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minors. Epstein purports to find a cause of action for this by alleging that Edwards somehow was involved in “’pumping’ these three cases to investors.” As just explained, to the extent that Epstein is alleging that Edwards somehow did sontething related to the Ponzi scheme, those allegations fail for the simple reason that Edwards was not involved in any such scheme. Edwards, for example, could not have possibly “pumped” the cases to investors when he never participated in any communication with investors. Epstein’s “pumping” claims, however, fail for an even more basic reason: Edwards was ntitiad — indeed ethically obligated as an attorney — to secure the maximum recovery for his clients during the course of his legal representation. As is well known, “[a]s an advocate, a lawyer zealously asserts the client’s position under the rules of the adversary system.” Fla, Rules of Prof. Conduct, Preamble. Edwards therefore was required to pursue (unless otherwise instructed by his clients) a maximum recovery against Epstein. Edwards, therefore, cannot be liable for doing something that his ethical duties as an attorney required. Another reason that Epstein’s claims that Edwards was “pumping” cases for investors fails is that Edwards filed all three cases almost a year before he was hired by RRA or even knew of Scott Rothstein. Epstein makes allegations that the complaints contained sensational allegations for the purposes of luring investors; however, language in the complaints remained virtually unchanged from the first filing in 2008 and from the overwhelming evidence the Court can see for itself that all of the facts alleged by Edwards in the complaints were true. : Epstein ultimately paid to settle all three of the cases Edwards filed against him for more mpney than he paid to settle any of the other claims against him. At Epstein’s request, the terms In a further effort to harass Edwards, Epstein also filed a bar complaint with the Florida Bar against Edwards. The Florida Bar has dismissed that complaint. See Statement of Undisputed Facts. 10 HOUSE_OVERSIGHT_013379