Epstein Secrets

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

rm, which enhanced the credibility of the purported investment opportunity; (d) Rothstein and other co-conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA, to expand Among the allegations in the Razorback Complaint regarding the Epstein cas

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

Influenced and Corrupt Organization Act; (3) abuse of process; and (4) fraud. Epstein's complaint set forth details of a Pont scheme that Edwards, Rothstein, and others perpetrated through their law firm, Rothstein, Rosenfeldt, and Adler, P.A. ("RRA"). (It 1-36).' The scheme included fraudulent promises

ons of dollars and fund the RRA Ponzi scheme." Edwards ' R. 809: citing deposition testimony of Bradley Edwards dated March 23, 2010; deposition 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. R. 809,

rm, which enhanced the credibility of the purported investment opportunity; (d) Rothstein and other co-conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA, to expand RRA by the hiring of additional attorneys and support staff, to fund sala

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. 9. Upon r

Process and Malicious Prosecution. 4. As more fully described below, at the time that I commenced the Action against Edwards and Scott Rothstein ("Rothstein") in December 2009, I had a good faith basis for filing the same, based on the facts that existed at the time I filed suit, as set forth below and

irm, which enhanced the credibility of the purported investment opportunity; (d) Rothstein and other co-conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA, to expand RRA by the hiring of additional attorneys and support staff, to fund salar

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

ent to his cause of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

res on improper pleadings, discovery and motion practice by Edwards in the cases he was litigating against Epstein while a Partner at RRA and while the Ponzi Scheme was then in critical need of additional investment and about to unravel, as well as a subsequent Federal court order characterizing one of those mo

[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

ews outlets also reported at that time that the Florida Bar had begun actively investigating dozens of attorneys employed by RRA in connection with the Ponzi Scheme. [Cite Epstein Affidavit]; Miami Herald, Scott Rothstein Scandal: Scott Rothstein Partners Probed (January 14, 2010)("The Florida Bar is investigat

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. 9. Upon re

Process and Malicious Prosecution. 4. As more fully described below, at the time that I commenced the Action against Edwards and Scott Rothstein ("Rothstein") in December 2009, I had a good faith basis for filing the same, based on the facts that existed at the time I filed suit, as set forth below and

Razorback Complaint that the Epstein Cases were being deliberately misused for purposes unrelated to the litigation in order to lure investors into the Ponzi Scheme is the fact that on July 24, 2009, Edwards filed a two hundred thirty-four (234) page, one fifty-six (156) count federal complaint against me on be

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. 2 E FTA_R

Process and Malicious Prosecution. 4. As more fully described below, at the time that I commenced the Action against Edwards and Scott Rothstein ("Rothstein") in December 2009, I had a good faith 1 EFTA_R1_00008495 EFTA01733722 basis for filing the same, based on the facts that existed at the time I

rm, which enhanced the credibility of the purported investment opportunity; (d) Rothstein and other co- conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA, to expand RRA by the hiring of additional attorneys and support staff, to fund salar

his case come from the following sources: (1) the Defendants' Answer [D.E. 67] to the Plaintiffs Amended Complaint; (2) the criminal proceedings of Scott W. Rothstein and Debra Villegas;' (3) the affidavits and exhibits of attached to the Motion and Reply; and (4) the affidavit and exhibits attached to the Respon

urt takes judicial notice of the criminal Information [D.E. 1], the Plea Agreement [D.E. 69], and the Judgment [D.E. 290] filed in United States v. Rothstein, 09-60331-JIC (S.D. Fla. 2009), as well as the information [D.E. 1], and plea agreement [D.E. 20-2r filed in United States v. Vilieges, 10.60126-WJZ

tody. [D.E. 106 at '68-69]. At Rothstein's sentencing, Judge James I. Cohn made several findings regarding the role that RRA played in facilitating the Ponzi Scheme. In particular he noted that Millis case is about the selling of fake financial products. The marketing, however, was anything but simple. It was so

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

time that Rothstein had been disbarred and the Florida Bar had begun actively investigating dozens of attorneys employed by RRA in connection with the Ponzi Scheme. [Cite Epstein Affidavit]; Miami Herald, Scott Rothstein Scandal: Scott Rothstein Partners Probed (January 14, 2010)("The Florida Bar is investigati

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

ent to his cause of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

res on improper pleadings, discovery and motion practice by Edwards in the cases he was litigating against Epstein while a Partner at RRA and while the Ponzi Scheme was then in critical need of additional investment and about to unravel, as well as a subsequent Federal court order characterizing one of those mo