EFTA00286283

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. 'ist1)00004B v. Plaintiff, 50 2009CAO it 0B SCOTT ROTHSTEIN, individually, DLEY J. EDWARDS, individually, and IV , individually, COPY RECEIVED FOR FILING Defendants. Bic A 12099 stinnoN fl,DOCK COMPLAINT WM4 OQMPTFIC2660 Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and individually. Accordingly, EPSTEIN states: 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 professional obligations to the administration of justice, deliberately engaged in a pattern of racketeering that involved a staggering series of gravely serious obstructions of justice, actionable frauds, and the orchestration and conducting of egregious civil litigation abuses that resulted in profoundly serious Injury to Jeffrey Epstein one of several targets of their misconduct EFTA00286283 Epstein v. RRA, et al. Page 2 tein and his co- and others. Rothstein and RRA's fraud had no boundary; Roths ns. Amongst the violations of law conspirators forged Federal court orders and opinio non-existent Epstein settlements that are the subject of this lawsuit are the marketing of were unrelated to any principled and the sanctioning of a series of depositions that eous private information about litigation purpose but instead designed to discover extran well-known public figures) in Epstein or his personal and business associates (including nds for payment from Epstein. order to defraud investors and support extortionate dema and the pursuit of a civil litigation The misconduct featured the filing of legal motions clients' cases and, instead, strategy that was unrelated to the merits or value of their misrepresentations and deceit had as its improper purpose the furthering of Rothstein's to abusive investigatory tactics, to third party Investors. As a result, Epstein was subject . This lawsuit is filed and will unprincipled media attacks, and unsupportable legal filings . The Rothstein racketeering be vigorously pursued against all these defendants state and federal justice enterprise endeavored to compromise the core values of both and honest lawyers and their systems in South Florida and to vindicate the hardworking that is the subject of this clients who were adversely affected by the misconduct Complaint. co-conspirators as the Plaintiff reserves the right to add additional defendants — facts and evidence is developed. GENERAL ALLEGATONS exclu sive costs, interest, 1. This is an action for damages in excess of $15,000.00, and attorneys' fees. EFTA00286284 Epstein v. RRA, et at Page 3 2. Plaintiff, EPSTEIN, is an adult and currently is residing and works in Palm Beach County, Florida. 3. Defendant, SCOTT ROTHSTEIN ("ROTHSTEIN"), is an individual residing in Broward County, Florida, and was licensed to practice law in the State of Florida. In November 2009, ROTHSTEIN voluntarily relinquished his law license in the midst of the implosion of Rothstein, Rosenfeldt and Adler, P.A. ("RRA"). He was disbarred by the Florida Supreme Court on November 20, 2009. On December 1, 2009, ROTHSTEIN was arrested and arraigned in Federal Court In Broward County, Florida. 4. At all times relevant hereto, ROTHSTEIN was the managing partner and CEO of RRA. 5. Defendant, ROTHSTEIN and Stuart Rosenfeldt, are and were the principal owners of equity in RRA and each co-founded RRA. 6. Defendant, BRADLEY J. EDWARDS ("EDWARDS"), is an individual residing in Broward County, Florida and Is licensed to practice law in the State of Florida. At all times relevant hereto, EDWARDS was an employee, agent, associate, partner, shareholder, and/or other representative of RRA. 7. Defendant, IS (.."), is an individual residing in Palm Beach County, Florida. At all times relevant hereto, was represented by RRA, ROTHSTEIN and EDWARDS in a civil lawsuit against Epstein and was an essential participant in the scheme referenced infra by, among other things, substantially changing prior sworn testimony, so as to assist the Defendants in promoting their fraudulent scheme for the EFTA00286285 Epstein v. RRA, et al. Page 4 Civil Actions (defined below) promise of a multi-million dollar recovery relative to the her alleged damages. involving Epstein, which was completely out of proportion to Corporation , with a principal 8. Non-party, RRA is a Florida Professional Service e, FL 33401. In addition address of 401 East Las Olas Blvd., Suite 1650, Fort Lauderdal Florida, New York, and to its principal office, RRA also maintained seven offices in RRA also maintains Venezuela, and employed over 70 attorneys and 200 support staff. a 33009-8515. RRA, through an office at 1109 NE 2d Street, Hallandale Beach, Florid n, conducted business its attorneys, including those named as Defendants herei ess and filed lawsuits on throughout Florida, and relevant to this action, conducted busin behalf of clients in Palm Beach County, Florida. (RRA is currently a debtor in bankruptcy. RRA is not named as a Defendant). FACTUAL ALLEGATIONS W. Rothstein, Case No. 9. The United States in United States of America v. Scott District of Florida, has 09-60331CR-Cohn, United States District Court, Southern § 1962(d) against Scott W. brought an action for Racketeering Conspiracy, 18 U.S.C. RRA. Within the Rothstein who was the chief executive officer and chairman of has identified the enterprise information which was filed, the United States of America conjunction with "his co- as being the law firm, RRA, through which Rothstein in pattern of racketeering conspirators" (not yet identified by the USA) engaged in the time in 2005 up through through its base of operation at the offices of RRA from some al activities, Including and continuing into November of 2009. Through various crimin ica asserts that mail fraud, wire fraud and money laundering, the United States of Amer EFTA00286286 Epstein v. RRA, et al. Page 5 ximately $1.2 billion from Rothstein and his co-conspirators unlawfully obtained appro The USA further alleges that investors by fraud in connection with a Ponzi scheme. ct alleged in the instant "Rothstein and co-conspirators initiated the criminal condu supplemen t the income and Information in order to personally enrich themselves and to ce of Rothstein and his co- sustain the daily operation of RRA." In essence, in the absen tion of RRA, which included conspirators conducting the Ponzi scheme, the daily opera accounts payable Including payroll (compensation to lawyers, staff, investigators, etc.), tigation on cases, including unlimited improper, harassing and potential illegal inves been sustainable. A copy Epstein-related matters, would in all likelihood would not have of the information is attached as Exhibit 1 to this action. as legitimately and properly 10. As more fully set forth herein, RRA held itself out and others in RRA were using engaging in the practice of law. In reality, ROTHSTEIN bilk investors out of hundreds RRA to market Investments, as described below, so as to devised an elaborate plan of millions of dollars. ROTHSTEIN and others in RRA ts of a structured pay-out through which were sold purported confidential assignmen for clients, in exchange for settlements, supposedly reached on behalf of RRA amount. Investors were immediate payments to these clients of a discounted lump sum t which was to be paid out being promised in excess of a 30% return on their Investmen upon to Induce investor to the investors over time. While some of the cases relied , structured pay-out funding were existing filed cases, It is believed that the confidential settlements were all fabricated. EFTA00286287 Epstein v. RRA, et al. Page 6 of Investigation (FBI) press 11. Based on media reports, Federal Bureau Ponzi scheme and pattern of conferences and releases and the Information the massive 2005 and continued through criminal activity meant to lure investors began sometime in of the investors and the FBI. the fall of 2009, when the scheme was uncovered by some ue to be filed against various As of November of 2009, civil lawsuits were and contin al scheme. Defendants as result of their massive fraudulent and crimin evidenced by the filing of 12. This fraudulent and illegal investment scheme is also Transfer of Corporate Powers Amended Complaint For Dissolution And For Emergency Appointment of A Custodian or to Stuart A. Rosenfeldt, Or, In The Alternative, For the N, individually. (Case No. 09 Receiver by ROSENFELDT, and RRA, against ROTHSTEI ial Circuit, Broward County, 059301, In the Circuit Court of the Seventeenth Judic lution action, and attached Florida, Complex Business Div.), (hereinafter "RRA disso hereto as Exhibit 2). sole purpose that it 13. Plaintiff references the RRA dissolution action for the conducting an illegal and acknowledges that RRA and ROTHSTEIN were in fact of financial retums from improper investment or Ponzi scheme based on promises ing the actions brought settlements or outcomes of supposed legal actions, Includ against Plaintiff EPSTEIN. The RRA dissolution action alleges in part that — (RRA), has, according to "ROTHSTEIN, the managing partner and CEO of the firm antial misappropriation of assertions of certain investors, allegedly orchestrated a subst firm's name (RRA). The funds from investor trust accounts that made use of the law N centered around the sale of investment business created and operated by ROTHSTEI EFTA00286288 Epstein v. RRA, et al. Page 7 Statement of RRA dissolution interests in structured settlements? See Preliminary action, Exhibit 2 hereto. was used in communications 14. In furtherance of the scheme, RRA's letterhead ured settlements. RBA's trust regarding investment opportunities in purported struct dollars or wire transfer of monies account was used to deposit hundreds of millions of guaranteed payments. from duped investors and other victims. RRA personally e false and fraudulent Court 15. Rothstein's scheme went so far as to manufactur District Judge, Kenneth A. opinions/orders including forging the signatures of U.S. Circuit in other cases. It is not Marra and U.S. Circuit Court Judge, Susan H. Black, 11th ln related matters. See Composite yet known if he forged similar documents in Espte Exhibit 3 hereto. revealed on a daily basis through 16. The details of this fraudulent scheme are being recent estimate of the financial various media reports and court documents. The most scope of the scheme is that it exceeds $1.2 billion dollars. d as a defendant in three civil 17. Relevant to this action, EPSTEIN is currently name that were handled by RRA and its actions alleging, inter alia, sexual assault and battery of which is filed in federal attorneys including EDWARDS prior to its implosion — one U.S.D.C. S.D. Fla.)(Jane Doe is a court (Jane Doe v. Epstein, Case No. 08-CIV-80893, filed in state court in the 151° named Defendant herein), and two of which have been a, al . v. Epstein, Case No. Judicial Circuit Court, Palm Beach County, State of Florid No. 502008CA028058XXXXMB 502008CA028051XXXXM6 AB; E.W. v. Epstein, Case EFTA00286289 Epstein v. RRA, et al. Page 8 Actions," and ■ is a named AB), (hereinafter collectively referred to as the "Civil st and September of 2008. Defendant herein). The Civil Actions were all filed in Augu tment or Ponzi scheme was 18. What is clear is that a fraudulent and improper inves of the named Defendants, which in fact conducted and operated by RRA and certain dant in the Civil Actions. scheme directly impacted EPSTEIN as a named defen quoted in a November 2009 19. Miami attorney and developer, Alan Sakowitz, was a potential investor in August of article as saying that he had met with ROTHSTEIN as nced it was all a Ponzi scheme 2009, but became suspicious. He stated "I was convi was hiding behind a legitimate and I notified the FBI in detail how Scotty ROTHSTEIN witz was also quoted as saying law firm to peddle fake investments? Attorney Sako and former law enforcement ROTHSTEIN had sophisticated eavesdropping equipment ge looking for damaging officers who would sift through a potential defendants' garba dants could be in essence evidence to use with investors to show how potential defen the value of any legitimate blackmailed into paying settlement that far exceeded damage claim. le Rothstein related 20. Ft. Lauderdale attomey William Scherer represents multip used the "Epstein Ploy ... investors. He Indicated in an article that RRA/Rothstein had y. He would use. . .cases as a showpiece as bait. That's the way he raised all the mone cases he allegedly structured as bait for luring investors into fictional cases. All the In fact, on November 20, were fictional. I don't believe there was a real one in there." page Complaint against 2009, William Scherer, on behalf of certain clients, filed a 147 TD Bank, N.A., Frank ROTHSTEIN, David Boden, Debra Villegas, Andrew Barnett, EFTA00286290 Epsteh v. RRA, et al. Page 9 and Frank Preve asser ting various Spinosa, IMMI Kerstetter, Rosanne Caretsky scheme behind the RRA facade; and allegations that further prove the massive Ponzi ded Complaint naming additional as of November 25, 2009, a 249 page Amen Defendants was filed. STEIN, David Boden, Debbie 21. In addition, and upon information and belief, ROTH Jenne (all employees of RRA) Vilieges, Andrew Barnett, Michael Fisten and Kenneth ar meetings during which false through brokers or middlemen would stage regul /clients that existed or RRA had statements were made about the number of cases show and share actual case files against EPSTEIN and the value thereof. They would Thus, the attorneys and clients from the EPSTEIN actions with hedge fund managers. privileges that otherwise may have have waived any attorney-client or work- product existed. some of the actual Civil Action 22. Because potential investors were given access to of a name of an existing Plaintiff files, Investor-third parties may have became aware opposed disclosure of her legal who had filed anonymously against Epstein and had name. EDWARDS claiming the need 23. In all other instances, by RRA, ROTHSTEIN and s, they were able to effectively for anonymity with regard to existing or fabricated client was a key element in the use initials, Jane Doe or other anonymous designations which the inves tors believe fraudulent scheme. Fictitious names could be created to make many other cases existed against Epstein. EFTA00286291 Epstein v. RRA, et al. Page 10 were represented by RRA and 24. In each of RRA's Civil Actions, the Plaintiffs are or its attorneys, Including ROTHSTEIN and EDWARDS. Civil Actions another fifty 25. In addition, investors were told that in addition to the with the potential for hundreds (50) plus anonymous females were represented by RRA, its attorneys would sue Epstein of millions of dollars in settlements, and that RRA and ct his high-profile friends. unless he paid exorbitant-settlement amounts to prote 26. Upon information and belief, EDWARDS knew or should have known that ive Ponzi scheme and/or were ROTHSTEIN was utilizing RRA as a front for the mass s (and other claims) involving selling an alleged interest or investment in the Civil Action Epstein. attorneys of RRA) knew 27. Further evidencing that EDWARDS (and possibly other uation of the massive Ponzi or should have known and participated in the contin mber 24, 2009, reported on scheme, a front-page Palm Beach Post article, dated Nove prosecutors against "dozens of the recent filing of an amended forfeiture complaint by urants and other assets — ROTHSTEIN's real estate properties, foreign cars, resta along with millions more including $12 million in the lawyer's bank account in Morocco, furthe r reported that — donated to political campaigns and charitable funds.' The article massive Attorney Scott ROTHSTEIN tapped into millions of dollars from his Lauderdale investment scam to cover payroll costs at his expanding Fort ay. law firm, federal authorities said In court records released Mond n in one ROTHSTEIN's law firm (RRA) generated revenue of $8 millio $18 million, recent year, yet his 70-lawyer law firm had a payroll of EFTA00286292 Epstein v. RRA, et at. Page 11 used investors' prosecutors said. ROTHSTEIN, who owned half of RRA said. money from his Ponzi scheme to make up the shortfall, they STEIN received Subsequent articles and court filings have reflected ROTH million in 2009, while compensation in excess of $35.7 million in 2008 and $10.5 . his partner Rosenfeldt received greater than $6 million in 2008 Capital Club, LLC, ("D3"), 28. ROTHSTEIN attempted to lure the entity known as D3 00,000.00 court settlement by offering D3 "the opportunity" to invest in a pre-suit $30,0 existed and was entirely against EPSTEIN; yet this supposed settlement never N, upon information and belief, fabricated. To augment his concocted story, ROTHSTEI of case files in Jane Doe invited D3 to his office to view thirteen (13) banker's boxes claims against EPSTEIN (one of the Civil Actions) in an attempt to substantiate that the by RRA, ROTHSTEIN, and were legitimate and that the evidence obtained against him EDWARDS (the "Litigation Team") was real. d other investors like 29. Upon information and belief, ROTHSTEIN and others offere involving EPSTEIN. the entity D3 fabricated investment opportunities in the Civil Actions le police record and RRA Fisten (a former Dade County police officer with a questionab Sheriff and felon) assisted investigator) and Jenne (a former attorney, Broward County , privileged and work- ROTHSTEIN in making these offers by providing confidential product information to prospective third-party investors. Its investigation at RRA It appears that 13 out of the 40 boxes seized by the FBI as part of ed by counsel for the consisted of files relating to the Civil Actions involving EPST EIN, as report discovery, Epstein will Bankruptcy Trustee. Until those boxes can be reviewed, as well as other not know the depth of the fraud and those Involved. EFTA00286293 Epstein v. RRA, et al. Page 12 fabricating settlements 30. By using the Civil Actions against EPSTEIN as "bait" and able to lure investors into regarding same, ROTHSTEIN and others were turn, was used to fund ROTHSTEIN'S lair and bilked them of millions of dollars which, in uing the massive Ponzi the litigation against EPSTEIN for the sole purpose of contin scheme. Team, Individually and in 31. As part of this scheme, ROTHSTEIN and the Litigation a concerted effort, may have unethically and Illegally: of an interest in non- a. Sold, allowed to be sold and/or assisted with the sale able and non- settled personal injury lawsuits (which are non-assign (including those transferable) or sold non-existent structured settlements cases involving Epstein); rs; b. Reached agreements to share attorneys fees with non-lawye c. Used investor money to pay plaintiffs (I.e., E.W. and Jane Doe) "up Civil Actions; front" money such that plaintiffs would refuse to settle the ns in violation of d. Conducted searches, wiretaps or intercepted conversatio state or federal laws and Bar rules; and unreasonable and e. Utilized the judicial process including, but not limited to, ring the Ponzi unnecessary discovery, for the sole purpose of furthe scheme. including the Litigation 32. Any such actions by ROTHSTEIN, and other attorneys, of various Florida Bar Rules, Team, directly or indirectly, would potentially be a violation EFTA00286294 Epstein v. RRA, et al. Page 13 and various conflicts of issues including prohibiting the improper sharing of fees or costs rules. d have known of the improper 33. Evidencing that the Litigation Team knew or shoul continuation of the scheme, purpose that ROTHSTEIN was pursuing in the cases to pursue issues and ROTHSTEIN used RRA's Litigation Team in the EPSTEIN pled in the Civil Actions, but evidence unrelated to and unnecessary to the claims i scheme orchestrated by significantly beneficial to lure investors into the Ponz ROTHSTEIN and other co-conspirators. s claimed their investigators 34. Upon information and belief, ROTHSTEIN and other rd Epstein's private jet where discovered that there were high-profile individuals onboa bly others) copies of a flight log sexual assaults took place and showed D3 (and possi international figures. purportedly containing names of celebrities, dignitaries, and knowingly pursued flight data 35. For instance, the Litigation Team relentlessly and with these famous individuals and passenger manifests regarding flights EPSTEIN took and no Illicit activities took knowing full well that no underage women were onboard tely attempted to take the place. ROTHSTEIN and the Litigation Team also inappropria r the marketing scam that depositions of these celebrities In a calculated effort to bolste was taking place. of EPSTEIN'S pilots, and 36. One of Plaintiffs' counsel, EDWARDS, deposed three g in Iraq). The pilots were sought the deposition of a fourth pilot (currently servin ARDS never asked one deposed by EDWARDS for over twelve (12) hours, and EDW (RRA clients) as it related to question relating to or about E.W., Ill., and Jane Doe EFTA00286295 Epstein v. RRA, et al. Page 14 EIN'S planes. But EDWARDS transportation on flights of RRA clients on any of EPST ions about the pilots' thoughts asked many inflammatory and leading irrelevant quest only have been asked and beliefs (which will never be admissible at trial) which could the depositions to sell the for the purposes of "pumping" the cases and thus by using cases (or a part of them) to third parties. Epstein wanted to make 37. Because of these facts, ROTHSTEIN claimed that and therefore he had offered certain none of these Individuals would be deposed various potential plaintiffs in $200,000,000.00 to settle the claims of RRA female clients dollar settlement by EPST EIN actions against EPSTEIN. The offer of a $200 million . was completely fabricated; no such offer had ever been made intended to take the 38. EDWARDS' office also notified Defendant that he depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); itutional attorney (ii) Alan Dershowitz (noted Harvard Law professor, const . and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). es of EPSTEIN with 39. The above-named individuals were friends and acquaintanc the years. None of the whom he knew through business or philanthropic work over any of the Litigation above-named individuals had any connection whatsoever with Team's clients, E.W.,II. or Jane Doe. EFTA00286296 Epstein v. RRA, et al. Page 15 ries in the state court matters, 40. EDWARDS filed amended answers to interrogato that would allege dly be called E.W. and■., and listed additional high profile witnesses at trial, including, but not limited to: Richardson (Governor of New Mexico, formerly U.S. (i) Bill and Representative and Ambassador to the United Nations); charitable, (ii) Any and all persons having knowledge of EPSTEIN'S political or other donations;2 itions or listing high profile 41. The sole purpose of the scheduling of these depos again , to -pump" the cases to friends/acquaintances as potential witnesses was, these individuals had or have any investors. There is no evidence to date that any of knowledge regarding RRA's Civil Actions. scheme against EPSTEIN, 42. In furtherance of their illegal and fraudulent have known) and, at times, ■. ROTHSTEIN, EDWARDS (who either know or should in her Civil Action against EPSTEIN: al action in a) Included claims for damages in Jane Does feder ng the excess of $50,000,000.00 rather than simply allegi Jurisdictional limits. legitimate b) Organized a Jane Doe TV media interview without any tial legal purpose other than to "pump* the federal case for poten 2 These high-profile celebrity "purported' witnesses have no personal knowledge regarding the facts on these "Three Cases', but were being contacted, subpoenaed or listed to harass and intimidate them and e. Epstein, and to add 'star" appeal to the marketing effort of the Ponzi schem EFTA00286297 Epstein v. RRA, et al. Page 16 trial in Palm investors or to prejudice Epstein's right to a fair Beach County. d partner In c) EDWARDS, Berger and Russell Adler (another name RRA) all attended EPSTEIN's deposition. At that time, had no outrageous questions were asked of EPSTEIN which could be bearing on the case, but so that the video and questions shown to investors. letely irrelevant d) Conducted and attempted to conduct comp r of the Civil discovery unrelated to the claims in or subject matte witnesses Actions for the purpose of harassing and embarrassing of thousands and EPSTEIN and causing EPSTEIN to spend tens ding of dollars in unnecessary attorneys' fees and costs defen but was what appeared to be discovery related to the Civil Actions entirely related to the furtherance of the Ponzi scheme. spring of e) After EDWARDS was recruited and joined RRA in the st 2009, the tone and tenor of rhetoric directed to cases again ed EPSTEIN used by Attorney EDWARDS and Berger chang ns from dramatically in addressing the court on various motio y being substantive on the facts pled to ridiculously inflammator and sound-bite rich such as the July 31, 2009, transcript when EDWARDS stated to the Court in "What the evidence is really going to show is that Mr. Epstein — at least dating back as EFTA00286298 Epstein v. RRA, et al. Page 17 back to far as our investigation and resources have permitted, attempt to 1997 or '98 — has every single day of his life, made an we're not sexually abuse children. We're not talking about five, talking talking about 20, we're not talking about 100, we're not to law about 400, which, I believe, Is the number known . . and it enforcement, we are talking about thousands of children. ed is through a very intricate and complicated system that he devis him that where he has as many as 20 people working underneath these he is paying well to schedule these appointments, to locate girls." unsupportable and legally f) As an example, EDWARDS filed an fer of deficient Motion for Injunction Restraining Fraudulent Trans rty of Assets, Appointment of a Receiver to Take Charge of Prope tial Epstein, and to Post a $15 million Bond to Secure Poten 3- Judgment, In Jane Doe v. Epstein Case No. 08-CV-8089 Marra/Johnson. The motion was reported in the press as was the ing). ultimate goal (i.e., to "pump" the cases for investor follow d of However, the Court found "Plaintiffs motion entirely devoi evidence ... ", and denied the motion in toto. he 9) ROTHSTEIN told investors he had another 52 females that e, represented, and that Epstein had offered $200 million to resolv EFTA00286299 Epstein v. RRA, et at. Page 18 million, but that he could settle, confidently, these cases for $500 separate and apart from his legal fees. have known h) ROTHSTEIN and the Litigation Team knew or should al value that their three (3) filed cases were weak and had minim for the following reasons: (I) - testified she never had any type of sex with Epstein; worked at numerous strip clubs; is an admitted prostitute and call girl; has a history of Illegal drug use (pot, painkillers, Xanax, Ecstasy); and continually asserted the 5th Amendment during her depositions in order to avoid answering relevant but problem questions for her; (ii) E.W. — testified she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and In which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescription painkillers and drugs to customers and prostituting themselves. (iii) Jane Doe (federal case) seeks $50 million from Epstein. She and her attorneys claim severe EFTA00286300 Epstein v. RRA, et el. Page 19 emotional distress as a result of her having voluntarily gone to Epstein's home. She testified that there was never oral, and or sexual intercourse; nor did she ever touch his genitalia. Yet, Jane Doe suffered extreme emotional distress well prior to meeting Epstein as a result of having witnessed her father murder his girlfriend's son. She was required to give sworn testimony In that matter and has admitted that she has lied in sworn testimony. Jane Doe worked at two different strip clubs, including Platinum Showgirls in Boynton Beach. ridiculous and irrelevant discovery such as i) Conducted ard subpoenaing records from an alleged sex therapist, Dr. Leon Bard in Massachusetts, when the alleged police report reflected d that EPSTEIN had only seen a chiropractor In Palm Beach name alleged Dr. Bard. No records relating to EPSTEIN existed for this was sex therapist, Dr. Bard, and the alleged subpoena for records appeal; just another mechanism to "pump" the cases for investor 9 Allowed a Second Amended Complaint to be filed on behalf of ■. alleging that EPSTEIN forced the minor into "oral sex," yet ■. testified that she never engaged in oral, anal, or vaginal EFTA00286301 Epstein v. RRA, et el. Page 20 ed his intercourse with EPSTEIN and she had never touch genitalia. article, that k) Told investors, as reported in an Associated Press EPSTEIN'S celebrities and other famous people had flown on h none plane when assaults took place. Therefore, even thoug s, the (zero) of RRA's clients claim they flew of EPSTEIN'S plane Again, to Litigation Team sought pilot and plane logs. Why? ut any prime the investment "pump" with new money witho relevance to the existing claims made by the RRA clients. r Circuit I) After EDWARDS joined RRA, EDWARDS and forme Non- Judge William Berger filed and argued motion to make the Prosecution Agreement (NPA) between Epstein and USAO s, public. But, RRA, EDWARDS and Berger, and their three client they already had a copy of the NPA. They knew what it said and t knew the civil provisions in the agreement had no impac whatsoever on the three pending Civil Actions. was The concept behind certain civil provisions in the NPA Epstein, to allow an alleged victim to resolve a civil claim with with maintain her complete privacy and anonymity and move on her life. As an assistant United States Attorney stated at a hearing in federal court, the NPA was not designed "to hand them a jackpot or a key to a bank." EFTA00286302 Epstein v. RRA, et al. Page 21 e to magnify his financial gain 43. ROTHSTEIN, with the intent and improper motiv t and/or Ponzi scheme, had so continue to fund the fraudulent and illegal investmen in the Civil Actions. EDWARDS demand excessive money from EPSTEIN n had no legitimate purpose in 44. The actions described in paragraph 42 above herei r were meant to further the pursuing the Civil Actions against EPSTEIN, but rathe so that he and others could fraudulent scheme and criminal activity of ROTHSTEIN existi ng and non-existent claims fraudulently overvalue the settlement value of the against EPSTEIN to potential investors. i) scheme, RRA and its 45. As a result of the fraudulent investment or (Ponz have compromised their clients' attorneys in the Civil Actions against EPSTEIN may have been unable to give interests. ROTHSTEIN and the Litigation Team would had been promised a financial unbiased legal counsel because outside investor(s) a plaintiff received payments from interest in the outcome of the actions. Additionally, if clearly could impact the plaintiff's investment monies while her action is pending, this or shade their testimony (i.e. decision of whether or not to settle the current litigation t and to further promote the commit perjury) to gain the greatest return on the investmen Ponzi Scheme. state civil 46. The truthfulness of ■.'s allegations and testimony in ■.'s to seek a multi-million dollar action have been severely compromised by the need us settlements of tens of payout to help maintain RRA's massive fraud. Because fictitio d to "investors". in this millions of dollars in cases relating to EPSTEIN were represente to create a fiction that Ponzi scheme, RRA and the attorneys in the Civil Actions needed EFTA00286303 Epstein v. RRA, et al. Page 22 actual facts behind her action would included extraordinary damages. However, the extraordinary measures were never support such extraordinary damages. Therefore, s against EPSTEIN. undertaken to create an entirely inflated value of her claim in, she admitted to having a. Though she held herself out as a "victim" of Epste nt claim of abuse. She returned over and over again to him despite her curre cort since the age of 15. has now admitted, under oath, to being a call girl/es 'DT" 280:16-19). She (in her deposition September 24, 2009 Transcript DT 156:7) and "I am a testified "Well, I lived life as a prostitute," (see . M. admitted her prostitute when I make money" (see DT 156:12-13) a day from prostitution activity with men other than Epstein to making $1,000 (DT 157:11-158:21). on maybe more than 20 occasions in one year alone collected from It admitted under oath to keeping a list of amounts she of "Psalms" that she "Johns" in "two or three" lined books including a book circumstances, her obtained from a religious store (DT 152:1-14). Under the "Johns" during that claim for damages against EPSTEIN, one of M.'s many likely to produce the same period, would be so incredible and certainly not extraordinary settlements promised to "RRA's investors.' , and RRAII. 47. In April 2007, before she was represented by EDWARDS FBI. She was represented gave sworn taped recorded testimony to the agents of the of EPSTEIN in a very by a lawyer other than EDWARDS at that statement. She spoke central allegations on which positive and friendly terms and directly contradicted the Il.'s civil action against Epstein is now based. However, once in the hands of EFTA00286304 Epstein v. RRA, et al. Page 23 d to EDWARDS and RRA, is story changed dramatically. All of a sudden she wante millions of dollars. sue EPSTEIN and like other RRA clients, sought tens of III was insistent that a. For example, in her sworn statement to the FBI, conclusion of she "Jeffrey is an awesome man.' (p. 21 — FBI); At the because he's an stated: "I hope Jeffrey, nothing happens to Jeffrey that he has to awesome man and it really would be a shame. It's a shame didn't do nothing go through this because he's an awesome guy and he In fact, ■ spoke so highly of wrong, nothing." (pp. 57-58 - FBI). Attorney's office EPSTEIN and her interactions with him that the US ey could not Informed a federal court in July 2008 that the US Attorn consider a victim. began her Yet, by September 24, 2009, the date on which III. RRA and deposition in her civil action and now represented by EDWARDS, new and very different tale about purported sexual had been misconduct under the supposed Influence of EPSTEIN scam was thoroughly rehearsed and her role into the ROTHSTEIN complete. In her deposition in her civil action, declared that: "I, I don't really care about money." (DT 206:8) for "He needs time in jail. He doesn't want to be — this is not right him to be on the streets living daily . . ." (DT 219:21-23) EFTA00286305 Epstein v. RRA, et al. Page 24 life because of "You don't think my whole life I have lived that shitty Jeffrey Epstein?" (DT 222:7-8) , i. was b. In her sworn FBI testimony (pre-EDWARDS and RRA) no inappropriate emphatic that her Interactions with Epstein involved ite: sexual touching in any way. In fact, it was exactly the oppos kind of Q: Did he at any point kiss you, touch you, show any affection towards you? A: Never, never. (p. 21 — FBI) . . . Q: So he never pulled you closer to him in a sexual way? Jeffrey is an A: I wish. No, no, never, ever, ever, no, never. awesome man, no. (p. 21 - FBI) Yet, filed her second amended complaint In April 2009, EIN in after EDWARDS Joined RRA, the allegations against EPST 12 of ■.'s complaint became even more salacious. In paragraph ■.'s Second Amended Complaint, II. alleges among other things, that: minor "Jeffrey Epstein coerced, induced, or enticed . . .the then e acts Plaintiff to commit various acts of sexual misconduct. Thes and included, but were not limited to, fondling and inappropriate illegal sexual touching of the then minor Plaintiff, forcing or inducing the then minor plaintiff into oral sex or other sexual misconduct..." EFTA00286306 Epstein v. RRA, et al. Page 25 c. In her sworn FBI statement (pre-EDWARDS and RRA), in testified that the individual who first brought II. to EPSTEIN's home, told II "make sure you're 18 because Jeffrey doesn't want any underage girls." (p. 8 - FBI). d by Yet at her September, 2009 depositbn now represente EDWARDS and RRA, told a very different story: Q: My question was what did tell you to tell Mr. Epstein about your age? A: She said it didn't matter. O: That's your recollection about what she said? r. Don't A: Yes, she said — I remember her saying it doesn't matte worry about it. (DT 199:20-25) d. Pre-EDWARDS and RRA, II, testified to the FBI : "I always made sure — I had a fake ID, anyways saying that I was 18." (p. 8 - FBI). depo, she Yet, when questioned about her fake ID at her September 2009 stated: O: And did you have a fake ID? A: No. Q: Have you ever had a fake ID? EFTA00286307 Epstein v. RRA, et al. Page 26 A: No. (DT 300:5-8) testified e. In her FBI statement (pre-EDWARDS and RRA), she about others ■. brought to the Epstein home.... testified that women and content with their brought to EPSTEIN's home were eager for the opportunity experiences: They'd A: None of my girls ever had a problem and they'd call me. they beg me, you know, for us to go to Jeffrey's house because , and love Jeffrey. Jeffrey is a respectful man. He really is. I mean sad about he all thought we were of age always. This is what's so it. (p 30 - FBI). ••• after they left O: Did any of the girls complain about what happened there? Jeffrey. A: No. You asked me that question. No, everybody loved (p. 44 - FBI) • • • fine with A: Every girl that I brought to Jeffrey, they said they were s in the it. and like for example [E.W. — another of RRA's client the Civil Actions], a lot of girls begged me to bring them back for money. And as far as I know, we all had fun there. (p. 45 - FBI) EFTA00286308 Epstein v. RRA, et al. Page 27 did a "180" at her Yet, with EDWARDS and RRA as her attorneys, ■. September, 2009 deposition in saying: of their mind. A: . . . Once they were there, they were scared out said III They did it anyways and some of them walked out and that ever don't ever do this to me again. That was the worst thing happened to me. (DT 170:6-11) 171:13) . . . A: And then, a lot of girls weren't comfortable. (DT .. made f. The above represent only a few of the dramatic changes. ARDS/RRA and after she in her testimony prior to her representation by EDW hired ROTHSTEIN, EDWARDS and RRA. i) scheme, may knowingly 48. As a result of the fraudulent investment or (Ponz n, or committed a fraud on the have compromised her alleged interests in her Civil Actio court. set of facts involving 49. RRA and the Litigation Team took an emotionally driven a Palm Beach Billionaire and alleged innocent, unsuspecting, underage females and resolving the cases based sought to turn it into a gold mine. Rather than evaluating and able, voluntary and consensual on the merits (i.e. facts) which included knowledge in psychological and actions by each of the claimants and substantial pre-Epste sexual experiences pre- emotional conditions of each of the claimants and substantial ctive orders and objections Epstein, RRA and the Litigation Team sought through prote Instead forged ahead with to block relevant discovery regarding their claimants. They in into settling the cases. discovery the main purpose of which was to pressure Epste EFTA00286309 Epstein v. RRA, et al. Page 28 As Magistrate Judge Linnea Fortunately, their tactics have not been successful. 15, 2009 (DE 299 in Federal Case Johnson wrote in a discovery order dated September Order: #08-80119) in denying Plaintiffs' Motion for Protective that the childhood of "This is his [Epstein's] right. The Record in this case is clear and neglect, which in many of the Plaintiffs was marred by instances of abuse damages claimed by the turn may have resulted, in whole or in part, in the Plaintiffs.° 28, 2009 (DE 377 in Federal In addition, in an Omnibus Order dated October : Case #08-80119) Magistrate Judge Linnea Johnson wrote Plaintiff's damage claims, "Here the request at issue goes to the very heart of the tiff's sexual history, but requesting not only general information relating to Plain ed compensation or inquiring as to specific instances wherein Plaintiff receiv lly assaulted, battered, or consideration for sex acts, claim other males sexua or lascivious acts on her. abuses her, and/or claim other males committed lewd their sexual history As a global matter, Plaintiffs clearly and unequivocally place case has negatively in issue by their allegations that Epstein's actions in this in men," "sexual affected their relationships by, among other things, "distrust :" problems in personal intimacy problems," "diminished trust," "social problems teenage pregnancy," relationships," " feeling of stress around men," "premature y." Considering these "antisocial behaviors," and "hyper-sexuality and promiscuit in is entitled to know allegation, there simply can be no question that Epste al activity" or "lewd whether Plaintiffs were molested or the subject of other "sexu EFTA00286310 Epstein v. RRA, et al. Page 29 er there is an alternative and lascivious conduct" in order to determine wheth have sustained, whether basis for the psychological disorders Plaintiffs claim to acts and how certain acts Plaintiffs engaged in prostitution or other similar type relatio nships with others or alleged in the Complaint materially affected Plaintiffs' nships and/or whether how those acts did not have such an affect on those relatio ological disorders as a Plaintiffs suffered from the alleged emotional and psych the Complaint. To deny result of other sexual acts prior to the acts alleged in g him from mounting a Epstein thus discovery, would be tantamount to barrin defense." a fraud upon EPSTEIN 50. ROTHSTEIN, EDWARDS and ■.'s actions constitute d themselves to be acting in as RRA, ROTHSTEIN and the Litigation Team represente at all times when in reality, good faith and with the bests interests of their clients In mind l scheme described herein. they were acting in furtherance of the investment or Ponz sentations of RRA, and EPSTEIN justifiably relied to his detriment on the repre Defendants, ROTHSTEIN, EDWARDS and as to how he conducted and defended the Civil Actions brought against him. illegal investment or Ponzi 51. As a direct and proximate result of the fraudulent and wn co-conspirators and as scheme orchestrated by ROTHSTEIN and as yet other unkno Team and M. as set forth a result of the litigation tactics undertaken by the Litigation monetary damages herein, Plaintiff EPSTEIN has incurred and continues to incur the the Civil Actions' true including, but not limited to, having to pay an amount in excess of any payment by value as a result of them refusing to settle In that a percentage of EFTA00286311 Epstein v. RRA, et al. Page 30 tors; incurring significant EPSTEIN may have been promised to third party inves al to conduct settlement additional legal fees and costs as result of Defendants refus se any monies paid by negotiations in a forthright and good faith manner becau and incurred significant EPSTEIN is in reality a promised return on an investment; not relevant, material attorneys' fees and costs In defending the discovery that was but which was done for the and/or calculated to lead to the admissibility of evidence, sole purpose of "pumping* the cases to investors. fraudulent and criminal 52. EPSTEIN has also been Injured in that the scope of the EPSTEIN has been or racketeering activity so permeated the RRA law firm that brought against him. In prevented from fully and fairly defending the civil actions uation of the massive essence, the very existence of RRA was based on the contin nspirators. In order to Ponzi scheme orchestrated by ROTHSTEIN and other co-co other co-conspirators used continue to bring in monies from investors, ROTHSTEIN and ed lawsuits, as a means the Civil Actions against EPSTEIN, along with other manufactur of obtaining massive amounts of money. 53. ROTHSTEIN, EDWARDS and are liable for damages caused to EPSTEIN — individually, and jointly and severally. Count I — Violation of 64772.101, et seq., Fla. Stat. - Florida Civil Remedies for Criminal Practices Act — Against All Defendants as if fully set forth 54. Plaintiff realleges and incorporates paragraphs 1 through 53 herein. EFTA00286312 Epstein v. RRA, et al. Page 31 collectively constitute an 55. RRA, ROTHSTEIN, EDWARDS and M. each and enterprise pursuant to §772.102(3), Fla. Stat. (2009). 56. ROTHSTEIN, EDWARDS and ■. engaged In a pattern of criminal activity as defined in §772.102(3) and (4), Fla. Stat. (2009). itted multiple predicate 57. As alleged herein, ROTHSTEIN and EDWARDS comm including violations of Florida acts in violation of §772.103(1), (2), (3) and (4), Fla. Stat., ; Chap ter 817, relating to Statutes - Chapter 517, relating to securities transactions h includesill.); Chapter fraudulent practices, false pretenses, and fraud generally (whic h includes E.); and Chapter 831, relating to forgery; §836.05, relating to extortion (whic 837, relating to perjury (which includes ■.). Substantially more than two predicate fabricated settlements outlined acts (I.e., the selling of or participation of the sale of as the improper litigation herein, including the Civil Actions involving Epstein as well d. tactics outlined above) occurred within a five-year time perio N, EDWARDS and ■.'s 58. As a direct and proximate result of ROTHSTEI violations of §772.103, Fla. Stat., EPSTEIN has been injured. is entitled to threefold of 59. Pursuant to §772.104(1), Fla. Stat., Plaintiff EPSTEIN and court costs, and such his actual damages sustained, reasonable attorney's fees other damages as allowed by law. entry of a judgment for WHEREFORE, Plaintiff EPSTEIN respectfully demands the damages against all the named Defendants. Count II — Florida RICO "Racketeer Influenced and Corrupt Organization Act" Pursuant to 4(895.01. et seq., Fla. Stat. (2009), Against All Defendants EFTA00286313 Epstein v. RRA, et al. Page 32 60. Plaintiff realleges and incorporates paragraphs 1 through 53 as if fully set forth herein. 61. RRA, along with ROTHSTEIN, EDWARDS and a, each and collectively, constitute an enterprise pursuant to §895.02(3), Fla. Stat. (2009). 62. During all times relevant hereto, ROTHSTEIN, EDWARDS and III. were and are associated with the enterprise, RRA, and each other. 63. Defendants, ROTHSTEIN, EDWARDS and as persons associated with the enterprise, RRA and each other (as an enterprise), unlawfully conducted or participated, directly or indirectly, in such an enterprise through a pattern of racketeering, § 895.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, E.'s racketeering activity continues to be investigated by the FBI, as numerous civil lawsuits against some of the Defendants and others continue to be filed by persons who have been damaged. As of the filing of this Complaint, criminal charges have only been brought against ROTHSTEIN. 65. Substantially more than two predicate acts (i.e., the selling of fabricated settlements outlined herein, including the Civil Actions involving Epstein as well as the improper litigation tactics outlined above) occurred within a five year time period. 66. Pursuant to §895.02, Fla. Stat., ROTHSTEIN and EDWARDS engaged in a pattern of "racketeering activity through the commission of crimes as defined in § 895.02(1)(a)-(b), Fla. Stat., including Chapter 517, relating to securities; Chapter 817, relating to fraudulent practices, false pretenses, and fraud (including MI) generally; EFTA00286314 Epstein v. RRA, et al. Page 33 Chapter 813, relating to forgery; §836.05, relating to extortion (including.); Chapter 837, relating to perjury (including.). 67. Pursuant to §895.05, Fla. Stat., Plaintiff seeks the following relief against Defendants, ROTHSTEIN, EDWARDS and...: a) Ordering ROTHSTEIN and EDWARDS to divest themselves of any interest in the enterprise, RRA; b) Enjoin all Defendants from engaging in the same type of conduct and activities as described herein; and c) Temporarily enjoining ROTHSTEIN, EDWARDS and.., from the continuation of the Civil Actions brought against EPSTEIN until criminal charges have been formally brought against RRA and/or any of the Defendants, such that EPSTEIN may be allowed to evaluate whether a stay or dismissal of all Civil Actions against him is merited. 68. EPSTEIN further seeks an award of his reasonable attorney's fees and costs, and such other relief that this Court deems appropriate. WHEREFORE, Plaintiff EPSTEIN respectfully demands the entry of a judgment for the relief sought and damages against the named Defendants. Count III — Abuse of Process — Against All Defendants 69. Plaintiff realleges and incorporates paragraphs 1 through 53 as if fully set forth herein. EFTA00286315 Epstein v. RRA, et al. Page 34 70. After instituting the Civil Actions against EPSTEIN, the actions of Defendants, ROTHSTEIN, EDWARDS and ■. as alleged in paragraphs 9 through 53 herein, constitute an illegal, improper or perverted use of process. 71. ROTHSTEIN, EDWARDS and ■. possessed ulterior motives or purposes in exercising such illegal, improper, or perverted use of process. 72. As a result of ROTHSTEIN, EDWARDS and■ actions, EPSTEIN suffered damages. WHEREFORE, Plaintiff EPSTEIN respectfully demands the entry of a judgment for damages against all the named Defendants. Count IV — Fraud Against All Defendants 73. Plaintiff realleges and incorporates paragraphs 1 through 53 as if fully set forth herein. 74. ROTHSTEIN, by and through Defendant EDWARDS and ■. made false statements of fact to EPSTEIN and his attorneys and agents, known to be false at the time made, and/or intentionally concealed material information from EPSTEIN and his attorneys and agents, for the purpose of inducing EPSTEIN to act In reliance thereon. 75. EPSTEIN did so act on the misrepresentation and/or concealment by incurring additional attorney's fees, costs, and expenses in aggressively defending the civil actions whereas in reality, because the Civil Actions against Plaintiff were being exploited and over-valued so as to lure additional investors and to attempt to extort as much money as possible from EPSTEIN so as to continue the massive fraud. EFTA00286316 Epstein v. RRA, et al. Page 35 WHEREFORE Plaintiff EPSTEIN demands judgment against Defendants for damages Incurred and for any other relief to which he is entitled under the law. Conspiracy to Commit Fraud Against All Defendants 76. Plaintiff realleges and incorporates paragraphs 1 through 53, and 74 and 75 as if fully set forth herein. 77. ROTHSTEIN, EDWARDS and conspired to commit a fraud upon EPSTEIN. 78. ROTHSTEIN, EDWARDS and II combined by and through concerted action as detailed herein to accomplish an unlawful purpose or accomplish some purpose by unlawful means. The unlawful purpose was, among other things, the orchestrating and continuation of the massive fraudulent Ponzi scheme and receipt of monies for the continuation of the scheme. The unlawful means includes, but is not limited to, the use of the Civil Actions against EPSTEIN In an unlawful, improper, and fraudulent manner. 79. As a direct and proximate result of ROTHSTEIN, EDWARDS and ■.'s conspiracy to defraud EPSTEIN, EPSTEIN suffered damages. WHEREFORE Plaintiff EPSTEIN demands judgment against Defendants for damages incurred and for any other relief to which he is entitled under the law. Jury Trial Plaintiff demands Jury Trial on all issues so triable. By: ROBERT 17. CRITTON, JR., ESQ. Florida r No. 224162 EFTA00286317 Epstein v. RRA, at al. Page 36 rcritabcIclaw.corn MICHAEL J. PIKE, ESQ. MOM BURMAN, CRITTON, LUTTIER & COLEMAN 303 Banyan Blvd., Suite 400 SNest Palm Beach, FL 33401 Attomeys for Plaintiff) EFTA00286318