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case are Jeffrey Epstein (via video deposition), Bradley Edwards, Scott Rothstein (via video deposition), and Mr. Edwards' clients (L.M., E.W. and Jane Doe). Source: Florida Standard Jury Instruction (Civil) 201.1 Given Given as Modified Denied Withdrawn 5 EFTA00804794 PLAINTIFF/COUNTER-DEFENDA
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
ge female plaintiff. To augment his concocted story, Rothstein invited D3 to his office to view the thirteen banker's boxes of actual case files in Jane Doe in order to demonstrate that the claims against Epstein were legitimate and that the evidence against Epstein was real. In particular, Rothstein cla
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
that Rush had waived sa applicable reporter's privilege by disclosing brief portions of the Epstein interview to third parties (Balin Aff. Ex. K (Jane Doe's Response in Opposition to Motion of Daily News, to Quash Subpoena), at 6-13) — the same exact waiver argument he makes here. The federal District
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 Jane Doe and Civil Remedies for Criminal Practices Act

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