HOUSE_OVERSIGHT_013394.jpg

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXX XMBAG JEFFREY EPSTEIN, Plaintiff(s), VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). ., SCOUNTER-PLAINTIFF; EDWARDS’ SECOND RENEWED MOTION.FORLEAVE TO: -. - ASSERT CLAIM FOR PUNITIVE DAMAGES Counter-plaintiff, BRADLEY J. EDWARDS, moves this Honorable Court for entry of an ier granting him leave to assert a claim for punitive damages against # the Counter- defendant, JEFFREY EPSTEIN, and in support thereof swonilal show that the evident summarized herein satisfies the statutory prerequisites for the assertion of a punitive damage cl claim. Specifically, the evidence establishes that EPSTEIN’s Complaint against EDWARDS; 1. was filed in the total absence of evidence to support any allegation of wrongdoing on the part of EDWARDS; ds was filed in the total absence of evidence that EPSTEIN had sustained damage as a consequence of any misconduct other than his own well-established criminal enterprise; 3. was filed in the absence of any intention to meet his own obligation to provide relevant and material discovery; EXHIBIT | HOUSE_OVERSIGHT_013394