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Case No.: 502009CA040800XXXXMBAG
Edwards' Opposition to Epstein's Motion for Summary Judgment
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they were true. Epstein knew that he had in fact molested each of the minors represented by Brad
Edwards. He also knew that each litigation decision by Brad Edwards was grounded in proper litigation
judgment about the need to pursue effective discovery against Epstein, particularly in the face of
Epstein’s stonewalling tactics. Epstein also knew that he suffered no legally cognizable injury
proximately caused by the falsely alleged wrongdoing on the part of Edwards. Moreover, Epstein had no
intention of waiving his Fifth Amendment privilege against self-incrimination in order to avoid providing
relevant and material discovery that Epstein would need in the course of prosecuting his claims and to
which Edwards was entitled in defending those claims. Epstein knew that his prosecution of his claims
would be barred by the sword-shield doctrine. Most significantly, the evidence submitted in the
supporting papers would compel a fact finder to determine that Epstein had no basis in law or in fact to
pursue his claims against Edwards and that Epstein was motivated by a single ulterior motive to attempt
to intimidate Edwards and his clients and others into abandoning or settling their legitimate claims for
less than their just and reasonable value. The evidence demonstrates that Epstein did not file these claims
for the purpose of collecting money damages since he knew that he never suffered any damage as a
consequence of any alleged wrongdoing by Edwards but filed the claim to require Edwards to expend
time, energy and resources on his own defense, to embarrass Edwards and impugn his integrity and deter
others with legitimate claims against Epstein from pursuing those claims. Indeed, the evidence
demonstrates that Epstein continued to pursue his claims by filing the Second Amended Complaint
alleging abuse of process against Edwards even after he had paid significant sums in settlement of the
claims instituted by Mr. Edwards’ clients against Mr. Epstein.¹

¹ The evidence marshalled in support of these assertions is set forth in the previously filed documents in this Court.
Those documents include Exhibit “A” – Edwards’ Statement of Undisputed Facts; Exhibit “B” – Edwards’ Renewed
Motion for Summary Judgment; Exhibit “C” – Edwards’ October 19, 2012 Second Renewed Motion for Leave to
Assert Claim for Punitive Damages; Exhibit “D” – Edwards’ Notice of Filing of Transcript of Telephone Interview
of Virginia Roberts in Support of Motion for Leave to Amended to Assert Punitive Damages; Exhibit “E” –
Transcript of Deposition of Jeffrey Epstein dated January 25, 2012; Exhibit “F” – Deposition of Bradley Edwards
dated March 23, 2010; Exhibit “G” - Deposition of Scott Rothstein dated June 14, 2012; Exhibit “H” – Order of

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