.4 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. JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN individually, J. individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFF EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTEFtPLAINTIFF MOTION FOR ATTORNEY'S FEES PURSUANT TO FLA. STAT. 657.105 Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel, hereby offers the Defendant/Counterplaintiff Bradley J. NM' following Response In Opposition To Motion For Attorney's Fees Pursuant To Fla. Stat. §57.105, and states as follows : I. SUMMARY OF ARGUMENT M' frivolous. motion for attorney's fees pursuant to §57.105, Fla. Stat. ("O7.105 motion"), is seeks sanctions against Epstein based upon Epstein's service of a §57.105(4) notice of intent directed to IMF §57.105 motion that Counterclaim for abuse of process. Epstein asserted in his abuse of process counterclaim was legally insufficient because it did not allege any abuse of process after Epstein filed his Complaint. At a September 28, 2011 hearing, this Court expressed the same concern that Counterclaim for abuse of process did not state a valid claim because it failed to allege any improper process by Epstein subsequent EFTA02770154