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, I believed at the time of filing my original Complaint that these two individuals, and other unknown partners of theirs at Rothstein, Rosenfeldt, Adler ("RRA"), engaged in serious misconduct involving a widely publicized illegal Ponzi scheme operated through their law firm (the "Ponzi Scheme") tha
Razorback Funding, LLC, et al. v. Scott W Rothstein, et al., Case No. 09-062943(19); deposition of Scott W Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and Razorback Funding, LLC, et al. v. Scott W Rothstein, et al., Case No. 09-062943(19); letter dated July 22, 2009 from Edwards,
three defendants -7- EFTA00612489 including: Edwards, and his then partner Scott Rothstein. The four counts alleged: (1) violations of Florida's Civil Remedies for Criminal Practices Act; (2) violations of Florida's Racketeering Influenced and Corrupt Organization Act; (3) abuse of process; and (4) fraud. Epstein's complaint set for
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
and engaging in improper litigation tactics in order to promote and sustain that Ponzi scheme. Epstein brought claims for violations of Florida 's Civil Remedies for Criminal Practices Act, violations of Florida's Racketeer Influenced and Corrupt Organization (RICO), abuse of process, fraud and conspiracy to commit fraud. Rothstein di
overy motion. The facts underlying that action are briefly as follows: Scott Rothstein was the managing partner and CEO of Rothstein, Rosenfeldt and Adler ('RRA"), a 70-lawyer firm in Fort Lauderdale, Florida. Balin Aft Ex. A, Ex. 1 ("Rothstein Information") ¶¶ 1-2; id., Ex. 2 (Amended Complaint for D
in's complaint alleges claims against Rothstein and Edwards for fraud, violation of Florida's civil racketeering statute and violation of Florida's Civil Remedies for Criminal Practices Act. Ponzi Scheme Complaint ¶¶ 26, 54-68, 73-78.4 The complaint also pleads an abuse of process claim alleging that after the thrce sex abuse suits were
Entities connected to both Adler and Civil Remedies for Criminal Practices Act

Jeffrey Epstein
PERSONScott Rothstein
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Rosenfeldt
PERSONJack Goldberger
PERSONJane Doe
PERSONJack Scarola
PERSONthe Southern District
LOCATIONFlorida Bar
ORGANIZATIONGoldberger & Weiss
ORGANIZATIONE.W.
PERSONBurlington & Rockenbach
ORGANIZATIONValdes
PERSONPayless Flea Market, Inc.
ORGANIZATIONMancusi
PERSON