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Case No.: 502009CA040800XXXXMBAG Edwards' Opposition to Epstein's Motion for Summary Judgment Page 6 of 15 undisputed facts submitted by Mr. Edwards in support of his Motion for Summary Judgment, Edwards had a sound legal basis for believing that Donald Trump, Allen Dershowitz, Bill Clinton, Tommy Mattola, David Copperfield and Governor Bill Richardson had relevant and discoverable information (Exhibit “A” — Edwards’ Statement of Undisputed Facts, paragraphs 69-81). That belief was reinforced by the testimony of Virginia Roberts (Exhibit “D” pp. 10-17, 21-23). Epstein’s assertion of impropriety in the pursuit of this discovery clearly evidences his bad faith attempts to attribute wrongdoing to Edwards when he knew, in fact, that the pursuit of that discovery was entirely appropriate under the circumstances of this case. Finally, any attempt by Epstein to rely upon what he claims are undisputed facts to support his Motion for Summary Judgment are undermined by his refusal to provide any testimony on the key issues and evidence which would demonstrate the validity and strength of each of the claims brought against him by Brad Edwards. Epstein’s depositions of March 17, 2010 and January 25, 2012 were replete with refusals of Epstein to testify based upon his Fifth Amendment privilege. Questions that Epstein refused to answer in his depositions and the reasonable inferences that a fact finder would draw and which would otherwise bear on the arguments submitted by Epstein in support of his Motion for Summary Judgment are as follows: e Question not answered: “I want to know whether you have any knowledge of evidence that Bradley Edwards personally ever participated in devising a plan through which were sold purported confidential assignments of a structured payout settlement?” Reasonable inference: No knowledge that Brad Edwards ever participated in the Ponzi scheme. e Question not answered: “Specifically what are the allegations against you which you contend Mr. Edwards ginned up?” Reasonable inference: No allegations against Epstein were ginned up. © Question not answered: “Well, which of Mr. Edwards’ cases do you contend were fabricated?” Reasonable inference: No cases filed by Edwards against Epstein were fabricated. HOUSE_OVERSIGHT_013309