Epstein Secrets

TEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S NOTICE OF P

wsuit." This case has two components. First, Plaintiff Jeffrey Epstein has a claim against Defendant Scott Rothstein for utilizing three cases that Rothstein's firm had against Epstein to fabricate other claims and continue the operation of a Ponzi scheme. Second, about whether Plaintiff Jeffrey Epstein

al damages such as one dollar. Source: Abuse of Process: Valdes v. GAB Robins N. Am. Inc., 924 So. 2d 862 (Fla. 3d DCA 2006); S & I Investments v. Payless Flea Market, Inc., 36 So. 3d 909, 917 (Fla. 4th DCA 2010). Nominal damages are sufficient to recover on an action for abuse of process. See Stole,. v. Levinson, 394

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 at all times when in

the Rothstein Rosenfeldt Adler law firm ("RRA") where Edwards worked for a short period of time). Epstein appears to allege that Edwards joined and Rothstein in fabricating sexual assault cases against Epstein to "pump" the cases to Ponzi scheme investors. As described by Epstein, investor victims were t

ired to prove harm. See, e.g., Bortell v. White Mountains Ins. Group, Ltd., 2 So.3d 1041, 1047 (Fla. 4th Dist. Ct. App. 2009); S & I Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla. 4'h Dist. Ct. App. 2010). Epstein was not harmed by Rothstein's misrepresentations to other people that he knew nothing abo

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

Inc. v. Euroclassics Ltd., 502 So.2d 959 (Fla. Dist. Ct. App. 1983) 21 Russman v. Bd. of Ed., 260 F.3d 114 (2d Cir. 2001) 13 S&I Investments v. Payless Flea Market, Inc., 36 So.3d 909 (Fla. Dig. Ct. App. 2010) 18 Saxton v. Arkansas Gazette Co., 264 Ark. 133 (1978) 29 Smith v. Moore, 31 III3d 628, 818 2d 603 (2

plaintiff suffered damage.” S & I Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla, 4" Dist. Ct. App. 2010)

CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, Vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, / DEFENDANT/COUNTER-PLAINTIFF’S RESPONSE IN OPPOSITION TO PLAIN

laint he carries forth the essence of all claims asserted in his original Complaint. In that pleading Epstein essentially alleges that Edwards joined Rothstein in the abusive prosecution of sexual assault cases against Epstein to “pump” the cases to Ponzi scheme investors. The purported “proof” of the allega

Rothstein falsely informed the investors that the potential settlement agreements were available for purchase. Plea Agreement at 2, United States v. Scott W. Rothstein, No. 9-60331-CR-COHN (S.D. Fla. Jan. 27, 2010) attached hereto as Exhibit “SS.” 87. It has been alleged that among other cases that Rothstein used t