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Case No.: 502009CA040800XXXXMBAG Edwards’ Opposition to Epstein's Motion for Summary Judgment Page 4 of 15 None of the public materials identified by Epstein in his Motion make reference to any wrongdoing by Brad Edwards. Rather, Epstein seeks to pyramid one impermissible inference upon another from his citation to these materials to support his otherwise unsubstantiated and non-verifiable conclusion that he had sufficient evidence to proceed with claims of wrongdoing against Edwards. In truth, as reflected in Edwards’ deposition and his supplemental affidavit, he has no involvement in any fraud perpetrated by Rothstein (Edwards’ deposition of March 23, 2010 at 301-302; Edwards Affidavit attached to Statement of Undisputed Facts as Exhibit “N” at paragraphs 8-10, paragraph 20, paragraphs 22-23; Exhibit “H” — Deposition of Scott Rothstein at pp. 62-63, 114, and 121-124). Therefore, any allegations relating to Rothstein’s activities simply have no bearing on the legitimacy of any of the claims against Edwards. Edwards could not have possibly “pumped” cases to investors when he never participated in any communications with investors. Rather, Edwards had a duty to his clients to zealously pursue discovery to achieve a maximum recovery against Epstein. Edwards cannot be liable for taking appropriate action that his ethical duties as an attorney required. The evidence also reflects that Edwards filed all three of his cases almost a year before he was hired by RRA or even knew Scott Rothstein (Edwards’ Affidavit, Exhibit “N” attached to Statement of Undisputed Facts). The language set forth in his Complaints remain virtually unchanged from the first filing in 2008 and, as the evidence shows, the claims asserted against Epstein from the outset were true. The citation to public documents is a convenient ruse; Epstein was not only liable for the molestation of the clients of Brad Edwards, he was also a serial molester of minors — even as young as twelve years of age (Exhibit “A” — Edwards’ Statement of Undisputed Material Facts paragraphs 1-43; Exhibit “D” — Statement of Virginia Roberts pp. 16-17). Epstein entered a plea of guilty to felony charges involving prostitution and the solicitation of a minor for the purposes of prostitution (Exhibit “E” — Deposition of Jeffrey Epstein, March 17, 2010, pp. 101-103). Epstein also entered into an agreement with the United States Attorney’s Office acknowledging that approximately 34 other young girls could receive payments from him under the HOUSE_OVERSIGHT_013307