IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN individually, J. L.M., individually, individually, and Defendant(s). il MOTION TO FILE AMENDMENT TO TRU& MENDED COUNTERCLAIM Counter-plaintiff, J. 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 a, EPSTEIN voluntarily dismissed that claim, bringing all claims against to (ionclusion. terminatio EDW The circumstances of that dismissal constitute a bona fide claim in al favor and provide the basis for the expansion of urrently pending malicious prosecution claims to encompass that recent development. WHEREFORE, seeks leave to file the proposed Amendment and Order directing EPSTEIN's expedited response. EFTA02771223