CIRCUIT COURT 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, Defendant, / DEFENDANT/COUNTER-PLAINTIFF’S RESPONSE IN OPPOSITION TO PLAIN

laint he carries forth the essence of all claims asserted in his original Complaint. In that pleading Epstein essentially alleges that Edwards joined Rothstein in the abusive prosecution of sexual assault cases against Epstein to “pump” the cases to Ponzi scheme investors. The purported “proof” of the allega

Rothstein falsely informed the investors that the potential settlement agreements were available for purchase. Plea Agreement at 2, United States v. Scott W. Rothstein, No. 9-60331-CR-COHN (S.D. Fla. Jan. 27, 2010) attached hereto as Exhibit “SS.” 87. It has been alleged that among other cases that Rothstein used t

dismiss), rev. denied, 81 So. 3d 414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individu

URLINGTON Florida Bar No. 285862 By:/s/ Nichole J. Segal NICHOLE J. SEGAL Florida Bar No. 41232 /kbt 6 EFTA00613506 SERVICE LIST Epstein v. Rothstein/Edwards Case No. 502009CA040800XXXXMB W. Chester Brewer, Jr., Esq. W. CHESTER BREWER, JR., P.A. 250 S. Australian Ave., Ste. 1400 West Palm Beac

EENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, -VS- SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION TO STRIKE

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

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

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

t matter, she was no longer required to answer. One of the lawyers primarily responsible for promoting allegations against Jeffrey Epstein has been Scott Rothstein. In June 2010, Mr Rothstein was sentenced to 50 years imprisonment for his involvement in what is reported to have been the largest ever fraud in Fl

ed to answer. One of the lawyers primarily responsible for promoting allegations against Jeffrey Epstein has been Scott Rothstein. In June 2010, Mr Rothstein was sentenced to 50 years imprisonment for his involvement in what is reported to have been the largest ever fraud in Florida, a US$1.2 billion ponz

shred of credibility. He is a proven liar and someone who has sought to manipulate the law to his own advantage. It is recorded in Court papers that Mr Rothstein made and pursued false claims against Jeffrey Epstein which included promoting allegations of improper conduct of the type you describe. Lexcel 30

F. "Trustee" means Herbert Stettin as bankruptcy trustee for RRA. 3 EFTA00731273 Case 09-34791-RBR Doc 1063 Filed 10/13/10 Page 4 of 8 G. "Rothstein" means Scott W. Rothstein who pled guilty to operating the largest Ponzi scheme in south Florida history. H. "Rothstein Ponzi Scheme" means the Po

y Plaintiff's case. 6. All documents made available to any Investor or potential Investor by Bradley J. Edwards, RRA, Scott W. Rothstein or any of Scott W. Rothstein's entities to solicit "investors" for any case involving Jeffrey Epstein. 7. All document reflecting the names and addresses of all individuals or e

4. All emails exchanged between-any of the following individuals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned: a. Scott Rothstein b. Russell Adler c. Michael Fisten d. Kenneth Jenne e. David Boden f. Deborah Villegas g. Andrew Bamett 6 EFTA00731276 Case 09-34791-RBR D

are disssemiinating stolen information. Mike Fisten was dismissed from the police force and has represented himself as an FBI agent. . ike many of SCott Rotbsteins victims was taken in by their scheme designed to get money. william Scherer has filed a 1200 page complaint against the former BRad Edwards firm of

r the following, have an off the record conversation with the tabloid reporter or alexandra wolfe, explaining that the man bites dog story, is that Scott Rothsteiin is currently serving a 50 year sentence in prison for seining fake epstein sexual cases. His partners Brad Edwards and his investigator Michael Fist

ions relating to the use of Epstein cases in the Rothstein Ponzi scheme. httl): .WWW.scribd com'doe '228252

Razorback Funding, LLC, et at, v. Scott W. Rothstein, et at Complex Litigation Division - Case No.: 09-062943 (19) Third Amended Complaint By ignoring evidence of the Principal Conspirators' miscondu

Plaintiffs have discovered, relative to Levin, Preve, and Banyon, that: a. an $8,000,000.00 wire transfer confirmation used by Levin, Preve, and Rothstein to induce Razorback's $32,000,000.00 payment was never received by RRA or TD Bank. In fact, the fictitious $8,000,000.00 wire is powerful evidence

and has not been returned. Specific examples of Gibraltar Bank's overt acts, assistance and/or omissions in furtherance of the conspiracy include: a. Rothstein learned early in his scheme that he could not convince wealthy investors to give him money unless he established relationships with financial insti

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

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

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.

n sex settlement cases. in part for forging a ju=ges signature, 2 EFTA_R1_01649569 EFTA02515277 As you know, Brad Edwards, current counsel was Rothsteins partner. Despite the fact that Rothstein=20 was convicted of serious criminal offences of fraud relating to his conduct in generating false claims,

stantial period for his part in a Ponzi fraud scheme, which related to encouraging investors to fu=d litigation against Epstein in respect of which Rothstein produced false =laimants. As you know, Brad Edwards, current advisor worked for Rothstein.</=pan> Despite the fact that Rothstein=was convicted of

inister. You have not challenged her to name this person as you shou=d have done, as this is yet another fantasy. It should be apparent to you that Scott Rothstein'S FIRM ORIGINALLY GOT get together=20 to make FALSE AND DEFAMATORY false claims. Had these been properly investigated you would have reported them as

IllOAPX L STANK WACO,' A. ITINLI VT A PAY ANTI MAIL March 11, 2011 Joseph.. Ackerman, Jr., Esquire Fowler White Burnett. P.A. Re: Epstein v. Rothstein, et al Our File No.: 291874 Dear Mr. Ackerman: I TALLAHANNErop Aria Enclosed please find Edwards' Motion for Protective Order, together with a No

ack Scarola, Searcy Denney Scarola Barnhart & Shipley, Attorneys for Bradley L Edwa rds, Marc S. Nurik, Law Offices of Marc S. Nurik, Attorneys for Scott Rothstein, taMM EM Respectfully submitted, oseph Ackerman, Jr. Fla. Bar o. 235954 Christopher E. Knight Fla. Bar No. 607363 FOWLER WHITE BURNETT P.A. c

rnett, P.A. M: S. Nurik, Esquire 3 EFTA00616179 03/11/2011 18:00 FAS SEARCY DENNEY 12 005 #291874/mep Jt —FREY EPSTEIN, Plaintiff(s), vs. SCIOTT ROTHSTEIN, individually, LEY 5. EDWARDS, individually, and ., Defendant(s). N THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH

5. All emails exchanged between-any of the following individuals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned: a. Scott Rothstein b. Russell Adler c. Michael Fisten d. Kenneth Jenne e. David Boden f. Deborah Villegas g. Andrew Barnett h. Bradley Edwards i. A.J. Discala

y Plaintiff's case. 7. All documents made available to any Investor or potential Investor by Bradley J. Edwards, RRA, Scott W. Rothstein or any of Scott W. Rothstein's entities to solicit "investors" for any case involving Jeffrey Epstein. 8. All document reflecting the names and addresses of all individuals or e

3 EFTA00616122 Case 09-34791-RBR Doc 1323 Filed 01/12/11 Page 4 of 8 F. "Trustee" means Herbert Stettin as bankruptcy trustee for RRA. G. "Rothstein" means Scott W. Rothstein who pled guilty to operating the largest Ponzi scheme in south Florida history. H. "Rothstein Ponzi Scheme" means the Po

4. All emails exchanged between-any of the following individuals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned: a. Scott Rothstein b. Russell Adler c. Michael Fisten d. Kenneth Jenne e. David Boden f. Deborah Villegas g. Andrew Barnett 9 EFTA00722468 h. Bradley Edwards

y Plaintiff's case. 6. All documents made available to any Investor or potential Investor by Bradley J. Edwards, RRA, Scott W. Rothstein or any of Scott W. Rothstein's entities to solicit "investors" for any case involving Jeffrey Epstein. 7. All document reflecting the names and addresses of all individuals or e

ler, P.A. E. "Money" means any tangible thing of value. F. "Trustee" means Herbert Stettin as bankruptcy trustee for RRA. 6 EFTA00722465 G. "Rothstein" means Scott W. Rothstein who pled guilty to operating the largest Ponzi scheme in south Florida history. H. "Rothstein Ponzi Scheme" means the Po

T COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY EDWARDS, individually, Defendants/Counter-Plaintiffs. TRANSCRIPT OF PROCEEDINGS VOLUME I DATE TAKEN: Tuesday, October 3r

his deposition testimony, his response to certain discovery requests, the undisputed facts available at the time he filed suit, the indictment of Scott Rothstein, every report in which it's discussed what Mr. Edwards and RRA were doing in these Epstein cases, as well as the filings in the federal court, and

4 25 of the primary element of the malicious prosecution claim, what may have been in the mindset of Mr. Epstein when he filed the claim against Rothstein, Edwards and LM -- initials being used only since she was allegedly a minor at the time that the suit was brought -- is of importance to the Court

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,

dibility of the messengers of the false information. And it was important = for me to also remind the public that Bradley Edwards was a 2 partner of [Scott] Rothstein, a man who is spending fifty a years in jail for fraudulently creating a Ponzi scheme to sell 4 Jeffrey Epstein cases that didn’t exist. Scott Roth

as Mich of his nicknames was TPOF Darkness,” and in private, he the repercussions of engagin Understand that I am capabl imagination could ever conju Rothstein hosted reception McCain, Bobby Jindal, Arno out hundreds of thousands contributions. He gave millio ; the Joe DiMaggio Children’ HOUSE_OVERSIGHT_0

e and let you knoy twenty-fourth, and it is gc brother....Really enjoyed : watch[ing] a little football a me. We love you. Take care. That same day, Rothstei Casablanca, Morocco. For a Tunning. But a few days late Fort Lauderdale. The Ponzi! The moment he did, he s for a lenient sentence. Roths the list i

shred of credibility. He is a proven liar and someone who has sought to manipulate the law to his own advantage. It is recorded in Court papers that Mr Rothstein made and pursued false claims against Jeffrey Epstein which included promoting allegations of improper conduct of the type you describe. Lexcel 30

t matter, she was no longer required to answer. One of the lawyers primarily responsible for promoting allegations against Jeffrey Epstein has been Scott Rothstein. In June 2010, Mr Rothstein was sentenced to 50 years imprisonment for his involvement in what is reported to have been the largest ever fraud in Fl

ed to answer. One of the lawyers primarily responsible for promoting allegations against Jeffrey Epstein has been Scott Rothstein. In June 2010, Mr Rothstein was sentenced to 50 years imprisonment for his involvement in what is reported to have been the largest ever fraud in Florida, a US$1.2 billion ponz

scope. 5. "Epstein" means the Plaintiff. 6. "Holmes" "You" or "Yours" refers to Cara Holmes. 7. "Edwards" means Defendant Bradley J. Edwards. "Rothstein" means Defendant Scott Rothstein. "RRA" or the "Firm" means Rothstein Rosenfeldt Adler, •. 5 EFTA00583205 8. "Person" means any individual natu

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and •., individually, Defendants. Complex Litigation, Fla. R. Civ. Pro.1201 Case No. 50 2009CA

n, past or settled litigation, investigations, surveillance, incidents of misconduct or claims against Epstein from September 2008 to the present: a. Rothstein; b. Edwards; c. Russell Adler; d. William Berger; e. Mike Fisten; f. Ken Jenne; g. Wayne Black; h. Patrick Roberts; i. Patrick Diaz

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, Defendant, SECOND AMENDED COUNTERCLAIM Bradley J. Edwards (EDWARDS) su

ty: )ROTHSTEIN, SCOTT Disposition Amount: Docket Text: NOT USED SM-09-232389 7 SMIS - SUMMONS ISSUED Filing Date: 07-DEC-2009 Filing Party: IROTHSTEIN, SCOTT Disposition Amount: I Docket Text: SCOTT ROTHSTEIN SM-09-232390 RCPT - RECEIPT FOR PAYMENT (Filing Date: 08-DEC-2009 Filing Party: EPS

7-DEC-2009 Filing Party: L M, Disposition Amount: Docket Text: SM-09-232330 4 SMIS - SUMMONS ISSUED Filing Date: 07-DEC-2009 Filing Party: ROTHSTEIN, SCOTT Disposition Amount: Docket Text: SM-09-232331 http://councon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report... 11

ZO, CLERK. 3/28/2023 2:27:00 PM The revelations of the settlements came as part of an ongoingdawsuit:that started as a dispute between Epstein and Rothstein, both billionaires. J A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a minor for prostitution, he sued Rot

dermine Epstein's daimsthat Edwards "ginned up"•the allegations to help his former law partner, imprisoned and disbarred FortLauderdaklawyer Sc:qtt RothstRin, perpetµate a $LQ, billion Ponzi s~heme. CA/Aronberg-0O1064 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM The revela

undermine Epstein’s claims that Edwards “ginned up” the allegations to help; his former law partner, imprisoned and disbarred Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1,2 billion Ponzi scheme. CA/Aronberg-00.1064 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/28/2023 2:27:00 PM NOT A CERTIFIE

THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.:50 2009 CA 040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants, STATEMENT OF UNDISPUTED FACTS Defendant Bradley J. Edwards, Esq., offers the foll

Scott Rothstein appears to have mun a giant Ponzi scheme at his law firm of Rothstein, Rosenfeldt and Adler P.A. (“RRA”). This Ponzi scheme involved Rothstein falsely informing investors that settlement agreements had been reached with putative defendants based upon claims of sexual harassment and/or wititl

Rothstein falsely informed the investors that the potential settlement agreements were available for purchase. Plea Agreement at 2, United States v. Scott W. Rothstein, No. 9-60331-CR-COHN (S.D. Fla. Jan. 27, 2010) attached hereto as Exhibit “SS.” 87. It has been alleged that among other cases that Rothstein used t