IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTI [STEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. JUL 1 9 2011 MOTION FOR LEAVE TO AMEND TO ASSERT A CLAIM FOR PUNITIVE DAMAGES Defendant, Bradley J. Edwards, Esq., by and through his undersigned counsel and pursuant to Rule 1.190(f), Florida Rules of Civil Procedure, hereby moves for leave to amend to assert a claim for punitive damages, and in support thereof relies upon the following evidence in the record and such additional evidence as is herein proffered*: I. INTRODUCTION The pleadings, discovery taken to date, and the evidence proffered with this motion show that a reasonable basis exists to support the recovery of punitive damages against the Counter- Defendant, Jeffrey Epstein. Not only is there an absence of competent evidence to demonstrate that Edwards participated in any fraud against Epstein, the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards's involvement in the prosecution of legitimate claims against Epstein and the fact that the sole basis for the assertion of the spurious claims filed against Edwards was an attempt to intimidate Edwards into abandoning EFTA01100999