JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XVOCMBAG JUDGE: CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO BIFURCATE TRIAL Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.270(b) of the Florida Rules of Civil Procedure, hereby files this Motion to Bifurcate the Trial in this matter. In support thereof, Epstein states: INTRODUCTION On December 19, 2012, this Honorable Court granted Defendant/Counter- Plaintiff Bradley J. Edwards's (hereinafter "Edwards") Motion for Leave to Assert Claim for Punitive Damages against Epstein. This case is currently scheduled on this Court's October 2013 Trial Calendar. Edwards has alleged two causes of action in this matter against Epstein; one for malicious prosecution and one for abuse of process. Damages are a requisite for each cause of action. Before Edwards is permitted to present a case for punitive damages, he must first prove these claims against Epstein. Epstein has denied liability as to these claims and has asserted various affirmative defenses, which include Edwards's failure to state a cause of action in both abuse of process and malicious prosecution; Edwards's failure to properly plead damages; Edwards's inability to overcome the absolute immunity afforded to 1 EFTA01102332