IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. Case No. 50 2009 CA 040800XXXXMBAG SUMMARY OF PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT AND INCORPORATED MEMORANDUM OF LAW Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to this Court's Order dated November 4, 2013 setting this Motion for Hearing', files this Summary of his Motion for Summary Judgment on Defendant/Counter-Plaintiff Bradley Edwards's Fourth Amended Counterclaim, and states: I. SUMMARY OF THE ARGUMENT Epstein filed this action to recover damages from Co-Defendants Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards") based upon Epstein's well-founded belief at the time of filing his Complaint that these two individuals, among others, engaged in serious misconduct involving a widely publicized illegal pyramid scheme operated through their law firm, Rothstein, Rosenfeldt & Adler ("RRA"). To further the Ponzi Scheme, civil cases were used as bait to lure unsuspecting investors into the fraudulent scheme, including cases being prosecuted against Epstein by RRA through its Partner and lead counsel, Bradley J. Edwards. In response to Epstein's original lawsuit, Edwards filed a Counterclaim, and after a series of dismissals and multiple revisions thereof, Edwards alleges two causes of action against Epstein: Epstein's Motion for Summary Judgment was filed before the Hearing was set and the Court issued its order, which states that submissions should not exceed ten (10) pages. In accordance with that order, Epstein submits this summary of his Motion. EFTA01122209