involved. See, e.g., Edwards Depo. at 301-02 (Q: “...[Wlere you aware that Scott Rothstein

involved. See, e.g., Edwards Depo. at 301-02 (Q: “...[Wlere you aware that Scott Rothstein was trying to market Epstein cases... ?” A: “No.”), Edwards has supplemented his deposition answers with an Affidavit that declares in no uncertain terms his lack of involvement in any fraud perpetrated by Rothstein. See, eag., Edwards Affidavit attached to Statement of Undisputed Material Facts as Exhibit “N” at 8-10, 420, 422-23. Indeed, no reasonable juror could find that Edwards was involved in the scheme, as Edwards joined RRA well after Rothstein began his fraud and would have been already deeply in debt. In fact, the evidence of Epstein’s crimes is now clear, and Edwards’s actions in this case were entirely in keeping with his obligation to provide the highest possible quality of legal representation for his clients to obtain the best result possible. In view of this clear evidence rebutting all allegations against him, Epstein must now “produce counter-evidence establishing a genuine issue of material fact.” See Bryant v. Shands Te caching Hospital and Clinics, Inc., 479 So.2d 165, 168 (Fla. Ist Dist. Ct. App. 1985). Epstein cannot do this. Indeed, when asked at his deposition whether he had any evidence of Edwards’s involvement, Epstein declined to answer, purportedly on attorney-client privilege grounds: Q. I want to know whether you have any knowledge of evidence that Bradley Edwards personally ever participated in devising a plan through which were sold purported confidential assignments of a structured payout settlement? .. . A. Id like to answer that question by saying that the newspapers have reported that his firm was engaged in fraudulent structured settlements in order to fleece unsuspecting Florida investors. With respect.to my personal knowledge, I’m unfortunately going to, today,.but I look forward to at some point being able to disclose it, today I’m going to have to assert the attorney/client privilege. See Deposition of Jeffrey Epstein, Mar. 17, 2010 (hereinafter “Epstein Depo.”) at 67-68. Therefore summary judgment should be granted for Edwards on all claims involving any Ponzi scheme by Rothstein. HOUSE_OVERSIGHT_013376