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Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Renewed Motion for Leave to Assert Claim for Punitive Damages

It is thus neither necessary nor appropriate for a court to make evidentiary rulings,
weigh rebuttal evidence, or engage in credibility determinations in considering the
sufficiency of the proffer.

"...a proffer should be evaluated by standards akin to those governing a motion to
dismiss, where the truth of the plaintiff's allegations are assumed, and not the
more rigorous summary judgment standard, where the opposing party must show
that there is sufficient admissible evidence in the record to support a reasonable
jury finding in his favor."

I. INTRODUCTION

The pleadings and discovery taken to date as confirmed by Epstein's voluntary dismissal
of all claims brought by him against Bradley J. Edwards, show that there is an absence of
competent evidence to demonstrate that Edwards participated in any fraud against Epstein, show
the propriety of every aspect of Edwards' involvement in the prosecution of legitimate claims
against Epstein, and further support the conclusion that Epstein sued Edwards out of malice and
for the purpose of intending to intimidate Edwards and Edwards' clients into abandoning or
compromising their legitimate claims against Epstein. Epstein sexually abused three clients of
Edwards – L.M., E.W., and Jane Doe – and Edwards properly and successfully represented them
in a civil action against Epstein. Nothing in Edwards' capable and competent representation of
his clients could serve as the basis for a civil lawsuit against him. Allegations about Edwards's
participation in or knowledge of the use of the civil actions against Epstein in a "Ponzi Scheme"
were never supported by probable cause or any competent evidence and could never be
supported by competent evidence as they are entirely false.

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