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nt. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as well as Scott Rothstein. Edwards' former law partner. ee infra. Kam incorrectly states that "Imlore recent cases" in this Circuit and District have demoted the showing req
more so in light of Epstein's admission in his lawsuit against M. and others that he that he was "one of M's many `Johns.— See Complaint Epstein v. Rothstein, Edwards & M s, No. 50 2009 CA0 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co.. Dec. 7, 2009) at 146(a), pertinent pages annexed as Ex. E to the C
. Inc., 4 121 F.R.D. 163 (E.D.N.Y. 1988) Ulrich v. Coast Dental Servs.. Inc., 15, 18 739 So. 2d 142 (Fla. Dist. Ct. App. 1999) United States v. Burke, 3, 13 700 F.2d 70 (2d Cir. 1983) United States v. Monteleone 13 257 F.3d 210 (2d Cir. 2001) United States v. Treacv 19 603 F. Supp. 2d 670 (
nt. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as well as Scott Rothstein. Edwards' former law partner. ee infra. 1° Doe incorrectly states that "Imlore recent cases" in this Circuit and District have demoted the showing
ges in his complaint against M. 13 12 The document is available online at http://www.scribd.com/doc/23947743/121009-epstein. "Complaint, Epstein v. Rothstein et al., II 42(h)(i) ("M. testified that she ... worked at various strip clubs; is an admitted prostitute and call girl; has a history of illegal dru
. Inc., 4 121 F.R.D. 163 (E.D.N.Y. 1988) Ulrich v. Coast Dental Servs.. Inc., 15, 18 739 So. 2d 142 (Fla. Dist. Ct. App. 1999) United States v. Burke, 3, 13 700 F.2d 70 (2d Cir. 1983) United States v. Monteleone 13 257 F.3d 210 (2d Cir. 2001) United States v. Treacv 19 603 F. Supp. 2d 670 (
ifferent litigation in which he himself — not Jane Doc — is a party. Specifically, in January 2010 the managing partner of Edwards' former law firm, Scott Rothstein, pled guilty and was sentenced to 50 years in prison for a massive "Ponzi" scheme in which he defrauded investors of $1.2 billion by convincing the
brought a civil lawsuit against Edwards in Florida state court in which he alleges that Edwards was involved in, or knew or should have known about, Rothstein's Ponzi scheme, and pleads claims against Edwards for fraud and violation of Florida's racketeering statute as well as an abuse of process claim al
th v. Moore, 31 III3d 628, 818 2d 603 (2d Dep't 2006) 22 Tannenbaum v. City of New York, 30..3d 357, 819 Eig2d 4 (1st Dep't 2006) 15, 19 US. v Burke, 700 F.2d 70 (2d Cir. 1983) 26 U.S v. Marcos, 1990 WL 74521 ( June I, 1990) 26 U.S. v. Munsingwear, 340 U.S. 36 (1950) 13 Ulrich v. Coast D
Entities connected to both Scott Rothstein and Burke

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Kenneth Marra
PERSON
Prince Andrew
PERSON
Salt Lake City
LOCATION
United States
LOCATION
Ghislaine Maxwell
PERSON
Scarlett Johansson
PERSONLeon Black
PERSON
Bill Clinton
PERSONAtterbury
ORGANIZATION
Sarah Kellen
PERSONJaffe
PERSON
Marc Rich
PERSON