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 MOTION FOR PARTIAL SUMMARY JUDGMENT ON COUNTERCLAIM OF DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, files this Motion For Partial Summary Judgment On Counterclaim of Defendant/Counter-Plaintiff BRADLEY EDWARDS ("Edwards") as set forth below, and states: 1. On or about December 21, 2009, Edwards filed a single count Counterclaim against Epstein in which he denies that he had had engaged in any unethical or improper conduct (1 8) and seeks damages for abuse of process based on allegations that Epstein "has filed the claims herein against EDWARDS . . .for the sole purpose of further attempting to intimidate EDWARDS . . . and others into abandoning or settling legitimate claims for less than ...reasonable value" (¶9); Epstein's Complaint against Edwards has no factual support (110); Epstein has "ulterior motives and purposes in exercising such illegal, improper and perverted use of process" including "put[ting] pressure on EDWARDS . . . by publishing what amounts to FOWLER WHITE BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14"' FLOOR. MIAMI, FLORIDA 33131 • EFTA01111289