Epstein Secrets

Liability Company, by its manager, Bahia Property IS,agement, LLC, a Delaware Limited Liability Company, by its co-manager, Scott Rothstein; (B12) Scott W. Rothstein's equity interest in QTask; frW.i (313) Scott W. Rothstein's equity interest in Broward Bank erce; (814) Scott W. Rothstein's equity interest in Bov

thereafter through in or about November 2009, \ \\;\ in Broward County, in the Soutite \District of Florida and elsewhere, the defendant, /SCOTT W. ROTHSTEIN, 1,1eZNIK did knowingly conspi federate, and agree with persons known and unknown to the United States Atto mmit offenses against the United Sta

se of Conspiracy to Commit Mail Fraud and Wire Fraud and to 't re Fraud as set forth in Counts 3, 4, and 5 of the Information, the defendant, S . OTHSTEIN, shall forfeit to the United States, all property, real or personal, which eons! tes or is derived from proceeds traceable to the offense. 5. The

an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. * 64. The breadth and scope of RQWEIN, EDWARDS and, potentially, L.M.'s 4 racketeering activity continues t tigated by

A is currently a debtor in bankruptcy. RRA is not named as a Defendant). FACTUAL ALLEGATIONS 9. The United States in United States of America I Scott W. Rothstein, Case No. 09-60331CR-Cohn, United States District Court, Southern District of Florida, has brought an action for Racketeering Conspiracy, 18 U.S.C.

icle or other commodity. THE ROLES AND RESPONSIBILITIES OF THE CONSPIRATORS 7. The roles of the conspirators were as follows: A. Defendant scorr W. ROTHSTEIN was a shareholder, Chairman and CEO of RRA. Through his position at RRA, defendant ROTHSTEIN promoted, managed, and supervised the administration o

hn, United States District Court, Southern District of Florida, has brought an action for Racketeering Conspiracy, 18 U.S.C. § 1962(d) against Scott.W. Rothstein who was the chief executive officer and chairman of RRA. Within the information which was filed, the United States of America has identified the ent

an enterprise); unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, L.M.'s racketeering activity continues to be investigat

ential investor in August of 2009, but became suspicious. He stated "I was convinced it was all a Ponzi scheme and I notified the FBI in detail how Scotty ROTHSTEIN was hiding behind a legitimate law firm to peddle fake investments." Attorney Sakowitz was also quoted as saying ROTHSTEIN had sophisticated eavesd

ey claim a lack of knowledge when: a. The firm had 24 hour security in the form of Broward County Sheriff's officers on each floor of the offices; b. ROTHSTEIN had 24 hour (firm paid) security at his home; c. Partners/attorneys/staff could not directly access ROTHSTEIN without going through extensive secur

an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 72. The breadth and scope of ROTHSTEIN, BODEN, VILLEGAS, BARNETT, FISTEN, JENNE, the Litigation Team and, potentially, L.

ential investor in August of 2009, but became suspicious. He stated "I was convinced it was all a Ponzi scheme and I notified the FBI in detail how Scotty ROTHSTEIN was hiding behind a legitimate law firm to peddle fake investments." Attorney Sakowitz was also quoted as saying ROTHSTEIN had sophisticated eavesd

problems with the firm existed when: a. RRA had 24 hour security in the form of Broward County Sheriffs officers on each floor of the law offices; b. ROTHSTEIN had 24 hour (firm paid) security at his home; c. Partners/attorneys/staff could not directly access ROTHSTEIN without going through extensive secur

an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 72. The breadth and scope of ROTHSTEIN, FISTEN, JENNE, the Litigation Team and, potentially, L.M.'s racketeering activity

PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO

LER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLF.R DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00306384 Epstein v Rothstein, Edwards Case No. 502009CA0408003OOOCMBAG First, Edwards seeks "damages including but not limited to..." various elements of damages. (See Second

tion. Finally, assuming arguendo that the Court were to view the dismissal of Epstein's initial claims for RICO, fraud and conspiracy and §772.101, Fla. Stat., as proving a basis for a malicious prosecution claim by Edwards, Edwards' damages for malicious prosecution must be limited to any damages arising

(RRA is currently a debtor in bankruptcy. RRA is not named as a Defendant). FACTUAL ALLEGATIONS 9. The United States in United States of America'. Scott W. Rothstein, Case No. 09-60331CR-Cohn, United States District Court, Southern District of Florida, has brought an action for Racketeering Conspiracy, 18 U.S.C.

d L.M., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and prof

an enterprise); unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, L.M.'s racketeering activity continues to be investigat

ability Company, by its manager, Bahia Property Management, LLC, a Delaware Limited Liability Company, by its co-manager, Scott W. Rothstein; (312) Scott W. Rothstein's equity interest in QTask; (B13) Scott W. Rothstein's equity interest in Broward Bank of Commerce; (1314) Scott W. Rothstein's equity interest in Bo

d L.M., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and prof

an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, L.M.'s racketeering activity continues to be investigat

ability Company, by its manager, Bahia Property Management, LLC, a Delaware Limited Liability Company, by its co-manager, Scott W. Rothstein; (Bt2) Scott W. Rothstein's equity interest in QTask; (BD) Scott W. Rothstein's equity interest in Broward Bank of Commerce; (BM) Scott W. Rothstein's equity interest in Bova

and E., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and prof

an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, racketeering activity continues to be investigated by t

PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LA

FOWLER WHITE BURNETT • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLF.R DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00582686 Epstein v Rothstein, Edwards Case No. 502009CA040800XXXXMBAG First, under Florida law, Edwards cannot recover compensatory damages for the alleged loss or use of his

uest and deposition (see Second Amended Counterclaim, ¶16) and malicious prosecution based on the filing of priors claim for violation of §772.101, Fla. Stat., Florida RICO, abuse of process, fraud and conspiracy to commit fraud (id., ¶27) -- is inherently defamatory. (To be expanded) Accordingly, Edwards

1CR-Cohn, United States District Court, Southern District of Florida, has brought an action for Racketeering Conspiracy, 18 U.S.C. § 1962(d) against Scott W. Rothstein who was the chief executive officer and chairman of RRA. Within the information which was filed, the United States of America has identified the ent

cordingly, EPSTEIN states: Defendants. COMPLAINT SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and prof

an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, E.'s racketeering activity continues to be investigated