IN THE CIRCUIT COURT OF THE

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, ANSWER AND AFFIRMATIVE DEFENSES TO SECOND AMENDED COMPLAINT Defendant, BRADLEY J. EDWARDS (EDWARDS), responds to Plaintiffs Introduction by stating that it is irrelevant surplusage requiring no answer. GENERAL ALLEGATIONS I. Defendant, EDWARDS, denies the allegations contained in paragraph 1 and demands strict proof thereof. 2. Admitted. 3. Admitted. 4. Admitted. 5. Defendant, EDWARDS, denies the allegations contained in paragraph 5 and demands strict proof thereof. 6. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in paragraph 6 so therefore denies same and demands strict proof thereof. EFTA01100786 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG ANSWER TO SECOND AMENDED COMPLAINT Page 2 of 6 7. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in paragraph 7 so therefore denies same and demands strict proof thereof. 8. Defendant, EDWARDS, admits that RRA was engaged in litigation against Epstein in three civil cases, but Defendant, EDWARDS, is without knowledge to either admit or deny the balance of the allegations of paragraph 8 so therefore denies same and demands strict proof thereof. 9. Admitted. 10. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in paragraph 10 so therefore denies same and demands strict proof thereof. 11. Defendant, EDWARDS, admits that Fisten and Jenne provided investigative services relating to the prosecution of the Epstein Actions. Defendant, EDWARDS, denied the balance of the allegations of paragraph 11 and demands strict proof thereof 12. Defendant, EDWARDS, admits that Fisten and Jenne reported to Edwards regarding matters related to the Epstein Actions. Defendant, EDWARDS, is without knowledge as to the balance of the allegations of paragraph 12 so therefore denies same and demands strict proof thereof. 13. Admitted. 14. Defendant, EDWARDS, admits that Edwards incurred costs in the prosecution of the Epstein Actions. Defendant, EDWARDS, is without knowledge as to the balance of the allegations of paragraph 14 so therefore denies same and demands strict proof thereof. EFTA01100787 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG ANSWER TO SECOND AMENDED COMPLAINT Page 3 of 6 15. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in paragraph 15 so therefore denies same and demands strict proof thereof. 16. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in paragraph 16 so therefore denies same and demands strict proof thereof. 17. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in paragraph 17 so therefore denies same and demands strict proof thereof. 18. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in paragraph 18 so therefore denies same and demands strict proof thereof. 19. Defendant, EDWARDS, has accurately testified regarding the prosecution of the Epstein Actions and all conflicting allegations are denied and defendant demands strict proof thereof. 20. Defendant, EDWARDS, has accurately testified regarding the prosecution of the Epstein Actions and all conflicting allegations are denied and defendant demands strict proof thereof. 21. Admitted. 22. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in paragraph 22 so therefore denies same and demands strict proof thereof. 23. Admitted. 24. Defendant, EDWARDS, admits the allegations contained in subparts (e) and (I) of paragraph 24. Defendant, EDWARDS, denies the balance of the allegations contained in paragraph 2 and demands strict proof thereof. EFTA01100788 Edwards adv. Epstein Case No.: 502009CA040%00XXXXMBAG ANSWER TO SECOND AMENDED COMPLAINT Page 4 of 6 25. Defendant, EDWARDS, denies the allegations contained in paragraph 25 and demands strict proof thereof. 26. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in paragraph 26 so therefore denies same and demands strict proof thereof. 27. Admitted. 28. Defendant, EDWARDS, admits that Rothstein was arrested, arraigned in federal court, pled guilty and ultimately was sentenced to a 50 year prison sentence for fraud and racketeering. Defendant, EDWARDS, is without knowledge as to the balance of the allegations contained in paragraph 29 so therefore denies same and demands strict proof thereof. COUNT I: ABUSE OE PROCESS-EDWARDS 29. Defendant, EDWARDS, admits or denies each of the allegations contained in paragraphs I through 28 as if fully set forth here. 30. Defendant, EDWARDS, denies the allegations contained in paragraph 30 and demands strict proof thereof. 31. Admitted. 32. Defendant, EDWARDS, denies the allegations contained in paragraph 32 and demands strict proof thereof. 33. Defendant, EDWARDS, denies the allegations contained in paragraph 33 and demands strict proof thereof. 34. Defendant, EDWARDS, denies the allegations contained in paragraph 34 and demands strict proof thereof. EFTA01100789 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG ANSWER TO SECOND AMENDED COMPLAINT Page 5 of 6 COUNT II: CONSPIRACY TO COMMIT ABUSE OF PROCESS-ROTHSTEIN 35. The allegations of paragraphs 35-39 are not directed to Defendant, EDWARDS, and are therefore not responded to. AFFIRMATIVE DEFNSES 1. The actions of EDWARDS are absolutely protected from liability in accordance with the litigation privilege. 2. The actions of EDWARDS are qualifiedly protected in accordance with the litigation privilege. 3. The claims against EDWARDS are barred by the sword-shield doctrine. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S. Mail to all counsel on the attached !is , Jack Seam Florida t r No.: 169440 Scare $enney Scarola Barnhart & Shipley, P.A. 21/3 Palm Beach Lakes Boulevard West Palm Beach Florida 33409 Phone: Fax: Attorneys for BRADLEY J. EDWARDS 28th day of October, 2011. 6 - 6 -6-1-e.‘,--- / EFTA01100790 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG ANSWER TO SECOND AMENDED COMPLAINT Page 6 of 6 COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. Attorney For: Jeffrey Epstein 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: Fax: Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL Attorney For: Jeffrey Epstein 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: Fax: Marc S. Nurik, Esquire Law Offices of Marc S. Nurik Attorney For: Scott Rothstein One E Broward Blvd., Suite 700 Fort Lauderdale FL 33301 Phone: Fax: Joseph L. Ackerman, Jr., Esquire Fowler White Burnett, P.A. Attorney For: Jeffrey Epstein 901 Phillips Point West 777 S Flagler Drive West Palm Beach, FL 33401-6170 Phone: Fax: EFTA01100791