estment or Ponzi scheme orchestrated by ROTHSTEIN and as yet other unknown co-conspirators arid as a result of the litigation tactics undertaken by the Litigation Team and ■. as set forth herein, Plaintiff EPSTEIN has incurred and continues to incur the monetary damages including, but not limited to, having to pay an a

vestment or Ponzi scheme orchestrated by ROTHSTEIN and as yet other unknown co-conspirators and as a result of the litigation tactics undertaken by the Litigation Team and ■. as set forth herein, Plaintiff EPSTEIN has incurred and continues to incur the monetary damages including, but not limited to, having to pay an a

vestment or Ponzi scheme orchestrated by ROTHSTEIN and as yet other unknown co-conspirators and as a result of the litigation tactics undertaken by the Litigation Team and ■. as set forth herein, Plaintiff EPSTEIN has Incurred and continues to incur the monetary damages including, but not limited to, having to pay an am