the Counter-defendant, JEFFREY EPSTEIN, and in support thereof would show that the record evidence presented to the pre tha Court in support of Edwards' Motion for Summary Judgment satisfies the statutory uisites for the assertion of a punitive damage claim. Specifically, the evidence establishes EPSTEIN's Complaint against ED

the litigation when they should have been, and among other things, Epstein would have maintained his claim against Edwards, would have prevailed on Edwards' Motion for Summary Judgment and would have been able to settle the case early and favorably based on those e-mails. Conclusion As the Agreed Mediation Confidentiality Order c