Filing # 62118872 E-Filed 09/28/2017 10:54:46 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800VOOLMBAG v. et al., JUDGE HAFELE Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MO SUMMARY GMENT ON DEFENDANT/COUNTER-PLAINTIFFilia FOURTH AMENDED COUNTERCLAIM AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, hereby files this Motion for Summary Judgment on the aolxemaining count of Defendant/Counter-Plaintiff (a'') Fou C Counterclaim, Malicious Prosecution. '%J$TRODUCTION In order to prevail on ' _ol)aim of Malicious Prosecution, must prove, among other things, that Epsteirtd not have probable cause to initiate his lawsuit against at the time that he did so. The threshold of facts required to establish probable cause that will defeat M claim for malicious prosccution, is "extremely low and easily satisfied." IMI v. Kostroff 82 F.Supp. 2d 1354, 1364 (M.D Fla. 2000). The specific facts cited herein, which are independently verifiable from numerous independent sources, including multiple court filings, are indisputable, far exceed the minimal threshold, and establish as a matter of law that Epstein had legally sufficient probable cause to file suit against at the time he did so. Ex4rarr A FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 09/28/2017 10:54:46 AM EFTA02777510