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. / CIVIL DIVISION AG Case No. 502009CA040800XXXXMBAG PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS AMENDED COUNTERCLAIM AND INCORPORATED MEMORANDUM OF LAW Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel, hereby moves to dismiss the Amended Counterclaim of the Defendant/Counter-Plaintiff, BRADLEY EDWARDS ("Edwards"), and in support thereof states as follows : I. SUMMARY OF ARGUMENT Edwards' Amended Counterclaim should be dismissed because it fails to state an actionable claim against Epstein for abuse of process or malicious prosecution. Count I fails to state a valid abuse of process claim because Edwards does not -- and cannot -- allege (1) that Epstein made any illegal, improper, or perverted use of process; (2) that Epstein had any ulterior motive or purpose at any time; and (3) that Edwards suffered any legally cognizable damage as a result of Epstein's actions in the pending litigation. Count II fails to state a valid claim for malicious prosecution because Edwards does not -- and cannot -- allege that there was a bona fide termination of an original proceeding in his favor, much less that any such original EFTA01111357