IN THE CIRCUIT COURT OF TIE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defendant(s). MOTION TO FILE AMENDMENT TO THIRD AMENDED COUNTERCLAIM Counter-plaintiff, BRADLEY J. EDWARDS, by and through his undersigned counsel, moves this Honorable Court to permit the filing of the accompanying Amendment to the Third Amended Counterclaim and in support thereof would show that on the eve of the summary judgment hearing scheduled to address Plaintiff, JEFFREY EPSTEIN'S, abuse of process claim against EDWARDS, EPSTEIN voluntarily dismissed that claim, bringing all claims against EDWARDS to a conclusion. The circumstances of that dismissal constitute a bona fide termination of the claim in EDWARDS' favor and provide the basis for the expansion of EDWARDS' currently pending malicious prosecution claims to encompass that recent development. WHEREFORE, EDWARDS seeks leave to file the proposed Amendment and Order directing EPSTEIN's expedited response. EFTA01112638