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Thursday, September 12, 2013 Page 4 claims. It was his last ditch effort to escape the public disclosure by Edwards and his clients of the nature, extent, and sordid details of Epstein’s life as a serial child molester. The bulk of Epstein’s claims against Edwards hinge on the premise that Edwards was involved in a Ponzi scheme run by Scott Rothstein. Broad allegations of wrongdoing on the part of Edwards were scattered willy-nilly throughout the complaint. None of the allegations provided any substance as to how Edwards actually assisted the Ponzi scheme, and allegations that he “knew or should have known” of its existence all failed for one straightforward reason: Edwards was simply not involved in any Ponzi scheme. He provided sworn testimony and an affidavit in support of that assertion, and there was not (and could never be) any contrary evidence. Edwards was deposed at length in this case. As his deposition makes crystal clear, he had no knowledge of any fraudulent activity in which Scott Rothstein may have been involved. See, e.g., Edwards Depo. at 301-02 (Q: “...[Wlere you aware that Scott Rothstein was trying to market Epstein cases... ?” A: “No.”). Edwards supplemented his deposition answers with an extremely detailed Affidavit that declared in no uncertain terms his lack of involvement in any fraud perpetrated by Rothstein. In view of this clear evidence rebutting all allegations against him, Epstein was required to “produce counter-evidence establishing a genuine issue of material fact.” Epstein could not meet this obligation. Indeed, when asked at his deposition whether he had any evidence of Edwards’s involvement, Epstein declined to answer, purportedly on attorney-client privilege grounds: Q. I want to know whether you have any knowledge of evidence that Bradley Edwards personally ever participated in devising a plan through which were sold purported confidential assignments of a structured payout settlement? . . . A. I’d like to answer that question by saying that the newspapers have reported that his firm was engaged in fraudulent structured settlements in order to fleece unsuspecting Florida investors. With respect to my _ personal knowledge,.I’m unfortunately. going to, today,.but I look forward to at some point being able to disclose it, today I’m going to have to assert the attorney/client privilege. Epstein alleged 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 minors. Epstein purported to find a cause of action for this by alleging that Edwards somehow was involved in “‘pumping’ these three cases to HOUSE_OVERSIGHT_029318