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, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants. 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 (I) 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 EFTA01111385