Epstein’s Confidential 2010 Settlement and Related Motions Reveal Potential Undisclosed Payments

Case No.: 502009CA040800XXXXMBAG Edwards' Opposition to Epstein's Motion for Summary Judgment Page 5 of 15 Federal Statute providing for compensation to victims of child abuse.. (Exhibit “A” — Edwards’ Statement of Undisputed Material Facts, paragraphs 41-43). On July 6, 2010 Epstein ultimately paid to settle all three of the cases Edwards had filed against him (Exhibit “A” — Edwards’ Statement of Undisputed Material Facts, paragraphs 84-85). At Epstein’s request, the terms of the settlement were kept confidential. The sum that he paid to settle all these cases in therefore not filed with this pleading and will be provided to the court for in camera review. Epstein chose to make this payment as a result of a Federal Court ordered mediation process which he himself sought. Epstein entered into the settlements in July 2010 more than seven months after he filed his lawsuit against Edwards and before he filed his Second Amended Complaint alleging abuse of process on August 22, 2011. Further, Epstein could not have been the victim of any scheme to pump the cases against him because he never paid to settle the cases until well after Edwards had left RRA and severed all connection with Rothstein in December 2009 (Edwards’ Affidavit attached to Statement of Undisputed Facts as Exhibit “N,” paragraph 20). Moreover, Epstein could not have suffered any damage as a result of the perpetration of the Ponzi scheme by Rothstein because he was not an investor in the scheme. Perhaps the most significant evidence presented in opposition to Epstein’s Motion for Summary Judgment is the telephone interview of [REDACTED] submitted in Support of Edwards’ Motion for Punitive Damages (Exhibit “D”). In addition to the specious claims against Edwards relating to his alleged involvement in a Ponzi scheme, Epstein, in asserting his claims, primarily relied upon the pursuit by Edwards of testimony from his close friends and associates (See Second Amended Complaint, paragraph 32, pp. 11-13). Reliance on these assertions is also threaded through Epstein’s Motion for Summary Judgment in his citation to the public documents referencing the pursuit of such discovery. But as set forth in detail in Edwards’ Motion for Final Summary Judgment (Exhibit “B”) at pages 14-16, that discovery was entirely appropriate and Epstein knew it. Specifically, as reflected in the statement of HOUSE_OVERSIGHT_013308