the lack of justification for each of the claims and EPSTEIN never had as EFTA00283051 11/29/2011 15:40 FAX 5816845816 SEARCY DENNEY a1006/013 Ed ards adv. Epstein Cas No.: 502009CA040800XXXICvfBAC Sec nd Amended Counterclaim Ng 6 of 13 his primary purpose to establish what he did consider or reason

ant questions, which a plaintiff in a civil case then refuses to answer. EFTA00294297 02/01/2012 16:14 FAX 5616845816 SEARCY ISBNNBV la008/015 Ed ards adv. Epstein Cas No.: 502009CA040800XXXXMBAG Res nse in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in Su on of