IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants. Complex Litigation, Fla. R. Civ. Pro. 1201 Case No. 50 2009 CA 040800XXXXMBAG PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' COUNTERCLAIM 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 Summary Judgment on Defendant/Counter-Plaintiff Bradley Edwards' Counterclaim, and states as follows : I. SUMMARY OF ARGUMENT Summary judgment should be entered in favor of Epstein on Edwards' single-count Counterclaim for abuse of process because it is legally insufficient and Edwards can offer no facts in support of his allegations that would support a claim for abuse of process against Epstein. The crux of Edwards' Counterclaim is that Epstein's mere filing of his lawsuit against Edwards was improper. Edwards does not allege any misuse of process by Epstein after Epstein filed his lawsuit against Edwards. As a matter of settled Florida law, an abuse of process claim based solely on the filing of an allegedly unfounded complaint, which is all that Edwards has alleged, does not state a valid claim for abuse of process. "Process" must occur subsequent to FOWLER WHITE BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14"' FLOOR. MIAMI, FLORIDA 33131 EFTA01111295