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only Edwards but also more than 60 other reputable lawyers at a major law firm. Cf. Sun
Sentinel, Fort Lauderdale, Dec. 11, 2009, 2009 WLNR 25074193 at *1 (“Sure, some outlandish
John Grisham murder plot[s] sound far-fetched. But if you asked me a few months ago if Scott
Rothstein was fabricating federal court orders and forging a judge’s signature on documents to
alidgeitty fleece his friends, as federal prosecutors allege, I would have said that was far-fetched,
too.”). No reasonable lawyer could have expected that a fellow member of the bar would have
beeh involved in such a plot. Nobody seemed to know of Rothstein’s Ponzi scheme, not even his
best friends, or the people he did business with on a daily basis, or even his wife. Many of the
attorneys at RRA had been there for years and knew nothing. Edwards was a lawyer at RRA for
less than 8 months and had very few personal encounters with Rothstein during his time at the
firm, yet Epstein claims that he should have known of Rothstein’s intricate Ponzi scheme. No
doubt for this reason the U.S. Attomey’s Office has now listed Edwards as a “victim” of
Rothstein’s crimes. See Statement of Undisputed Facts filed contemporaneously.
Epstein’s Complaint does not offer any specific reason why a jury would conclude that
Edwards was negligent, and he chose not to offer any explanation of his claim at his deposition.
Accordingly, Edwards is entitled to summary judgment to the extent the claim against him is
somehow dependent upon his negligence in failing to discover Rothstein’s Ponzi scheme.
2. Edwards is Entitled to Summary Judgment to the Extent the Claim Against
Him is Dependent on Allegations Regarding “Pumping the Cases” Because
He Was Properly Pursuing the Interests of His Three Clients Who Had Been
Sexually Abused by Epstein.
Epstein alleges that Edwards somehow improperly enhanced the value of the three civil
cases he had filed against Epstein. Edwards represented three young women — L.M., E.W., and
Jane Doe — by filing civil suits against Epstein for his sexual abuse of them while they were
2)
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