IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION TO DISMISS THE AMENDED COMPLAINT Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel, hereby offers the following response in opposition to Defendant/Counter- Plaintiff EDWARDS' ("EDWARDS") motion to dismiss the Amended Complaint and states: 1. EDWARDS' one-page motion to dismiss is perfunctory and conclusory, cites no— supporting authorities, and contains no valid arguments supporting dismissal. The Amended Complaint satisfies all of the elements of a cause of action for abuse of process, and EDWARDS has not demonstrated otherwise. 2. It is axiomatic that a motion to dismiss for failure to state a cause of action admits all well-pleaded facts as true and that the allegations and reasonable inferences therefrom must be construed in the light most favorable to the plaintiff. See, e.g., Morris v. Fla. Power & Light Co., 753 So. 2d 153, 154 (Fla. 4th DCA 2000) ("[A] complaint should not be dismissed for failure to state a cause of action 'unless the movant can establish beyond any doubt that the claimant could prove no set of facts whatever in support of his claim."); Sault v. Ruden, EFTA01103321