IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO DAMAGES PLED IN BRADLEY EDWARDS' SECOND AMENDED COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, pursuant to this Court's Order on March 29, 2012, respectfully submits this Memorandum Of Law In Opposition To Damages Pled In Bradley Edwards' Second Amended Counterclaim, and states as follows: In his Second Amended Counterclaim, Edwards seeks the following damages from Epstein for alleged abuse of process: injury to Edwards' reputation, "interference in his professional relationships, the loss of the value of his time required to be diverted from his professional responsibilities, and the cost of defending against Epstein's spurious and baseless claims." (Second Amended Counterclaim, ¶17). Edwards seeks precisely the same damages for alleged malicious prosecution. (See Second Amended Counterclaim, ¶33). No other damages are specifically pled. EFTA01111213