at provided the basis for Epstein's probable cause to file and continue his suit against Edwards. In his malicious prosecution counterclaim against Epstein, Edwards specifically must disprove that Epstein had any such probable cause. Thus, Epstein's "claim" against Rothstein and Edwards' "counterclaim" against

ogatories dated 9/5/17 is attached as Exhibit B. 16. While all known facts paint the picture that Edwards profited immensely from litigation with Epstein, Edwards claims to have been damaged by this litigation. As noted above, Edwards is claiming damages of: (a) injury to his reputation; (b) mental anguish, em