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FLORIDA CIVIL DIVISION CASE NO. 502009CA040800X.XXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. SECOND AMENDED COMPLAINT The Plaintiff, Jeffrey Epstein, ("Epstein"), by and through his undersigned attorneys, files
tein"), by and through his undersigned attorneys, files this action against the Defendants, Scott Rothstein, ("Rothstein") and Bradley J. Edwards ("Edwards") (collectively referred to as "Defendants") and alleges: INTRODUCTION This litigation has at its core a law firm that has been described by a Unit
ught in the case files for the Epstein Actions, which numbered as many as nineteen (19) boxes. 16. On or about October 13, 2009, Dean Kretschmar ("Kretschmar"), a representative of one of the investor groups, was encouraged by Rothstein, in a meeting with other partners of RRA, to look at the Epstein cas
nt was not made soon he would lose the client group to other lawyers. d) During this same time frame, specifically on or around October 13, 2009, Kretschmar and Legamaro of the investor group were shown by Rothstein the actual case files of RRA in the Epstein Actions. The Epstein files were brought to th
FLORIDA CIVIL DIVISION CASE NO. 502009CA040800X.XXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. SECOND AMENDED COMPLAINT The Plaintiff, Jeffrey Epstein, ("Epstein"), by and through his undersigned attorneys, files
tein"), by and through his undersigned attorneys, files this action against the Defendants, Scott Rothstein, ("Rothstein") and Bradley J. Edwards ("Edwards") (collectively referred to as "Defendants") and alleges: INTRODUCTION This litigation has at its core a law firm that has been described by a Unit
4215 Epstein v Rothstein, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint 16. On or about October 13, 2009, Dean Kretschmar ("Kretschmar"), a representative of one of the investor groups, was encouraged by Rothstein, in a meeting with other partners of RRA, to look at the Epstein cas
nt was not made soon he would lose the client group to other lawyers. d) During this same time frame, specifically on or around October 13, 2009, Kretschmar and Legamaro of the investor group were shown by Rothstein the actual case files of RRA in the Epstein Actions. The Epstein files were brought to th
ET as Trustee of the IRA SOCHET REVOCABLE INTER VIVOS TRUST, INVESTORS RISK ADVANTAGE, LP, SUSSCO, INC., EDWARD PALEY, FLORENCE PALEY, THE EDWARD AND FLORENCE PALEY FOUNDATION, STEVEN PALEY, LAURA PALEY, JANE ZARETSKY, STEVEN ZARETSKY as Trustee of the JANE ZARETSKY DYNASTY TRUST, LAWRENCE
on Income Fund. 18. Plaintiff, DEAN KRETSCHMAR (hereinafter, "Kretschmar"), is an individual residing in Broward County, Florida. On June 3, 2009, Kretschmar invested $8,000,000.00 into the Ponzi scheme through Banyon Income Fund. Page 10 of 2210 CONRAD & SCHERER, LLP, 633 SOUTH FEDERAL HIGHWAY, FORT LA
the Ponzi scheme through Banyon USVI, LLC. Von Allmen Dynasty Trust, D&L Partners, David Von Allmen Living Trust, Ann Von Allmen Living Trust, and Kretschmar were also major investors in Razorback. 12. Plaintiff, D3 CAPITAL CLUB, LLC (hereinafter, "D3"), is a Delaware limited liability company with its
FLORIDA CIVIL DIVISION CASE NO. 502009CA040800X.XXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. AMENDED COMPLAINT The Plaintiff, Jeffrey Epstein, (hereinafter "Epstein"), by and through his undersigned attorneys, f
through his undersigned attorneys, files this action against the Defendants, Scott Rothstein, individually ("Rothstein"), and Bradley J. Edwards ("Edwards"), individually. The Plaintiff alleges as follows: GENERAL ALLEGATIONS 1. The Plaintiff is an individual who resides in Palm Beach County, Florida
Fisten and Jenne bring into his office the case files for the Epstein Actions which numbered approximately nineteen (19) boxes. Dean Kretschmar, ("Kretschmar"), a representative of one of the investment companies was permitted by Rothstein to review the case files of RRA against Epstein. 16. On another
Entities connected to both Bradley Edwards and Kretschmar

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Prince Andrew
PERSONthe Southern District
LOCATION
Donald Trump
PERSONMartin Weinberg
PERSONFBI
ORGANIZATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONAtterbury Goldberger & Weiss
ORGANIZATION
Prince Charles
PERSONMarc S. Nurik
PERSON
Barry Diller
PERSONJoseph L. Ackerman
PERSONPalm Beach Lakes Blvd
LOCATION