. e “Ts there anything in L.M.’s Complaint that was filed against you in September of 2008 which you contend to be false?” | e “T would like to know whether you ever had any physical contact with the person referred to as Jane Doe in that [federal] complaint?” _ 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 are 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 has deprived Edwards of even a basic understanding of the evidence alleged to support claims against him. Moreover, by not offering any explanation of his allegations, Epstein is deptiving Edwards of any opportunity to conduct third party discovery and opportunity to challenge Epstein’s allegations. _ It is the clear law that “the chief purpose of our discovery rules is to assist the truth- Finding function of our justice system and to avoid trial by surprise or ambush,” Scipio v. State, 928 So.2d 1138 (Fla.2006), and “full and fair discovery is essential to these important goals,” McFadden v. State, 15 So.3d 755, 757 (Fla. 4" Dist. Ct. App. 2009). Accordingly, it is important | for the Court to insure “not only compliance with the technical provisions of the discovery rules, but also adherence to the purpose and spirit of those rules in both the criminal and civil context.” McFadden, 15 S0.3d at 757. Epstein has repeatedly blocked “full and fair discovery,” requiring dismissal of his claim against Edwards. 7 18 HOUSE_OVERSIGHT_013387