Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Renewed Motion for Leave to Assert Claim for Punitive Damages record evidence. From the beginning, Edwards diligently represented three victims of sexual assaults perpetrated by Epstein. As explained in detail below, 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 is entitled to summary --> ... Judgment on‘these grounds-as well: le at ee sree os os «Phe truth-is the record:is entirely devoid-of-any-evidence to support Epstein’s claims-and ~~ ~~ is completely and consistently corroborative of Edwards’s sworn assertion of innocence. Put simply, Epstein made allegations that have no basis in fact. To the contrary, his lawsuit was / ~ soe 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 this 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. Every one of Epstein’s Complaints against Edwards was nothing short of a far-fetched fictional fairy-tale with absolutely no evidence whatsoever to support his preposterous 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 seri