Epstein Secrets

t Railroad Avenue West Palm Beach, FL 33401 Co-Counsel för Defendant: Counter-Plaintiff Bradley J. Edwards 15 EFTA00805456 Bradley J. Edwards Marc S. Nurik Edwards Pottinger LLC Law Offices of Marc S. Nurik 425 N. Andrews Avenue, Suite 2 One E. Broward Boulevard, Suite 700 Ft. Lauderdale. FL 33301-326

where a malicious prosecution for criminal prosecution can be actionable "per se," a plaintiff in a civil action must prove the damages sought. See Adler v. Segal, 108 So. 2d 773, 775 (Fla. 3d DCA 1959)(malicious prosecution action based on acquittal in underlying criminal prosecution; court held that

as 11 EFTA00805452 those applicable in actions for defamation ... ."); compare Burchell v. Bechert, 356 So. 3d 377 (Fla. 4th DCA 1978)(applying Adler's holding but dicta because court already determined damages element met by record evidence of attorneys' fees incurred in defending the lawsuits).

h, FL 33409 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 Martin Weinberg, Esq. Martin G. Weinberg, P.A. 20 P

800XXXXMBAG Second Amended Complaint that same day, Nurik sent an email to Rothstein regarding discussions about Epstein. Also on August 13, 2009, Adler sent an email to Rothstein regarding legal research on the causes of actions against Epstein. On August 14, 2009, Edwards sent an email to RRA attor

signatures and a fundamental corruption of the many legal protections that the legal system has in place. The law firm of Rothstein, Rosenfeldt and Adler, P.A ("RRA") defrauded investors by what Scott Rothstein characterized as legal extortion. He defrauded investors by convincing them into purchasin

h, FL 33409 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 Martin Weinberg, Esq. Martin G. Weinberg, P.A. 20 P

causes of action against Epstein. On that same day, Nurik sent an email to Rothstein regarding discussions about Epstein. Also on August 13, 2009, Adler sent an email to Rothstein regarding legal research on the causes of actions against Epstein. On August 14, 2009, Edwards sent an email to RRA attor

s that the legal system has in place. By claiming to be engaged in what is tantamount to legal extortion, the law firm of Rothstein, Rosenfeldt and Adler, P.A ("RRA") defrauded investors, convincing them into purchasing fake interests in assignments of fictitious structured settlements, including thos

the offices of the undersigned at a mutually convenient time and date. TRIAL WITNESSES I. Scott W. Rothstein do Marc Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 2. Ken Jenne do Broward Co. Sheriff Office 2601 W. Broward Blvd. Ft. Lauderdale, FL 3

, Florida, Case No. 09-062943 (19); Lawsuit filed November 20, 2009. 4. All Depositions taken of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR. 5. The videotaped deposition and all exhibits as referenced/used in the Deposition of Scott W. Rothstein taken by Epstein on Ju

West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for Defendant1Counter-Plainhff Bradley J. Edwards 2 EFTA00804788 Bradley J. Edwards Marc S. Nurik Edwards Pottinger LLC Law Offices of Marc S. Nurik 425 N. Andrews Avenue, Suite 2 One E. Broward Boulevard, Suite 700 Fort Lauderdale. FL 33301-32

dwards filed three claims against Epstein for alleged sexual misconduct. In late March 2009, Edwards joined the law firm of Rothstein Rosenfeldt and Adler ("RRA"). At the time he joined RRA, Edwards held the title of "partner" and he turned over to Scott Rothstein the three clients who had brought cla

ley J. Edwards Link & Rockenbach, 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401 Phon Fax: Attorneys for Jeffrey Epstein Marc S. Nurik, Es uire One E Broward Blvd., Suite 700 10 EFTA00808618 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstei

Complaint, which includes the following allegations: Attorney Scott Rothstein aided by other lawyers . . . at the firm of Rothstein, Rosenfeldt and Adler, 5., for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and professional obligations to

erman, Esq. FOWLER WHITE BURNETT P.A. West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbu Goldber er et al. West Palm Beach, FL 33401 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik Fort Lauderdale, FL 33301 Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman P.L. Fort La

by Scott Rothstein. For example, Epstein alleges generally that "Edwards's... actions constitute a fraud upon Epstein as [Rothstein, Rosenfeldt, and Adler], [Scott] Rothstein and the Litigation Team represented themselves to be acting in good faith and with the best interests of their clients in mind

A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys or e endant, Bradley Edwards Marc Nurik Law Offices of Marc S. Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, FL 33301 Phone: Fax: Counsel for Scott -Rothstein Copies Furnished to: Judicial Assista

ad Edwards while at the law firm of Brad Edwards and associates. 5. In or about April of 2009, Brad Edwards went to work for Rothstein Rosenfeldt Adler (RRA), and his cases, including the case of L.M. v. Jeffrey Epstein, became cases of the RRA law firm. 6. The case of L.M. versus Jeffrey Epstein

33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Blvd., Suite 700, Fort Lauderdale, FL 33301. Joseph L. Ackerman, Jr. W:180713kAfTNCPL76.15th

The critical nature of these documents is vividly demonstrated by Rothstein's testimony during his recent deposition that he had asked Edwards or Adler to specifically set aside a flight manifest for an Epstein private jet. (Tr. Rothstein Depo 12/21/11 at 2278). Rothstein further testified that he

the offices of the undersigned at a mutually convenient time and date. TRIAL WITNESSES 1. Scott W. Rothstein do Marc Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 2. Ken Jenne c/o Broward Co. Sheriff Office 2601 W. Broward Blvd. Ft. Lauderdale, FL

rcuit, in and for Broward County, Florida, Case No. 09-062943 (19). 4. All Depositions taken of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and any and all ancillary cases related thereto, including, but not limited to, Razorback Funding, LLC, et al. v. Scott W. Rothste