IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and In, individually, Defendant. MOTION PURSUANT TO F.S. 457.105 Defendant, moves this Honorable Court for the imposition of sanctions pursuant to the provisions of F.S. §57.105 on the basis that the Plaintiff and his counsel knew or reasonably should have known that the Plaintiffs claims against ■., when initially presented to the court or subsequent thereto: a) were not supported by the material facts necessary to establish the claims and/or the defenses; or b) were not and would not be supported by the application of then existing law to those material facts. EFTA01082682