Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Renewed Motion for Leave to Assert Claim for Punitive Damages A. Epstein’s Complaint Epstein’s Second Amended Complaint essentially alleged that Epstein was damaged by Edwards, acting in concert with Scott Rothstein (President of the Rothstein Rosenfeldt Adler law firm (“RRA”) where Edwards worked for a short period of time). Epstein appeared to allege that Edwards joined Rothstein in the abusive prosecution of sexual assault cases against Epstein to “pump” the cases to Ponzi scheme investors. As described by Epstein, investor victims were told by Rothstein that three minor girls who were sexually assaulted by Epstein: L.M., E.W., and -« = Jane Doe were to be paid up-front money to ‘prevent those girls from -settling -their-civil cases © <=" - (sense against - Epstein. In Epstein's--view,-these child sexual assault--casts.-hiid “minimal value” Bats Hp (Complaint & 42(h)), and Edwards’s refusal to force his clients to accept modest settlement offers was claimed to breach some duty that Edwards owed to Epstein. Interestingly, Epstein ‘never states that he actually made any settlement offers. rene ewe Bete Te ee et The supposed “proof? of the Complaint’s allegations against Edwards includes Edwards’s alleged contacts with the media, his attempts to obtain discovery from high-profile persons with whom Epstein socialized, and use of “ridiculously inflammatory” language in arguments in court. Remarkably, Epstein has filed such allegations against Edwards despite the fact that Epstein had sexually abused each of Edwards’s clients and others while they were minors. Indeed, in discovery Epstein has asserted his Fifth Amendment privilege rather than answer questions about the extent of the sexual abuse of his many victims. Even more remarkably, since filing his suit against Edwards, Epstein settled the three cases Edwards handled for an amount that Epstein insisted be kept confidential. Without violating the strict