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| title: "House Oversight: Estate Documents (Nov 12) (HOUSE_OVERSIGHT_013399)" | |
| source: "House Oversight: Estate Documents (Nov 12)" | |
| sourceUrl: "https://www.justice.gov/epstein" | |
| date: "2026-01-01" | |
| category: "House Oversight" | |
| eftaNumber: "HOUSE_OVERSIGHT_013399" | |
| ocrPages: 1 | |
| ocrChars: 1810 | |
| ocrElapsed: 0.0 | |
| parseTier: "external-legacy" | |
| engine: "engine undisclosed (ep-nov-12.greg.technology mirror)" | |
| externalSource: "greg-ep-nov-12" | |
| externalLicense: "not granted" | |
| externalCredit: "ep-nov-12.greg.technology" | |
| externalUrl: "https://ep-nov-12.greg.technology" | |
| Edwards adv. Epstein | |
| Case No.: 502009CA040800XXXXMBAG | |
| 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 | |
| • -reasons.' | |
| -....... | |
| First, because Epstein elected to hide behind the shield of his right against self. a | |
| 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 fundamentally, 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 | |