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Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Renewed Motion for Leave to Assert Claim for Punitive Damages It is thus neither necessary nor appropriate for a court to make evidentiary rulings, weigh rebuttal evidence, or engage in credibility determinations in considering the sufficiency of the proffer. “...a proffer should be evaluated by standards akin to those governing a motion to dismiss, where the truth of the plaintiff's allegations are assumed, and not the more rigorous summary judgment standard, where the opposing party must show that there is sufficient admissible evidence in the record to support a reasonable jury finding in his favor.” i. INTRODUCTION ~» “The pleadings and discovery taken to date as confirmed by Epstein’s voluntary dismissal: ~ of all-claims brought -by him against “Bradley-J.-Edwards, show. that thete-i¢’an absence of | competent evidence to demonstrate that Edwards participated in any fraud against Epstein, show the propriety of every aspect of Edwards’ involvement in the prosecution of legitimate claims against Epstein, and further support the conclusion that Epstein sued Edwards out of malice and for the — of intending to intimidate Edwards and Edwards’ ‘clients into abandoning or compromising their legitimate claims against Epstein. Epstein sexually abused three clients of Edwards —L.M., EW. and 1 ane Doe — and Edwards properly and successfully represented them in a civil action against Epstein. Nothing in Edwards’s capable and competent representation of his clients could serve as the basis for a civil lawsuit against him. Allegations about Edwards’s participation in or knowledge of the use of the civil actions against Epstein in a “Ponzi Scheme” were never supported by probable cause or any competent evidence and could never be supported by competent evidence as they are entirely false. HOUSE_OVERSIGHT_013397