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minors. Indeed, in discovery Epstein has asserted his Fifth Amendment privilege rather than answer questions about the extent of the sexual abuse of his many victims. Even more remarkably, since filing his suit against Edwards, Epstein has now settled the three cases Edwards handled for an amount that Epstein insisted be kept confidential. Without violating the strict confidentiality terms required by Epstein, the cases did not settle for the “minimal value” that Epstein suggested in his Complaint. Because Epstein relies upon the alleged discrepancy between the “minimal value” Epstein ascribed to the claims and the substantial value Edwards sought to recover for his clients, the settlement amounts Epstein voluntarily agreed to pay while these claims against Edwards were pending will be disclosed to the court in-camera.

B. Summary of the Argument

Bradley J. Edwards, Esq., is entitled to summary judgment on Epstein’s frivolous claim for at least three separate reasons.

First, because Epstein has elected to hide behind the shield of his right against self incrimination to preclude his disclosing any relevant information about the criminal activity at the center of his claims, he is barred from prosecuting this case against Edwards. Under the well-established “sword and shield” doctrine, Epstein cannot seek damages from Edwards while at the same time asserting a Fifth Amendment privilege to block relevant discovery. His case must therefore be dismissed.

Second, all of Edwards’ conduct in the prosecution of valid claims against Epstein is protected by the litigation privilege.

Third, and most fundamentally, Epstein’s lawsuit should be dismissed because it is not only unsupported by but is also directly contradicted by all of the record evidence. From the

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