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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, Vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, / DEFENDANT/COUNTER-PLAINTIFF’S RESPONSE IN OPPOSITION TO PLAINTIFF/COUNTER-DEFENDANT’S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF’S FOURTH AMENDED COUNTERCLAIM Defendant/Counter-Plaintiff Bradiey J. Edwards, by and through his undersigned counsel, hereby submits this Response in Opposition to Plaintiff/Counter-Defendant Jeffrey Epstein’s Motion for Summary Judgment. Epstein seeks Summary Judgment on the claims of abuse of process and malicious prosecution set forth in Brad Edwards’ Fourth Amended Counterclaim. Each of the grounds asserted in support of Epstein’s Motion for Summary Judgment are without merit and must be denied. In Epstein’s Amended Complaint he carries forth the essence of all claims asserted in his original Complaint. In that pleading Epstein essentially alleges that Edwards joined Rothstein in the abusive prosecution of sexual assault cases against Epstein to “pump” the cases to Ponzi scheme investors. The purported “proof” of the allegations against Edwards, as referenced in the Second Amended Complaint and in Epstetn’s Motion for Summary Judgment, includes Edwards’ alleged contacts with the media, his attempts to obtain discovery from high profile persons with whom Epstein socialized, press reports of Rothstein’s known illegal activities, the use of “ridiculously inflammatory” language and arguments in court. But as the evidence submitted in opposition to Epstein’s Motion for Summary Judgment reflects, Epstein filed his claims and continued to pursue claims despite his knowledge that his claims could never be successful because they were both false and unsupported by any reasonable belief of suspicion that HOUSE_OVERSIGHT_013304