IN THE CIRCUIT COURT OF THE HI- I EENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOO(MBAG JEFFREY EPSTEIN, Plaintiff, vs. • SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, COUNTER-PLAINTIFF, BRADLEY J. EDWARDS' REPLY TO JEFFREY EPSTEIN'S MEMORANDUM IN OPPOSITION TO SECOND RENEWED MOTION FOR LEAVE TO ASSERT A CLAIM FOR PUNITIVE DAMAGES The principal attack on the sufficiency of Edwards' Motion for Leave to Assert a Claim for Punitive Damages is to point out the similarity between the proffer supporting that motion and Edwards' Motion for Summary Judgment. Epstein either fails to appreciate or chooses to ignore the fact that the evidence supporting a summary judgment in favor of the defense on the claims that form the basis for a malicious prosecution action is, of necessity, the identical evidence necessary to support a claim for punitive damages on the malicious prosecution claim itself. In other words, for Edwards to establish his entitlement to summary judgment on the various claims asserted by Epstein against him, it was necessary for Edwards to establish that there were no disputed facts and that the undisputed facts established the propriety of all of Edwards' actions against Epstein. That same evidence is essential in establishing Epstein's absence of probable cause to support any of Epstein's claims against Edwards. While the EFTA01145760