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Thursday, September 12, 2013 Page 3 e “Did you ever have any physical contact with E.W.?” e ‘What is the actual value that you contend the claim of E. W. against you has?” The matters addressed in these questions were the central focus of Epstein’s claims against Edwards. Epstein’s refusal to answer these and literally every other substantive question put to him in discovery deprived Edwards of even a basic understanding of the evidence alleged to support claims against him and substantiated Edwards’ position that no such evidence ever existed. Epstein’s case was doomed to fail on the basis of the “sword and shield” doctrine alone. But other grounds were equally and independently fatal to Epstein’s attempt to use the legal system to scare Edwards into submission. All of Edwards’ conduct in the prosecution of valid claims against Epstein was protected by the absolute bar of the litigation privilege. And most fundamentally, Epstein’s claims against Edwards were not only unsupported by but also directly contradicted by all of the record evidence. From the beginning, Edwards diligently represented three victims of sexual assaults perpetrated by Epstein. Each and every one of Edwards’s litigation decisions was grounded in proper litigation judgment about the need to pursue effective discovery against Epstein, particularly in the face of Epstein’s stonewalling tactics. Edwards’s successful representation finally forced Epstein to settle and pay appropriate damages. Effective and proper representation of child victims who have been repeatedly sexually assaulted cannot form the basis of a separate, “satellite” lawsuit, and therefore Edwards was entitled to summary judgment on those grounds as well. Facing these insurmountable obstacles, on the eve of the scheduled hearing on Edwards’ Motion for Summary Judgment, Epstein dismissed all of his claims against Edwards. Put simply, Epstein made allegations that he knew were baseless, that he never intended to try to support, and that were precluded as.a matter of well-established-law. His lawsuit was merely a desperate measure by a Serial pedophile to prevent being held accountable for repeatedly sexually abusing minor females. Epstein’s ulterior motives in filing and prosecuting his lawsuit are blatantly obvious. Epstein's behavior is another clear demonstration that he feels he lives above the law and that because of his wealth he can manipulate the system and pay for lawyers to do his dirty work - even to the extent of having them assert baseless claims against other members of the Florida Bar. Epstein’s Complaint against Edwards was nothing short of a far-fetched, fictional fairy-tale with absolutely no evidence whatsoever to support his preposterous HOUSE_OVERSIGHT_029317