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ed Edwards in a cause of action for abuse of process, arising out of a fraudulent Ponzi scheme perpetrated by attorneys and staff of the law firm of Rothstein, Rosenfeldt, and Adler ("RRA"), where Edwards was a partner who prosecuted actions against Epstein which were marketed by RRA to investors with the
09, I also became aware that the law firm of Conrad Scherer filed a Complaint against Scott Rothstein and others, Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al., Case No. 09-062943(19) (hereinafter referenced as the "Razorback Complaint"), on behalf of some of the Ponzi Scheme investors. Upon revie
neys employed by RRA. At or about the same time in November 2009, I also became aware that the law firm of Conrad Scherer filed a Complaint against Scott Rothstein and others, Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al., Case No. 09-062943(19) (hereinafter referenced as the "Razorback Complain
uestion of law to be determined by the court under the facts and circumstances of each case.'" Id. (citations omitted) (citing City of Pensacola v. Owens, 369 So.2d 328 (Fla.1979)). Grounds for Reconsideration The detailed and documented facts from Epstein's affidavit quoted below, along with the un
[PROVIDE CITATION FROM NYT ARTICLE, WSJ ARTICLE, SUN-SENTICAL ARTICLE AND EPSTEIN AFFIDAVIT]; Amended Complaint in Razorback Funding, LLC, et aL v. Scott W. Rothstein, et aL, Case No. 09- 062943(19); see Deposition Transcript of Bradley Edwards dated March 23, 2010; Deposition Transcripts of Scott W. Rothstein in
and equipment in order to enrich the personal wealth of persons employed by and associated with the RRA Enterprise. See Information Charging Scott W. Rothstein in United States of America v. Scott W. Rothstein, 09-60331-CR-COHN. Scott Rothstein, Edwards's partner at RRA, admitted to and was convicted for th
question of law to be determined by the court under the facts and circumstances of each case.'" Id. (citations omitted) (citing City of Pensacola v. Owens, 369 So.2d 328 (Fla.1979)). UNDISPUTED GROUNDS FOR SUMMARY JUDGMENT The well-documented and undisputed facts in existence at the time Epstein file
L v. Scott W. Rothstein, et at, Case No. 09-062943(19); see Deposition Transcript of Bradley Edwards dated March 23, 2010; Deposition Transcripts 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); Depos
aim; Deposition Transcripts of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and Razorback Funding, LLC, et at v. Scott W. Rothstein, et aL, Case No. 09-062943(19). On December 1, 2009, the Federal Government filed a 36 page Information against Rothstein charging that RRA was a r
be determined by the court under the facts and circumstances 16 EFTA00583967 of each case.'" Id. (citations omitted) (citing City of Pensacola v. Owens, 369 So.2d 328 (Fla.1979)). UNDISPUTED GROUNDS FOR SUMMARY JUDGMENT The reasonable suspicion that gives rise to probable cause for Epstein's suit
al assistants. T EXHIBIT B-30 EFTA00225783 A. Villafaria, Esq. December 9, 2009 Page 3 our part would constitute a breach of the NPA. So the Rothstein lawyers, once again, are using the power of the federal government to perpetrate and further their fraud. And the expense of litigating these cases
letter because other matters have consumed our time and effort. Over the past five weeks, the massive billion-dollar conspiracy created and run by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad Edwards, and others with tortuous an
rnment had to show that Sims benefited financially from Owen's sexual activity and that Sims knew that (a) force or coercion would be used to cause Owens to engage in a criminal sex act or (b) that Owens was under the age of 18." (emphasis added). The Eleventh Circuit's interpretation of the statute
ywood. Me- morial service Saturday. Rodriguez, Eugenio, 64, of West Palm Beach. died June 2. All County Funeral Home and Cre- matory. Like Worth. Rothstein, Violet, 86, of Boca Raton, died Tuesday. Levitt- Weinstein Memorial Chapel, West Palm Beach. Service Friday. Rulz,Mada 1,83, of Boca Raton, die
l County Funeral Home and Crema- tory Lake Worth. Meisel, Edith, 88, of Boca Raton, died Wednesday Beth Israel Memorial Cha- pel, Delray Beach. Owens, John Robert, 65, of West Palm Beach. died Wednesday. Quattlebaum Funeral Home, West Palm Beach. Service Thesday. Pacelli, Americo George, 96.
33401 William Berger, Esq. Attorney For: E. W. Rothstein Rosenfeldt Adler 401 E. Las Olas Blvd., Suite 16
dings below, effectively leaving no adequate remedy on appeal." Martin-Johnson, Inc. v. Savage, 509 So. 2d 1097, 1099 (Fla. 1987) (citing Brooks v. Owens, 97 So. 2d 693 (Fla. 1957); Kilgore v. Bird, 6 So. 2d 541 (Fla. 1942)). The latter requirement is jurisdictional—a "'petitioner must establish tha
Entities connected to both Scott Rothstein and Owens

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSONJane Doe
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSONRobert D. Critton
PERSONSpencer Kuvin
PERSON
Ghislaine Maxwell
PERSONMichael J. Pike
PERSON
Salt Lake City
LOCATION
Prince Andrew
PERSON
United States
LOCATIONGoldberger & Weiss
ORGANIZATIONRobert C. Josefsberg
PERSON