Edwards adv. Epstein Case No.: 502009CA040800KXXXMBAG Second Renewed Motion for Leave to Assert Claim for Punitive Damages confidentiality terms required by Epstein, the cases did not settle for the “minimal value” that Epstein suggested in his Complaint. Because Epstein relies upon the alleged discrepancy . between the “minimal value” Epstein ascribed to the claims and the substantial value Edwards sought to recover for his clients, the settlement amounts Epstein voluntarily agreed to pay while these claims against Edwards were pending will be disclosed to the court in-camera. B. Summary of the Argument The claims against Bradley J. Edwards, Esq., were frivolous for at least three separate Po AP@ASOTS 8 he ee ne Bae ene co ty net ee iin eg, 0 nal Heos - -S First, because’“Epstein’ elected tohide ‘behind the shield of his right against self-=-'--.:> -- incrimination to preclude his disclosing any relevant information about the criminal activity at the center of his claims, he was barred from prosecuting his case against Edwards. Under the well-established “sword and shield” doctrine, Epstein could not legitimately. seek damages from : Edwards while at the same time asserting a Fifth Amendment privilege to block relevant discovery. His case was therefore subject to summary judgment and on the eve of the hearing seeking that summary judgment Epstein effectively conceded that fact by voluntarily dismissing his claims. Second, all of Edwards’ conduct in the prosecution of valid claims against Epstein was protected by the litigation privilege, a second absolute legal bar to Epstein’s claims effectively conceded by his voluntary dismissal. | Third, and most famdamentally, Epstein’s lawsuit was not only unsupported by both the applicable law, it was based on unsupported factual allegations directly contradicted by all of the 6 HOUSE_OVERSIGHT_013399