EFTA00607531

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. Plaintiff, 50 2009 cm) h 0,39 ME V. SCOTT ROTHSTEIN,findIvIdually, • BRADLEY J. EDWARDS, Individually, and COPY • LM., Individually, RECEIVED FOR FILING Defendants. DEC II 200g COMPI .INT Plaintiff, JEFFREY EPSTEIN, (hereinafter 'EPSTEIN", by and through his undersigned attorneys, files this action against Defendants. SCOTT ROTHSTEIN, Individually, BRADLEY J. EDWARDS, Individually, and ,.M., Individually. Accordingly, EPSTEIN states: SUMMARY OFACTION 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 EFTA00607531 Epstein v. RRA, et al. Page 2 Rothstein and his co- and others. Rothstein and RFtA's fraud had no boundary, ns. Amongst the violations of law conspirators forged Federal court orders and opinio of non-existent Epstein settlements that are the subject of this lawsuit are the marketing were unrelated to any principled and the sanctioning of a series of depositions that er extraneous private information about litigation purpose but instead designed to discov (including well-known public figures) In .Epstein or his personal and business associates dema nds for payment from Epstein. tirderto defraud investors and support extortionate ns and the pursuit of a civil litigation The misconduct featured the filing of legal motio of their clients' cases and, instead, strategy that was unrelated to the merits or value tein's misrepresentations and deceit had as Its improper purpose the furthering of Roths t to abusive Investigatory tactics, to third party investors. As a result, Epstein was subjec filings. This lawsuit is filed and will unprincipled media attacks, and unsupportable legal defendants. The Rothstein racketeering be vigorously pursued against all these values of both state and federal justice enterprise endeavored to compromise the core orking and honest lawyers and their systems in South Florida and to vindicate the hardw nduct that is the subject of this clients who were adversely affected by the misco Complaint. — co-conspirators as the Plaintiff reserves the right to add additional defendants facts and evidence is developed. GENERAL ALLEGATONS 00.00, exclusive costs, interest, 1. This is an action for damages In excess of $15,0 and attorneys' fees. EFTA00607532 Epstein v. RRA, et al. Page 3 residing and works in Palm Beach 2. Plaintiff, EPSTEIN, is an adult and currently Is County, Florida. is an individual residing in 3. Defendant, SCOTT ROTHSTEIN rROTHSTEIN"), law in the State of Florida. In Broward County; Florida, and was licensed to practice his law license In the midst of the November 2009, ROTHSTEIN voluntarily relinquished (RRA"). He was disbarred by the IrMil0sIon of Rothstein, Rosenfeldt and Adler, P.A. On December 1. 2009, ROTHSTEIN Florida Supreme Court. on November 20, 2009. rd County, Florida. was arrested and arrelgnedln Federal Court In Browa the managing partner and CEO of 4. At all times relevant hereto, ROTHSTEIN was RRA, and were the principal 5. Defendant ROTHSTEIN end Stuart Rosenfeldt, are owners. of RRA and each co-founded RRA. "), is an Individual residing in 6. Defendant, BRADLEY J. EDWARDS ("EDWARDS ce law in the State of Florida. At all Broward County, Florida and is licensed to practi yee, agent, associate, partner, times relevant hereto, EDWARDS was an emplo shareholder, and/or other representative of RRA. 7. Defendant I.M. ("L.M.1, is an individual residing in Palm Beach County, Florida. At all times relevant hereto, ■. was represented by RRA, ROTHSTEIN and essential participant in the EDWARDS in a civil lawsuit against Epstein and was an y changing prior sworn scheme referenced infra by, among other things, substantiall ting their fraudulent scheme for the testimony, so as to assist the Defendants in promo EFTA00607533 Epstein v. RRA, et al. Page 4 the Civil Actions (defined below) promise of a mulll-mllilon dollar recovery relative to hor alleged damages. involving Epstein, which was completely out of proportion to ration , with a principal 8. Non-party, RRA is a Florida Professional Service Corpo rdale, FL 33401. In addition address of 401 East Las Olas Blvd., Suite 1650, Fort Laude offices In Florida, New York, and to Its principal office, RRA also maintained seven rt staff. RRA also maintains Venezuela, and employed over 70 attorneys and 200 suppo a 33909-8515. RRA, through an office at 1109 NE 2d Street, Hallendale Beach, Florid herein, conducted business Its attorneys, Including those named as Defendants cted business and filed lawsuits on throughout Florida, and relevant to this action, condu (RRA is currently a debtor In behalf of clients In Palm Beach County, Florida. bankruptcy. RRA is not named as a Defendant). FACTUAL ALLEBATIoNs v. Scott W. Rothstein, Case No. 9. The United States In United States of America South ern District of Florida, has 09-60331CR-Cohn, United States District Court, . § 1962(d) against Scott W. brought an action for Racketeering Conspiracy, 18 U.S.C an of RRA. Within the Rothstein who was the chief executive officer and chairm identif ied the enterprise Information which was filed, the United States of America has In conjunction with "hls co- as being the law firm, RRA, through which Rothstein in the pattern of racketeering conspirators" (not yet identified by the USA) engaged sometime in 2005 up through ' • through its base of operation at the offices of RRA from al activities, Including and continuing Into November of 2009. Through various crimin ca asserts that moll fraud, wire fraud and money laundering, the United States of Ameri EFTA00607534 Epstein v.110.4.44.4, 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. conduct alleged In the Instant "Rothstein and co-conspirators initiated the criminal to supplement the Income and information in order to personally enrich themselves and absence of Rothstein and his co- sustain the daily operation of RRA." In essence, In the operation of RRA, which included 'Conspirators conducting the Renzi schema, the daily accou nts payable including payroll (compensation to lawyers, staff, Investigators, etc.), tigation on cases, including unlimited Improper, harassing and potential illegal Inves not have been sustainable. A copy Epstein-related matters, would in all likelihood would . of the Information is attached as Exhibit *I to this action out as legitimately and properly 10. As more fully set forth herein, RRA held itself and others In RRA were using engaging in the practice of law. In reality, ROTHSTEIN , so as to bilk investors out of hundreds RRA to market Investments, as described below elaborate plan of millions of dollars. ROTHSTEIN and others in RRA devised an of a structured pay-out through which were sold purported confidential assignments 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 tment which was to be paid out being promised In excess of a 30% return on their Inves cases relied upon to Induce Investor to the investors over time. While some of the the confidential, structured pay-out funding were existing filed cases, It is believed that settlements were all fabricated. EFTA00607535 Epstain v. RRA, et at. Page 6 of Investigation (FBI) press 11. Based on media reports, Federal Bureau Ponzl scheme and pattern of conferences arid reteases and the Information the massive In 2005 and continued through criminal activity meant to lure Investors began sometime by some of the Investors and the FBI. the fall of 2009, when the scheme was uncovered and continue to be filed against various As of November of 2009, civil lawsuits were al scheme. Defendants as result of their massive fraudulent and crimin ced by the filing of 12. This fraudulent and Illegal investment scheme Is also eviden Transfer of Corporate Powers Amended Complaint For Dissolution And For Emergency the Appointment of A Custodian or to Stuart A. Rosenfefdt, Or, In The Alternative, For STEIN, individually, (Case No. 00 Receiver by ROSENFELDT, and RRA, against ROTH Judicial Circuit, Broward County, 059301, In the Circuit Court of the Seventeenth ution action, and attached Florida, Complex Business Div.), (hereinafter "RRA dissol hereto as Exhibit 2). for the sole purpose that it 13. Plaintiff references the RRA dissolution action in fact conducting an Illegal and acknowledges that RRA and ROTHSTEIN were promises of financial returns from improper Investment or Ponzl scheme based on ing the actions brought settlements or outcomes of supposed legal actions, includ against Plaintiff EPSTEIN. The RRA dissolution action alleges in part that — the firm (RRA), has, according to "ROTHSTEIN, the managing partner and CEO of antial misappropriation of assertions of certain Investors, allegedly orchestrated a subst law firm's name (RRA). The funds from investor trust accounts that made use of the STEIN centered around the sale of investment business created and operated by ROTH EFTA00607536 Epstein v. RRA, at al. Page 7 Preliminary Statement of RRA dissoluti on interests in structured settlements.° See action, Exhibit 2 hereto. letterhead was used In communications 14. In furtherance of the scheme, RRA's 's trust purported structured settlements. RRA regarding investment opportunities in monies of millions of dollars or wire transfer of account was used to deposit hundreds RRA personally guaranteed payments. from duped Investors and other victims. rt to manufacture false and fraudulent Cou 15; Rothstein's scheme went so far as A- signatures of U.S. District Judge, Kenneth opInkms/ordera including forging the It Is not Susan H. Black, 1144 Circuit in other cases. Marra and U.S. Circuit Cold Judge, ite in Espteln related matters. See Compos yet known ff he forged similar documents Exhibit 3 hereto. ugh me are being revealed on a daily basis thro 16. The details of this fraudulent sche cial ments. The most recent estimate of the finan various media reports and court docu billion dollars. scope of the scheme is that it exceeds $12 civil currently named as a defendant In three 17. Relevant to this anion, EPSTEIN is its and battery that were handled by RRA and actions alleging, inter alia, sexual assault ral its implosion — one of which is filed in fede attorneys including EDWARDS prior to is a 0S-CIV-80893, U.S.D.C. S.D. Fla.XJane Doe court (Jane Doe v. Epstein, Case No. which have been filed In state court In the le named Defendant herein), and two of nty, State of Florida, v. Epstein, Case No. Judicial Circuit Court, Palm Beach Cou O(MB v. Epstein, Case No. 502008CA026058)OC 502008CA028051)OOO(MB AB; E.W. EFTA00607537 Epstein v. RRA, et al; Pep 8 "Civil Actions,' and 1_,M is a named AB), (hereinafter collectively referred to as the August and September of 2008. Defendant herein). The Civil Actions wore all filed In ment or Ponzl scheme was 18. Whet Is clear Is that a fraudulent and improper invest n of the named Defendants, which In fact conducted and operated by RRA and certai defendant In the Chill Actions. scheme directly Impacted EPSTEIN as a named itz, was quoted In a November 2009 • 19; Marn1 attorney entneveloper, Alen Sakow as a potential Investor In August of artielinSfsatifnlytethe had met with ROTHSTEIN ced it was all a Ponzl scheme 2009, but became suspicious. He stated 'I was convin was hiding behind a legitimate and 1 notified the FBI in detail how Scotty ROTHSTEIN Sakowitz was also quoted as saying law firm to peddle fake investments." Attorney ment and former law enforcement ROTHSTEIN had sophisticated eavesdropping equip garbage looking for damaging officers who would sift through a potential defendants' 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. multiple Rothstein related 20. Ft. Lauderdale attorney William Scherer represents used the "Epstein Ploy .., Investors. He indicated In an article that RRNRothsteln had money. He would use. . .cases as a showpiece as bait. That's the way he raised all the All the cases he allegedly structured as bait for luring investors into fictional cases. in there." In fact, on November 20, were fictional. I don't believe there was a real one filed a 147 page Complaint against 2009, William Scherer, on behalf of certain clients, TD Bank, N.A., Frank ROTHSTEIN, David Boden, Debra Villegas, Andrew Barnett, EFTA00607538 Epstein y. RRA, et al. Page 9 rting various anne Caretsky and Frank Preve asse Spinosa, Jennifer Kerstetter, Ros and Ponzl scheme behind the RRA façade; allegations that further prove the massive additional page Amended Complaint naming as of November 25, 2009, a 249 Defentients was filed. bie and belief, ROTHSTEIN, David Boden, Deb 21. hi addition, and upon Information loyees of RRA) on and Kenneth Jenne (all emp VIllegas, Andrew Barnett, Michael Pist h false stage regular meetings during whic through brokers or middlemen would RRA had ber of cases/clients that existed or statements were made about the num files They would show and share actual case against EPSTEIN and the value thereof. clients ge fund managers. Thus, the attorneys and from the EPSTEIN actions with hed e may have work- product privileges that otherwis have waived any attorney-client or existed. l Action n access to some of the actual Civi 22. Because potential investors were give ting Plaintiff became aware of a name of an exis files, Investor-third partios may have her legal tein and had opposed disclosure of who had filed anonymously against Eps Name. the need HSTEIN and EDWARDS claiming 23. In all other instances, by RRA, ROT effectively or fabricated clients, they were able to for anonymity with regard to existing in the designations which was a key element use Initials, Jane Doe or other anonymous ld be created to make the investors believe fraudulent scheme. Fictitious names cou many other cases existed against Epstein. EFTA00607539 Epstein v. RRA, et al. Prise to RRA and Plaintiffs are or were represented by 24. In each of RRA's Civil Actions, the and EDWARDS. its attorneys, Including ROTHSTEIN ons another fifty told that in addition to the Civil Acti 25. in addition, investors were for hundreds represented by RRA, with the potential (50) plus anonymous females were Epstein and that RRA and its attorneys would sue of millions of dollars in settlements, ds. amounts to protect his high-profile frien unless he paid exorbitant-settlement e known that f, EDWARDS knew or should hav 26. Upon information and belie me and/or wore a front for the massive Ponzi sche ROTHSTEIN was utilizing RRA as r claims) involving ent in the Civil Actions (and othe selling an alleged Interest or investm Epstein. RRA) knew S (and possibly other attorneys of 27. Further evidencing that EDWARD massive Ponzi ted in the continuation of the or should have known and participa reported on article, dated November 24, 2009, scheme, a front-page Palm Beach Post "dozens of iture com plaint by prosecutors against the recent filing of an amended forfe r assets — s, foreign cars, restaurants and othe ROTHSTEIN's real estate propertie millions more k account In Morocco, along with including $12 million in the lawyer's ban rted that - ritable funds." The article further repo donated to political campaigns and cha into millions of dollars from his massive Attorney Scott ROTHSTEIN topped costs at his expanding Fort Lauderdale investment scam to cover payroll records released Monday. law firm, federal authorities said in court one generated revenue of $8 million in ROTHSTEiN's law firm (RRA) firm had a payroll of $18 million, recent year, yet his 70-lawyer law EFTA00607540 Epoteln.v. RRA, et al. 'Pagt!'11 RRA used Investors' prosecutors said. lkoTHSTEIN, who owned half of all, they said. money from his Ponzl scheme to make up the shortf ROTHSTEIN received Subsequent articles and court filings have reflected million In 2009, while compensation in excess of $35.7 million In 2008 and $10.5 million In 2008. his partner Rosehfeldt received greater than $6 as D3 Capital Club, LW, ("Dr, 28. ROTHSTEIN attempted to lure the entity known court settlement by offering D3 'e opportunity" to invest in a pre-suit $30,000,000.00 existed and was entirely against EPSTEIN; yet this supposed settlement never STEIN, upon Information and belief, fabricated. To augment his concocted story, ROTH of case files in Jane Doe invited D3 to his office to view thirteen (13) banker's boxes antiate that the claims against EPSTEIN (one of the Civil Actions)! in an attempt to subst against him by RRA. ROTHSTEIN, and were legitimate and that the evidence obtained EDWARDS (the "Litigation Team") was real. others offered other investors like 29. Upon Information and belief, ROTHSTEIN and in the Civil Actions Involving EPSTEIN. the entity D3 fabricated investment opportunities ionable police record and RRA Flsten (a fon-nor Dade County police officer with a quest ty Sheriff and felon) assisted investigator) and Jenne (a former attorney, Broward Coun confid ential, privileged and work- ROTHSTEIN In making these offers by providing product Information to prospective third-party investors. as part of Its Investigation at RRA ' It appears that 13 out of the 40 boxes seized by the FBI EIN, as repotted by counsel for the consisted of flies relating to the Chill Actions Involving EPST be review ed, as well as other discovery, Epstein will Bankruptcy Trustee. Until those boxes can not know the depth of the fraud and those Involved. EFTA00607541 Epstein v. FiRA, et al. Paga 12 N as "bait* and fabricating settlements 30. By using the Civil Actions against EPSTEI Into rs were able to lure investors regarding same; ROTHSTEIN and othe to fund ons of dollars which, In turn, was used ROTHSTEIN'S lair and baked them of milli zi sole purpose of continuing the massive Pon the litigation against EPSTEIN for the scheme. In and the Litigation Team, Individually and 31. As part of this scheme, ROTHSTEIN end Illegally: a conceded effort, may have unethically d with the sale of an Interest In non- a. Sold, allowed to be sold and/or assiste ere non-assignable and non- settled personal injury lawsuits (which ed settlements (including those transferable) or sold non-existent structur cases involving Epstein); rneys fees with non-lawyers; b. Reached agreements to share atto tiffs (I.e., E.W. and Jane Doe) "up c. Used investor, money to pay plain se to settle the Civil Actions; front" money such that plaintiffs would refu rcepted conversations In violation of d. Conducted searches, wiretaps or Inte state or federal laws and Bar rules; and , but not limited to, unreasonable and e. Utilized the judicial procass including purpose of furthering the Ponzl unnecessary discovery, for the sole scheme, other attorneys, Including the Litigation 32. Any such actions by ROTHSTEIN, and s, lly be a violation of various Florida Bar Rule Team, directly or indirectly, would potentia EFTA00607542 Epstein v. RRA, et al. Page 13 and various conflicts of Issues including prohibiting the improper sharing of tees or costs rules. have known of the Improper 33. Evidencing that the Litigation Team knew or should continuation of the scheme, purpose that ROTHSTEIN was pursuing In the EIN cases to pursue Issues and ROTHSTEIN used RRA's Litigation Team in the EPST claims pled In the Civil Actions, but evidence unrelated to and unnecessary to the Ponzi scheme orchestrated by significantly beneficial to lure investors into the ROTHSTEIN and other co-conspirators. claimed their Investigators 34. Upon information and belief, ROTHSTEIN and others rd Epsteln's private jet where discovered that there wore high-profile Individuals onboa possib ly others) copies of a flight log sexual assaults took place and showed D3 (and and international figures. purportedly containing names of celebrities, dignitaries, and knowingly pursued flight data 35. For Instance, the Litigation Team relentlessly EPSTEIN took with these famous Individuals and passenger manifests regarding flights rd and no Illicit activities took knowing full well that no underage women wore onboa ropriately attempted to take the place. ROTHSTEIN and the Litigation Team also inapp to bolster the marketing scam that depositions of these celebrities In a calculated effort was taking place. three of EPSTEIN'S pilots, and 36. One of Plaintiffs' counsel, EDWARDS, deposed serving In Iraq). The pilots wore sought the deposition of a fourth pilot (currently , and EDWARDS never asked one deposed by EDWARDS for over twelve (12) hours question relating to or about E.W., ■., and Jane Doe (RRA clients) as it related to EFTA00607543 Epstein v. RRA, et al. Page 14 planes, But EDWARDS transportation on flights of RRA clients on any of EPSTEIN'S the pilots' thoughts asked many Inflammatory and leading Irrelevant questions about could only have been asked and beliefs (which will never be admissible at trial) which depositions to sell the for the purposes of apUrnping• the cases and thus by using the cases (or apart of them) to third parties. 1 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 settlement by EPST EIN actions against EPSTEIN. The offer of a $200 million dollar 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: (1) Donald Trump (real-estate magnate and business mogul); Law professor, constitutional attorney (ti) Alan Dershowltz (noted Harvard . and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); and (iv)Tommy Mottola (former Presidentof Sony Record); (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 of the Litigation above-named Individuals had any connection whatsoever with any Team's clients, E.W.,11. or Jane Doe. EFTA00607544 Epstein v. PRA, et al. Page 15 es In the state court matters, 40. EDWARDS filed amended answers to interrogatod dly be called E . and ■, and listed additional high profile witnesses that would allege at trial, Including, but not limited to: rly U.S. (i) Bill Richardson (Governor of New Mexico, forme and Representative and Ambassador to the United Nations); EPSTEIN'S charitable, (ii).Any arid all persons having knowledge of political or other donations:2 depositions or listing high profile 41. The sole purpose of the scheduling of these , to "pump' the cases to friends/acqualntances as potential witnesses was, again of these Individuals had or have any Investors. There is no evidence to date that any knowledge reg'ardIng RRA's Civil Asthma. scheme against EPSTEIN, 42. 1n furtherance of their illegal and fraudulent have known) and, at times, L.M. ROTHSTEIN, EDWARDS (who either know or should in her Civil Action against EPSTEIN: federal action in a) Included claims for damages in Jane Doe's g the excess of $50,000,000.00 rather than simply allegin Jurisdictional Hmits. legitimate b) Organized a Jane Doe TV media Interview without any potential legal purpose other than to "pump" the federal case for 2 Those high-profile celebrity 'put pui witnesses have no personal knowledge regarding the facts on these 'Three Cases', but were being contacted, subpoeof naed or listed to harass and Intimidate them and Epstein, and to add 'shwa appeal to the marketing effort the Ponzl scheme. EFTA00607545 Epstein v. RRA et al. Page 16 in Palm investors or to prejudice Epstein's right to a fair trial Beach County. d partner In c) EDWARDS, Berger and Russell Adler (another name RRA) ail attended EPSTEIN's deposition. At that time, no outrageous questions were asked of EPSTEIN which had ons could be bearing on the case, but so that the video and questi shown to Investors. Irrelevant d) Conducted and attempted to conduct completely the CM discovery unrelated to the claims in or subject matter of witnesses Actions for the purpose of harassing end embarrassing thousands and EPSTEIN and causing EPSTEIN to spend tens of defending of dollars in unnecessary attorneys' fees and costs s but was whet appeared to be discovery related to the Civil Action e. entirely related to the furtherance of the Ponzi schem the spring of e) After EDWARDS was recruited and joined RRA in t 2009, the tone and tenor of rhetoric directed to cases agains changed EPSTEIN used by Attorney EDWARDS and Berger from dramatically in addressing the court on various motions matory being substantive on the facts pled to ridiculously inflam and sound-bite rich such as the July 31, 2009, transcript when ce EDWARDS stated to the Court in E.W.L.M.: 'What the eviden as Is really going to show is that Mr. Epstein — at least dating back EFTA00607546 Epstein v. RRA, et at Page 17 tted, back to far as our Investigation and resources have permi attempt to 1997 or '98 — has every single day of his life, made an we're not sexually abuse children. Were not talking about five, larking talking about 20, we're not talking about 100, were not to law about 400, which, I believe, Is the number known .. end it enforcement, we are talking about thousands of children. devised Is through a very intricate and complicated system that he him that where ho has as many as 20 people working underneath those he is paying well to schedule these appointments, to locate girls? and legally f) As an example, EDWARDS filed an unsupportable fer of deficient Motion for Injunction Restraining Fraudulent Trans rty of Assets, Appointment of a Receiver to Take Charge of Prope e Potential Epstein, and to Post a $15 million Bond to Secur -80893- Judgment, In one Doe v. Epstein, Case No. 08-CV was the Marra/Johnson. The motion was reported In the press as ing). ultimate goal (i.e., to "pump" the cases for Investor follow of However, the Court found °Plaintiffs motion entirely devoid evidence . . . and denied the motion in Coto. es that he g) ROTHSTEIN told investors he had another 52 ferna' e, represented, and that Epstein had offered $200 million to resolv EFTA00607547 Epstein v. RRA, et el. Page 1B million, but that he could settle, confidently, these cases for $500 separate and apart from his legal fees. d have known h) ROTHSTEIN and the Litigation Team knew or shoul value that their three (3) filed cases were weak and had minimal 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 arid drugs to customers and prostituting themselves. (Hi) Jane Doe (federal case) seeks $50 million from Epstein. She and her attorneys claim severe EFTA00607548 Epstein v. RRA, et al. 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 arid has admitted that she has Iled 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 Leonard subpoenaing records from an alleged sex therapist, Dr. reflected Bard In Massachusetts, when the alleged police report named that EPSTEIN had only seen a chiropractor In Palm Beach this alleged Dr. Bard. No records relating to EPSTEIN existed for records was sex therapist, Dr. Bard, and the alleged subpoena for or appeal; just another mechanism to °pump" the cases for invest on behalf of j) Allowed a Second Amended Complaint to be filed a alleging that EPSTEIN forced the minor into 'oral sex," yet l ■. testified that she never engaged In oral, anal, or vagina EFTA00607549 Epstein v. RRA, el al. 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 dents 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 0 After EDWARDS Joined RRA, EDWARDS and forme Non- Judge William Berger filed and argued motion to make the USA0 Prosecution Agreement (NPA) between Epstein and , public. But, RRA, EDWARDS and Berger, and their three clients and they already had a copy of the NPA. They knew what It said no impact knew the civil provisions In the agreement had whatsoever on the three pending Civil Actions. The concept behind certain civil provisions In the NPA was 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 them healing in federal court, the NPA was not designed 'to hand a jackpot or a key to a bank." EFTA00607550 Eattele V. RRA, el el. Page 21 to magnify his financial gain 43. ROTHSTEIN, with the intent and improper motive and/or Ponzi scheme, had so continue to fund the fraudulent and Illegal investment the Clvil Actions. EDWARDS demand excessive money from EPSTEIN in had no legitimate purpose in 44. The actions described In paragraph 42 above heroin rather were meant to further the pursuing the Civil Actions against EPSTEIN, but STEIN so that he and others could fraudulent scheme and criminal activity of ROTH of the existing and non-existent claims fraudulently overvalue the settlement value 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) , if a plaintiff received payments from interest In the outcome of the actions. Additionally could impact the plaintiffs investment monies while her action is pending, this clearly on or shade their testimony (1.e. decision of whether or not to settle the current litigati ment and to further promote the commit perjury) to gain the greatest retum on the invest Ponzl Scheme. • 46. The truthfulness of ■'s allegations and testimony in state civil seek a multi-million dollar action have been severely compromised by the need to us settlements of tens of payout to help maintain RRA'e massive fraud. Because fictitio to investors' in this millions of dollars in cases relating to EPSTEIN were represented d to create a fiction that Ponzl scheme, RRA and the attorneys in the Civil Actions neede EFTA00607551 Epstein v. RRA, et al, Page 22 behin d her action would included extraordinary damages. However, the actual facts rdinary measures were never support such extraordinary damages. Therefore, extrao against EPSTEIN. undertaken to create an entirely inflated value of her claims in, she admitted to having a. Though she held herself out as a 'victim" of Epste t claim of abuse. She returned over and over again to him despite her curren gleUescort since the age of 15. has now admitted, under oath, to being a=call (in her deposition September 24, 2009 Transcript "DT" 280:1649). She 156:7) and 'I am a testified "Well, I lived life as a prostitute," (see DT admitted her prostitute when I make money" (see DT 156:12-13). 0 a day from prostitution activity with men other than Epstein to making $1,00 (DT 157:11-158:21). on maybe more than 20 occasions in one year alone nts she collected from L.M. admitted under oath to keeping a list of amou a book of 'Psalms" that she 'Johns" in "two or three" lined books including r the circumstances, her obtained from a religious store (DT 152:1-14). Unde .claim for damages against EPSTEIN, one of ■'s many 'Johns" during that not likely to produce the same period, would be so incredible and certainly ors.' extraordinary settlements promised to "RBA's Invest and RRA, C 47. In April 2007, before she was represented by EDWARDS, the FBi. She was represented gave sworn taped recorded testimony to the agents of spoke of EPSTEIN in a very by a lawyer other than EDWARDS at that statement. She l allegations on which positive and friendly terms and directly contradicted the centra civil action against Epstein is now based. However, once in the hands of EFTA00607552 Epstein v. RRA, of al. Rage 23 ted to changed dramatically. All of a sudden she wan EDWARDS and RRA, L.M.'s story ts, sought tens of millions of dollars. sue EPSTEIN and like other RRA clien nt to the FBI, ■. was insistent that a. For example, In her sworn stateme — FBI): At the conclusion of she 'Jeffrey Is an awesome man." (p. 21 happens to Jeffrey because he's an stated: "I hope Jeffrey, nothing to ld be a shame. It's a shame that he has awesome man and it really wou some guy and he didn't do nothing go through this because ho's an awe of . In fact.. spoke so highly wrong, nothing," (pp. 57-58 - FBI) e with him that the US Attorney's offic EPSTEIN and her interactions 2008 that the US Attorney could not Informed a federal court in July consider a a victim. date on which ■. began her Yet, by September 24, 2009, the and now represented by RRA and deposition in her civil action different tale about purported sexual EDWARDS, ■.'s new and very Influence of EPSTEIN had been misconduct under the supposed into the ROTHSTEIN scam was thoroughly rehearsed and her role action, C.declared that: complete. In her deposition In her civil 208:8) "I, I don't really care about money? (UT to be — this is not right for "Fla needs time in jail. He doesn't want . . 4 (DT 219:21-23) him to be on the streets living daily . EFTA00607553 Epstein v. RRA, et al. Page 24 "You don't think my whole life I have lived that shifty life because of Jeffrey Epstein?" (DT 2221-8) b. In her sworn FBI testimony (pre-EDWARDS and RRA), ■ was emphatic that her Interactions with Epstein Involved no Inappropriate sexual touchingin anyway. In fact, it was exactly the opposite: Did he at any point kiss you, touch you, show any kind of affection towards you? A: Never, never. (p. 21 — FBI) . . . Q: So he never pulled you closer to him in a sexual way? A: I wish, No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no. (p. 21 - FBI) Yet, filed her second amended complaint In April 2009, after EDWARDS Joined RRA, the allegations against EPSTEIN in •'s complaint became even more salacious. In paragraph 12 of L.M.'s Second Amended Complaint, • alleges among other things, that: "Jeffrey Epstein coerced, Induced, or enticed . . .the then minor Plaintiff to commit various acts of sexual misconduct. These acts Included, but wore not limited to, fondling and inappropriate and illegal sexual touching of the then minor Plaintiff, forcing or inducing the then minor plaintiff into oral sex or other sexual misconduct..." EFTA00607554 Epstein v. RRA, et et. Page 25 ,S testified that c. In her sworn FBI statement (pm-EDWARDS and RRA) Me the Individual who first brought LM. to EPSTEIN's any home, told II *make sure you're 18 because Jeffrey doesn't want underage girls.* (p. 8 - FBI). by Yet at her September, 2009 deposition now represented EDWARDS and RRA,.. told a very different story: to ten Mr. Epstein Q: My question was what did Carolyn tell you 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, ■, testifiedto the FBI :1 always made sure — I had a fake ID, anyway' saying that I was 18.* (p.8 FBI). 2009 depo, she Yet, when questioned about her fake ID at her September state& O: And did you have a fake ID? A: No. 0: Have you ever had a fake ID? EFTA00607555 Epstein v. RRA, et al. Page 26 A No. (DT 300:5-8) testified e. In her FBI statement (pre-EDWARDS and RRA), that women she about others'''. brought to the Epstein home. L.M. testified and content with their btought to EPSTEIN's home were eager foithe opporttinity experiences: They'd 154 None of my girls ever had a problem and they'd call me. because they beg me, you know, for us to go to Jeffrey's house I mean, and love Jeffrey. Jaffrey Is a respectful man. He really Is.. sad about he all thought we were of age always. This Is what's so ft. (p 30 - FBI), they left CI: Did any of the girls complain about what happened after there? Jeffrey. A: No. You asked me that question. No, evetybody loved fp. 44 - FBI) fine with A: Every girl that I brought to Jeffrey, they said they were It. and Ilke for example [E.W. - another of RRA's clients in the for the Chill Actions), a lot of girls bagged me to bring them back FBI) money. And as far as I know, we all had fun there. (p. 45 - EFTA00607556 Epstein v. RFtA, et al. Pape 27 Yet, with EDWARDS and RRA as her attorneys, III did a 9801 at her September, 2009 deposition in saying: mind. Pe . . . Once they were there, they were scared out of their They did It anyways and some of them walked out and said mg ever don't ever do this to me again. That was the worst thing that happened to me. (DT 170:6-11) 171:13) ... Pc And then, lot of girls weren't comfortable. (DT II. made f. The above represent only a few of the dramatic changes RDS/RRA end after she in her testimony prior to her representation by EDWA hired ROTHSTEIN, EDWARDS and RRA. scheme, 'M. may knowingly 48. As a result of the fraudulent investment or (Porrzl) Action, or committed a fraud on the have compromised her alleged interests in her Civil court. driven set of facts involving 49. RRA and the Litigation Team took an emotionally a Palm Beach Billionaire and alleged innocent, unsuspecting, underage females and and resolv ing the cases based sought to turn it into a gold mine. Rather than evaluating ble, voluntary and consensual on the merits (i.e. facts) which included knowledgea pre-Epstein psychological and actions by each of the claimants and substantial sexual experiences pre- emotional conditions of each of the claimants and substantial protective orders and objections Epstein, RRA and the Litigation Team sought through 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 EFTA00607557 Epstein v. RR& et S. Page 28 been successful. As Magistrate Judge Unnea Fortunately, their tactics have not Case d September 15, 2009 (DE 299 in Federal Johnson wrote in a discovery order date for Protective Order #08-80119) in denying Plaintiffs' Motion in this case Is clear that the childhood of "This is his [Epstein's] right. The Record ances of abuse and negleqt, which in many of the Plaintiffs was marred by Inst the in part, In the damages claimed by turn may have resulted, In whole or Plaintiffs.' d October 28, 2009 (DE 377 in Federal in addition, in an Omnibus Order date Linnea Johnson wrote: Case 808-80119) Magistrate Judge heart of the Plaintiffs damage claims, 'Here the request at issue goes to the very ry, but tion relating to Plaintiffs sexual histo requesting not only general Informa or rein Plaintiff received compensation inquiring as to specific Instances whe , or r males sexually assaulted, battered consideration for sex acts, claim othe committed lewd or lascivious acts on her, abuses her, and/Or dalm other males ry and unequivocally place their sexual histo As a global matter, Plaintiffs dearly 's actions in this case has negatively in issue by their allegations that Epstein other things, "distrust In men," 'sexual affected their relationships by, among personal t," "social problems; • problems In Intimacy problems,' diminished trus men," ;premature teenage pregnancy," relationships," feeling of stress around e ality and promiscuity." Considering thes 'antisocial behaviors,' and 'hyper-sexu no question that Epstein is entitled to know allegation, there simply can be d the subject of other "sexual activity' or lew whether Plaintiffs were molested or EFTA00607558 Epstein v. RRA, et el. Page 29 er there is an alternative end 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 relationships with others or alleged In the Complaint materially affected Plaintiffs' s and/or whether how those acts did not have such an affect on those relationship ological disorders as a Plaintiffs suffered from the alleged emotional and psych in the Complaint. To deny result of other sexual acts prior to the acts alleged g him from mounting a Epstein thus discovery, would be tantamount to barrin defense'? 50. ROTHSTEIN, EDWARDS and Ss actions constitute a fraud upon EPSTEIN ented themselves to be acting in as RRA, ROTHSTEIN and the Litigation Team repres at all times when in reality, good faith and with the bests Interests of their clients In mind or Ponzl scheme described herein. they were acting In furtherance of the investment the representations of RRA, and EPSTEIN Justifiably relied to his detriment on Defendants, ROTHSTEIN, EDWARDS and as to how he conducted and. defended the Civil Actions brought against him. Illegal Investment or Pon7I 51. As a direct and proximate result of the fraudulent and wn coconspirators and as scheme orchestrated by ROTHSTEIN and as yet other unkno tion Team and as set forth a result of the litigation tactics undertaken by the Litiga to incur the monetary damages herein, Plaintiff EPSTEIN has incurred and continues excess of the Civil Actions' true including, but not limited to, having to pay an amount in ntage of any payment by value as a result of them refusing to settle in that a perce EFTA00607559 Epstein V. RRA, et al. Page 30 investors; incurring significant EPSTEIN may have been promised to third party refusal to conduct settlement additional legal fees and costs as result of Defendants er because any monies paid by negotiations in a forthright and good faith mann and incurred significant EPSTEIN is in reality a promised return on an investment ery that was not relevant, material attorneys' fees and costs in defending the discov evidence, but which was done for the and/or calculated to lead to the admissibility of sole purpose of `pumping" the cases to Investors. of the fraudulent and criminal 52. EPSTEIN has also been Injured in that the scope firm that EPSTEIN has been or racketeering activity so permeated the RRA law s brought against him. In prevented from fully and fairly defending the civil action continuation of the massive essence, the very existence of RRA was based on the other co-conspirators. In order to Ponzi scheme orchestrated by ROTHSTEIN and and other co-conspirators used continue to bring In monies from Investors, ROTHSTEIN factured lawsuits, as a means the Civil Actions against EPSTEIN, along with other manu of obtaining massive amounts of money. 53. ROTHSTEIN, EDWARDS and ■, are liable for damages caused to EPSTEIN - individually, and jointly and severally. Count./ —Violation of 1$§772.101, of seq., Fla. Stat. - florltin Civil Remedies for Criminal Practices Act — Against All Defendant's, h 53 as if fully set forth 54. Plaintiff realieges and incorporates paragraphs 1 throug herein. EFTA00607560 Epstein v. RRA, et el. Page 31 55. RFtA, ROTHSTEiN, EDWARDS and each and collectively constitute an enterprise pursuant to §772.102(3), Ha. Stat. (2009). of criminal activity as 58. ROTHSTEIN, EDWARDS and L.M. engaged In a pattern defined In §772.102(3) and (4), Ha. Stat. (2009). multiple predicate 57. As alleged heroin, ROTHSTEIN and EDWARDS committed including violations of Florida acts in vielation of §772.103(1), (2), (3) and (4), Ha. Stat, ctions; Chapter 817, relating to Statutes - Chapter 517, relating to securities transa h Includes L.M.); Chapter fraudulent practices, false pretenses, and fraud generally (whic and Chapter 831, relating to forgery; §838.05, relating to extortion (which Includes' 837, relating to perjury (which Includes ■.). Substantially more than two predicate of fabricated settlements outlined acts (Le., the selling of or participation of the sale well as the improper litigation herein, including the Civil Actions involving Epstein as period. tactics outlined above) occurred within a five-year time , EDWARDS and L.M.'s 68. As a direct and proximate result of ROTHSTEIN d. violations of §772.103, Fla. Stet, EPSTEIN has been injure is entitled to threefold of 69. Pursuant to §772.104(1), Fla. Stat., Plaintiff EPSTEIN fees and court costs, and such his actual damages sustained, reasonable attorneys 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 end 0orroottOrpaplzatIon • ct" Pursuant to SAS9S.01, et SOCI.. Fla„Stattf2I309i, MaInst All Defendan EFTA00607561 Epstein v. RRA, el lg. Page 32 60. Plaintiff realleges and incorporates paragraphs 1 through 53 as if fully set forth herein. 61. RRA, along with ROTHSTEIN, EDWARDS and L.M., each and collectively, constitute an enterprise pursuant to §895.02(3), Fla. Stat, (2009). 62. During all times relevant hereto, ROTHSTEIN, EDWARDS end L.M. 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, § 695.03(3), Fla. Stat., as alleged above herein. 64. The breadth and scope of ROTHSTEIN, EDWARDS and, potentially, M.'s racketeering activity continues to be investigated by the FBI, as numerous cNil 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 AcUons Involving Epstein as well as the improper litigation tactics outlined above) occurred within a five year time period. 66. Pursuant to §895.02, Ma. Stat., ROTHSTEIN and EDWARDS engaged in a pattern of 'racketeering activity" through the commission of crimes as defined In § 695.02(1)(a)-(b), Fla. Stat., including Chapter 517, relating to securities; Chapter 817, relating to fraudulent practices, false pretenses, and fraud (Including M.) generally; EFTA00607562 Epstein v. RRA, at al. Page 33 ion (Includingill.); Chapter Chapter 813, relating to forgery; §836.05, relating to extort 837, relating to perjury (including L.M.). following relief against 67. Pursuant to §895.05, Fla. Stet, Plaintiff seeks the Defendants, ROTHSTEIN, EDWARDS andll.: elves of a) Ordering ROTHSTEIN and EDWARDS to divest thems any Interest In the enterprise, RRA; conduct b) Enjoin all Defendants from engaging In the same type of and activities as described herein; and LM., from c) Temporarily enjoining ROTHSTEIN, EDWARDS and EPSTEIN the continuation of the CMI Actions brought against st RRA until criminal charges have been formally brought again may be and/or any of the Defendants, such that EPSTEIN s allowed to evaluate whethor a stay or dismissal of all Civil Action against him Is method. ey's fees and costs, 65. EPSTEIN further seeks an award of his reasonable attorn and such Other reliefthat this Court deems appropriate. entry of a judgment for WHEREFORE, Plaintiff EPSTEIN respectfully demands the the relief sought and damages against the named Defendants. Count III — Abuse of Process - Against All Defendants h 53 as if fully set forth 69. Plaintiff realleges and incorporates paragraphs 1 throug herein. EFTA00607563 Epstein v. RRA, et el. Page 34 70. After Instituting the CM 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 exorcising 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 Aaalnst 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 L.M. 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 reallt)i, 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, EFTA00607564 Epstein v. RRA, at at 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 CommItcraud Aesinst 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 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 Ponzl 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 M.'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. ROBERT . CRITTON, JR., ESQ, Florida No. 224162 EFTA00607565 Epstein v. RRA, et at. Page 38 rCrit(DbcIclavii,corn MICHAEL J. PIKE, ESQ. Florida Bar #617298 mplkeeticiclewicem BURMAN, CRITTON, LUTTIER & COLEMAN 303 Banyan Blvd., Suite 400 West Palm Beach, FL 33401 581-842-2820 Fax 581-253-0154 (Attorneys for Plaintiff) EFTA00607566