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Case No.: 502009CA040800XXXXMBAG Edwards' Opposition to Epstein's Motion for Summary Judgment Page 7 of 15 e Question not answered: “Did sexual assaults ever take place on a private airplane on which you were a passenger?” Reasonable inference: Epstein was on a private airplane while sexual assaults were taking place. e Question not answered: “How many minors have you procured for prostitution?” Reasonable inference: Epstein has procured multiple minors for prostitution. © Question not answered: “Is there anything in L.M.’s Complaint that was filed against you in September of 2008 which you contend to be false?” Reasonable inference: Nothing in L.M.’s complaint filed in September of 2008 was false —i.e., as alleged in L.M.’s complaint, Epstein repeatedly sexually assaulted her while she was a minor and she was entitled to substantial compensatory and punitive damages as a result. e Question not answered: “J would like to know whether you ever had any physical contact with the person referred to as Jane Doe in that [federal] complaint?” Reasonable inference: Epstein had physical contact with minor Jane Doe as alleged in her federal complaint. e Question not answered: “Did you ever have any physical contact with E.W.?” Reasonable inference: Epstein had physical contact with minor E.W. as alleged in her complaint. e Question not answered: “What is the actual value that you contend the claim of E.W. against you has?” Reasonable inference: E.W.’s claim against Epstein had substantial actual value. (See Exhibit “A” — Edwards’ Statement of Undisputed Material Facts, paragraphs 93-120 for page references.) A jury could conclude, therefore, from the adverse inferences drawn against Epstein that he was liable for the claims brought by Brad Edwards and that he had no basis for the pursuit of his efforts to intimidate and extort Edwards and his clients in the pursuit of those claims. The Litigation Privilege Does Not Bar the Claims of Abuse of Process and Malicious Prosecution Epstein contends he is entitled to absolute immunity pursuant to the litigation privilege as to both claims asserted by Edwards because all actions taken by him occurred during the litigation of his abuse of process claim against Edwards. For support, he relies primarily on the decision of Wolfe v. Foreman, 2013 WL 3724763 (Fla. 3d DCA July 17, 2013), wherein the Third District found that the litigation privilege barred both an abuse of process claim and a malicious prosecution cause of action. Wolfe is still HOUSE_OVERSIGHT_013310