Every indexed document

and he invoked his 5th amendment right rather than provide

some went there as much as 100 times or more. Some of the

as counsel for the United States of America and

with attached proposed letter to special master regarding handling numerous

there is overwhelming proof that the number of underage girls

depositions attached to this memorandum will be identified numerically as attachments #1

what Edwards learned in the course of his

Epstein invoked his Fifth Amendment right to

thereby thwarting the defendant's defenses."" Rollins Burdick Hunter of

436 So. 2d 1099 (Fla. 4th DCA 1983)). Put another way

using the fifth amendment as both a 'sword and a shield.'""

a person may not seek affirmative relief in a civil action and then invoke the

Epstein could not seek damages from Edwards while at the same time asserting a

Epstein's multiple invocations of his Fifth Amendment Privilege results in

Epstein cannot rely upon the referenced public documents to support his claims

including the Scherer Complaint against Rothstein is unavailing. As discussed

2012 denying Motion to Dismiss re: Issue of Bonafide Termination attached as

the manner of termination reflects on the merits of the case

it is evident that Epstein took voluntary dismissal of his claims because he knew he did

Epstein effectively conceded that fact by voluntarily dismissing his