IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50 2009CA040800XXXXMB AG JEFFREY EPSTEIN Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. EPSTEIN'S MOTION TO DISMISS EDWARDS'S COUNTERCLAIM Plaintiff, JEFFREY EPSTEIN ("Epstein"), pursuant to Fla. R. Civ. P. 1.140(b), moves to dismiss the Counterclaim for abuse of process filed by Defendant, Bradley J. Edwards ("Edwards"), and states: 1. On December 21, 2009, Edwards answered the Complaint filed by Epstein and asserted a Counterclaim (attached as Exhibit A). 2. Epstein filed a Motion for More Definite Statement and Motion to Dismiss Edwards's Counterclaim as it was unclear what cause of action Edwards was attempting to assert. 3. On January 26, 2010, the Court entered an order (attached as Exhibit B) reflecting that "upon stipulation of counsel [ I, the claim is solely an abuse of process claim." 4. Edwards's Counterclaim fails to state an action for abuse of process. Specifically, Edwards fails to allege any wrongful act or misuse of process after the initial process was issued. EFTA00611281