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beginning, Edwards diligently represented three victims of sexual assaults perpetrated by
Epstein. As explained in detail below, each and every one of Edwards’s litigation decisions was
grounded in proper litigation judgment about the need to pursue effective discovery against
Epstein, particularly in the face of Epstein’s stonewalling tactics. Edwards’s successful
representation finally forced Epstein to settle and pay appropriate damages. Effective and proper
representation of child victims who have been repeatedly sexually assaulted cannot form the
basis of a separate, “satellite” lawsuit, and therefore Edwards is entitled to summary judgment on
these grounds as well.

The truth is the record is entirely devoid of any evidence to support Epstein’s claims and
is completely and consistently corroborative of Edwards’s sworn assertion of innocence. Put
simply, Epstein has made allegations that have no basis in fact. To the contrary, his lawsuit was
merely a desperate measure by a serial pedophile to prevent being held accountable for
repeatedly sexually abusing minor females. Epstein’s ulterior motives in filing and prosecuting
this lawsuit are blatantly obvious. Epstein’s behavior is another clear demonstration that he feels
he lives above the law and that because of his wealth he can manipulate the system and pay for
lawyers to do his dirty work - even to the extent of having them assert baseless claims against
other members of the Florida Bar. Epstein’s Second Amended Complaint against Edwards is
nothing short of a far-fetched fictional fairy-tale with absolutely no evidence whatsoever to
support his preposterous claims. It was his last ditch effort to escape the public disclosure by
Edwards and his clients of the nature, extent, and sordid details of his life as a serial child
molester. Edwards’s Motion for Summary Judgment should be granted without equivocation.

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