HOUSE_OVERSIGHT_013354.jpg

sexually assaulted these girls, he had committed several serious torts against them and would be liable to them for appropriate damages. See Preceding Undisputed Facts. Because of the outrageousness of Epstein’s sexual abuse of minor girls, Edwards reasonably expected that Epstein would also be liable for punitive damages to the girls. Because Edwards could show that Epstein had molested children for years and designed a complex premeditated scheme to procure different minors everyday to satisfy his addiction to sex with minors, the punitive damages would have to be sufficient to deter him from this illegal conduct that he had engaged in daily for years. Epstein was and is a billionaire. See Complaint, §49 (referring to “Palm Beach Billionaire”); see also Epstein Deposition, February 17, 2010, at 172-176 (Deposition Attachment #7) (taking the Fifth when asked whether he is a billionaire). Accordingly, Edwards reasonably believed the punitive damages that would have to be awarded against Epstein would have been substantial enough to punish him severely enough for his past conduct as well as deter him from repeating his offenses in the future. See Edwards Affidavit, Exhibit “N” at 719. 85. On July 6, 2010, rather than face trial for the civil suits that had been filed against him by L.M., E.W., and Jane Doe, defendant Epstein settled the cases against him. The terms of the settlement are confidential. The settlement amounts are highly probative in the instant action as Epstein bases his claims that Edwards was involved in the Ponzi scheme on Epstein's inability to “atthe the L.M., E.W., and Jane Doe cases for "minimal value". His continued inability to settle the claims for “minimal value” after the Ponzi scheme was uncovered would be highly probative in discrediting any causal relationship between the Ponzi scheme and Edwards’s settlement negotiations. See Edwards Affidavit, Exhibit “N” at 21. Edwards Non-Involvement in Fraud by Scott Rothstein 36 HOUSE_OVERSIGHT_013354