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

aint in April 2009, after EDWARDS joined RRA, the allegations against EPSTEIN in <SL7 complaint became even more salacious. In paragraph 12 of .'s Second Amended Complaint, L.M. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . . .the then minor Plaintiff to commit various acts of sexu

OURT 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, Defendants. SUPPLEMENT TO MOTION FOR SEPARATE TRIALS OR. IN THE ALTERNAT

grounds thereof states as follows: Summary Epstein is attempting to try a damages-only claim regarding a clerk's default entered against Defendant Rothstein on January 21, 2010. As the Court will see, however, that clerk's default was entered against the Initial Complaint. Epstein has since amended his c

e four abandoned counts in an inoperative pleading that was no longer part of the record was now a nullity. 6. On August 21, 2011, Epstein filed a Second Amended Complaint against Defendant Rothstein. In his Second Amended Complaint, which supersedes the Amended Complaint, Epstein abandoned his Abuse of Process claim

ATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: 4D18-0762 LT Case No: 502009CA0408003C3C3OCNIB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. REPLY TO RESPONSE TO EMERGENCY PETITION FOR WRIT OF MANDAMUS On Rev

n his Response that "the only reason the case was allegedly not at issue was Epstein's failure, over more than six years, to seek a default against Rothstein[.]" (Resp. at p. 1) [emphasis added]. However, at the March 8, 2018, hearing, Judge Hafele held Edwards equally responsible for the current Rule 1.

e like this one, "a case where the case had never been at issue." Serban, 148 So. 3d at 1291(quoting Labor Ready). Furthermore, Epstein's operative Second Amended Complaint, which had neither been answered nor defaulted, contained a "brand-new" count alleged in response to the trial court's order dismissing the prior a

tions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of pertinent pages of the Complaint in Epstein v. Rothstein, Edwards No. 50 2009 CAO 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co., Dec. 7, 2009), as downloaded from http://www.scribd.com/doc/23947743/121

NTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, ilr DLEY J. EDWARDS, individually, and ., individually, Defendants. 50 2009 cAo 03 (JUI0X04B COMPLAINT COPY RECEIVED FOR FILING

int in April 20O9, after EDWARDS joined RRA, the allegations against EPSTEIN in ■.'s complaint became even more salacious. In paragraph 12 of ■.'s Second Amended Complaint, ■. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . .the then minor Plaintiff to commit various acts of sexual

tions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of pertinent pages of the Complaint in Epstein v. Rothstein, Edwards & L.M. No. 50 2009 CAO 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co., Dec. 7, 2009), as downloaded from http://www.scribd.com/doc/2394774

NTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, ilr DLEY J. EDWARDS, individually, and ., individually, Defendants. 50 2009 cAo 03 (JUI0X04B COMPLAINT COPY RECEIVED FOR FILING

int in April 20O9, after EDWARDS joined RRA, the allegations against EPSTEIN in ■.'s complaint became even more salacious. In paragraph 12 of ■.'s Second Amended Complaint, alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . .the then minor Plaintiff to commit various acts of sexual mi

TEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800X)CaMB JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. COPY RECEIVED FOR FILING DEC 13 2011 SHARON CLERK CIRCUIT CIVIL DIVISION wiR.

producing any and all other contracts for legal services in the defense of criminal charges or other civil claims against EFTA00286378 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Mr. Epstein not related to the claims in the Second Amended Complaint as being irrelevant, overb

lving your misconduct with minor females. Answer: If there is a contract for legal services relating to the damages claimed by Mr. Epstein in his Second Amended Complaint, it will be produced. Plaintiff objects to producing any and all other contracts for legal services in the defense of criminal charges or other civi

"abuse of process" are based on the allegation that EDWARDS' discovery tactics, including the filing of RICO counts, were allegedly done to further Scott Rothstein's Ponzi scheme. To highlight the level of bad-faith to which EPSTEIN stoops to make this allegation that EDWARDS' filing of the RICO count was someho

ighlight the level of bad-faith to which EPSTEIN stoops to make this allegation that EDWARDS' filing of the RICO count was somehow in furtherance of Rothstein's schemes and not done for proper purposes, each of the original three complaints that included a RICO EFTA00294300 02/01/2012 10:15 FAX 56168458

and prosecute against El) ARDS and the pending, closely related counterclaims. FACTUAL BACKGROUND Plaintiff/Counterdefendant, EPSTEIN has filed a Second Amended Complaint against ED ARDS. The complaint challenges EDWARDS' professionalism as an attorney rep enting girls who had been sexually abused. In particular,

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

int In April 2009, after EDWARDS Joined RRA, the allegations against EPSTEIN in ■.'s complaint became even more salacious. In paragraph 12 of ■.'s Second Amended Complaint, II. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . . .the then minor Plaintiff to commit various acts of sexu