstein and was appiar i ently never served on him,* the Amended Complaint fails to identify the "process" alleged to be abusive, on whom it is claimed to have been sewed, or when it is claimed to have been ser*ed; *I13 ragraph 30(b) of the Second Amended Complaint references a federal civil action with which "Sowards was never served." Presumably, since the complaint is alleged to have been filed by Edwards, the allegation was meant to have referenced Epstein rather than Edwards. EFTA00594303