Filing # 58499694 E-Filed 06/30/2017 01:24:10 PM IN THE CIRCUIT COURT OF THE 1-1EENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG v. BRADLEY J. EDWARDS, et al., Defendants/Counter-Plaintiff. JUDGE HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' FOURTH AMENDED COUNTERCLAIM 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' ("Edwards") Fourth Amended Counterclaim, Malicious Prosecution. INTRODUCTION In order to prevail on his claim of Malicious Prosecution, Edwards must prove, among other things, that Epstein did not have probable cause to initiate his lawsuit against Edwards at the time that he did so. The threshold of facts required 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 (M.D Fla. 2000). The specific facts cited herein, which are independently verifiable from numerous independent sources, including multiple court filings, are indisputable, far exceed the minimal threshold, and establish as a matter of law that Epstein had legally sufficient probable cause to file suit against Edwards at the time he did so. EFTA00619811