IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOO(MBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). 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 conclusory 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 apparently never served on him,* the Amenclid:Complaint fails to identify the "process" alleged to be abusive, on whom it is claimed .to hayetbe41 served, or when it is claimed to have been served; *Paragraph 30(b) of the Second Amended Complaint references a federal civil action with which "Edwards 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. EFTA01100909