EFTA00622924

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50 2009CA040800XXXXMB AG JEFFREY EPSTEIN Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. EPSTEIN'S MOTION TO POSTPONE THE JUNE 4, 2010 HEARING ON ROTHSTEIN'S MOTION TO SET ASIDE DEFAULT Plaintiff, JEFFREY EPSTEIN ("Epstein"), moves to postpone the June 4, 2010 hearing on Defendant's, SCOTT ROTHSTEIN ("Rothstein"), Motion to Set Aside Default, and states: 1. Epstein filed the instant action against Rothstein and others on December 9, 2009. 2. On December 31, 2009, Epstein filed a Motion for Default due to Rothstein's failure to respond to the Complaint. 3. A default was entered by the Clerk on January 21, 2010. 4. Rothstein filed a Motion to Set Aside Default on February 17, 2010. 5. Several weeks later and on the eve of the hearing on Rothstein's Motion to Set Aside Default, Rothstein filed an affidavit on March 8, 2010in support of his Motion to Set Aside Default. 6. The next day, March 9, 2010, a hearing was held on Rothstein's Motion to EFTA00622924 Set Aside Default and the Court deferred ruling so the parties could conduct discovery related to the motion (3/9/10 Order attached as Exhibit A). 7. On April 5, 2010, counsel for Epstein wrote to counsel for Rothstein to coordinate Rothstein's deposition and indicated that since Rothstein is in jail, the location of his deposition would likely have to be moved. ask 4/5/10 Letter attached as Exhibit B. Counsel for Rothstein never responded to said letter. 8. On April 15, 2010, Epstein filed a Motion to Strike Affidavit of Scott Rothstein because he was unable to depose Rothstein. 9. On April 22, 2010, the Court denied Epstein's Motion to Strike Affidavit of Scott Rothstein and granted an additional thirty (30) days to depose Rothstein (4/22/10 Order attached as Exhibit C). 10. However, Rothstein's own counsel has had considerable difficulty locating and communicating with his client. In an April 22, 2010 article in the South Florida Business Journal (attached as Exhibit D), it was reported that Rothstein's counsel, Mark Nurik, Esq., was unaware of his client's location for substantial periods of time and has only had limited contact with Rothstein. Mr. Nurik was quoted as follows: a. "(Rothstein) is presently in protective housing outside of this district.... Undersigned counsel's contacts with his client must be arranged and approved in advance through the government, which creates delay." b. "There have been numerous occasions in the past few months when undersigned counsel has been unaware of his client's location and has been repeatedly out of contact with his client for substantial periods of time, including one period for over two weeks." c. "Given these limitations in the past five weeks, counsel has only been able to meet with his client on two occasions. Currently, there is no ability to e-mail (Rothstein), and phone contact is very limited. Even the sending and receipt of legal mail takes longer than the norm." 2 EFTA00622925 See Exhibit C (emphasis added). 11. Interestingly, counsel for Rothstein had no problem obtaining Rothstein's notarized signature on his affidavit. 12. Due to the additional time given to depose Rothstein, the hearing on Rothstein's Motion to Set Aside Default was rescheduled to June 4, 2010. 13. However, Epstein has been unable to locate, let alone depose, Rothstein and therefore requests the Court postpone the June 4, 2010 hearing on the Motion to Set Aside Default. 14. Epstein's counsel has made the numerous efforts to locate and depose Rothstein, to no avail: a. Telephone conference with Lisa Kaye, Case Management Coordinator/Legal Liaison at the Federal Detention Center in Miami — was advised they do not have custody of Rothstein, have no Information on his whereabouts and could not assist in coordinating his deposition; b. Telephone conference with U.S. Marshal's office — was advised they are not responsible for coordinating depositions and would not give provide any information regarding Rothstein. c. Telephone conference Bureau of Prisons Inmate Locator in Washington D.C. — was advised they have no record of Scott Rothstein; d. Telephone conference with Port St. Lucie Jail — was advised they had custody of Rothstein for brief period, but had no Information on his whereabouts; e. Two voicemails for Bureau of Prisons — never returned a call; f. Two letters and two voicemails for United States Attorney Paul Schwartz — never returned a call or responded to letters; and g. Voicemail for United States Attorney Jeff Kaplan — never returned call. 15. In addition, news articles have suggested that Rothstein is entering the federal witness protection program due to his involvement In assisting the government 3 EFTA00622926 arrest reputed Gambino mob figure Robert Settinerl: h. tut [Rothstein) may end up spending less time behind bars; the feds plan to put him In prison under the witness protection program for helping sting Settinerl in the FBI undercover operation.' See 3/19/10 Miami Herald Article attached as Exhibit E. I. "Sources tell CBS4 News that because of his cooperation in this case [against Settineri), Rothstein will be entering the federal witness protection program — meaning he will serve his prison time for the Ponzi scheme under a different name and in a prison outside of Florida. See 3/15/10 CBS4 Article attached as Exhibit F. 16. Given the above-described difficulties in locating and deposing Rothstein, Epstein requests the Court postpone the June 4, 2010 hearing on Rothstein's Motion to Set Aside Default and provide an additional thirty (30) days to take Rothstein's deposition. WHEREFORE, Defendant, JEFFREY EPSTEIN, requests the Court postpone the June 4, 2010 hearing on Rothstein's Motion to Set Aside Default and provide an additional thirty (30) days to depose Rothstein and grant any additional relief the Court deems just and proper. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this 2e day of Msy, 2010: Gary M. Farmer, Jr., Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, P.A. & Lehrman, PL 250 Australian Avenue South 425 N. Andrews Avenue, Suite 2 Suite 1400 Fort Lauderdale, FL 33301 West Palm Beach. FL 33401-5012 Fax: fax Co- unse efendant Jeffrey Epstein Attorneys for Defendant, L.M. Jack Scarola, Esq. Law Offices of Marc S. Nurik Seamy Denney Scarola Barnhart & Counsel to Scott Rothstein Shipley, P.A 4 EFTA00622927 2139 Palm Beach Lakes Blvd. One East Broward Boulevard, Suite 700 West Palm Beach, FL 33409 Fort Lauderdale, FL 33301 Attorneys for Defendant Bradley Edwards BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Palm Beach, FL 33401 Fax By: Ro .ert D. Craton, Jr. ci Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 5 EFTA00622928 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Clv. Pro.1201 Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, Individually, and L.M., Individually, Defendants.. ORDER ON DEFENDANT SCOTT ROTHSTEIN'S MOTION TO SET ASIDE DEFAULT THIS CAUSE came before the,Court on Defendant Scottflothstein's Motion to Set Aside Default, and the Court having heard argument of counsel and being fully advised in these premises, it is hereby ORDERED and ADJUDGED that said Defendant's Motion is hereby .grentedt .denied— yuc e;ettiAj i IP/ c-c.4....3 Tha d— /...eit/LA-2 1914Ath et4t, 9 t 7Z.; • "7171 /RA ehh.4 z ur°vet in Ad5O:4 ce-- -767- *tonen DONE AND ORDERED at Palm Beach County-Co rthouse, st P Im Beach, Florida, this ? - day of //hilt-- 2010 David F. Crbw Circuit Judge Copied furnished to: ROBERT D. CRITTON, JR., ESQ., Burman, Crilton, Lutlier & Coleman, 303 Banyan Boulevard. Suite 400, West Palm Beach, FL 33401, MARC S. NURIK, ESQ., Law Offices of Mark S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301, GARY M. FARMER, JR., ESQ., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL. 425 N. Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301, JACK SCAROLA, ESQ., Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409, and JACK ALAN GOLDBERGER, ESQ., Atterbury Goldberger & Weiss, PA., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012 EFTA00622929 BURMAN, CRITTON YE LUTHER &COLEMAN,LIP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP J. MICHAEL BARMAN. PAP GREGORY W. COLEMAN. PA =MT= Matta D. CRITTON. JR.. PA. • CADWELL BERNARD A. taunters BOBBIE M. MCKENNA MARK T. Linn. PA AsHut STOKEN•BARING MICHAEL J. Pin April 5, 2010 Stay STOKES DAVID A YAREMA PAMUCAIS RITA H. SuossyK SNONDA Kum)merino CIVIL ma LOVER Of COUNSEL 7ADMITTIO TO PMCTIVI IN aCOADAAND COTORMO EDWARD M. RICCI 07 COUNSEL Sent by Fax. E•Mall and US. Mali Mark Nurik, Esq. Rothstein, Rosenfedlt, Adler, P.A. 401 E. Las Olas Blvd., Suite 1650 Ft. Lauderdale, FL 33301 Re: Epstein v. Rothstein. et al, Case No. 50 2009CA040800XXXXMB AG Dear Mr. Nurlk: As you are aware, we have set your client's Motion to Set Aside Default on a special set for 40 minutes on April 30, 2010 at 3:30 p.m. The court indicated we both could take discovery. I am enclosing a Notice for the Deposition of Scott Rothstein at a court reporters office at West Palm Beach. I have set it for April 15, 2010. I am aware that Mr. Rothstein is in jail, and therefore probably cannot attend that deposition at that location. Therefore, I am willing to move the location. The deposition will deal solely with issues associated with his Motion to Set Aside the Default. If that deposition time does not work, please let me know. If it is your intent to file a motion for protective order regarding Mr. Rothstein, please so file. Additionally, I would like an additional date such that I can take Mr. Rothsteln's deposition in the case. Specifically, I would like to cover those Issues that are directed to Mr. Edwards, I have received a Notice from Mr. Edwards' attorney which requires me to do the necessary work and investigation such that I can make certain recommendations to my client. I am aware that Mr. Rothstein prior to his plea, was completely off limits to.a deposition. With his guilty plea, I would anticipate that he now EXHIBIT 303 BANYAN BOULEVARD • SUITE 4430. WEST PALM BEACH. FL 33401 • PHONE: S61.842-2820 •' WWW.BCLCLAW.COlvt EFTA00622930 Epstein v. Rothstein Page 2 is available to give a deposition. Would you please contact me such that the above discovery can be arranged. Cordially Yours, o D. Critton, Jr. RDC/clz EFTA00622931 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, Case No. BO 2009CA0401300XXXXMB AG v. SCOTT ROTHSTEIN, Individually, BRADLEY J. EDWARDS, Individually, and L.M., individually, Defendants. ORDER ON MOTION TO STRIKE AFFIDAVIT OF SCOTT ROTHSTEIN THIS CAUSE came before the Court on Motion to Strike Affidavit of Scott Rothstein, and the Court having heard argument of counsel and being fully advised in these premises, It is hereby ORDERED and ADJUDGED that said Motion is hereby /716141e4set," Att-rn--/ Tivo-Yiefut 02 wi / pop hrwafi 6, go 614,as 74, alla) /2•-d %AA-IS -76 66-61-> eixoccnz co - 7‘ DONE AND ORDERED at Palm Beach C Courtho est each, Florida, this (54 of 41 , 20 David F. Crow Circuit Judge Copied furnished to: ROBERT D. CRITTON, JR., ESQ., Burman, Critton, Luttier & Coleman, 303 Banyan Boulevard, Suite 400, West Palm Beach, FL 33401, MARC S. NURIK, ESQ., Law Offices of Mato S. Nurlk, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301, GARY M. FARMER, JR., ESQ., Farmer, Jaffe, Weissing, Edwards, Rstos & Lehrman, PL. 426 N. Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301, JACK SCAR0LA, ESQ., Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409, and JACK ALAN GOLDBERGER, ESQ., Atterbury Goldberger & Weiss, P.A., 260 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401.50 EXHIBIT I 0_ EFTA00622932 South Florida Business Journal: Rothstein sentencing moved to June 9 Page 1 of 1 Womboa:Ligil i Net asehrimit Rimier rre in ion myna Sate, /swim Mira :Weal •ma zt, otto theatrullahridairgasmeuseverMeorldstralwitindai nt eltragiteltaktiasulorlsodeameantirdsed_ttrol rida MISJOURNAL Blog: Scott Rothstein: Picking up the Pieces Paul Eirinkrnann Rothstein Sentencing Moved Reporter To June 9 thwiesy. An 22.2010. 1.2Sem EDT I Mailed Trmsder. Apra 22, 2010.1:40pm A fudge has moved Pond schemer Scott Rolinteln's sentencing back more than a month. that Is not necessarily so unusual, but re reasons seem pretty wad. There's a motion from Rothstein's attorney, Marc Nur*, that's unlike anything I've seen In a court case recently. Runk claims that ROthstein's cooperation with federal authorities by provIdkig evidence for alleged mana stings has Interfered with NudWs ability to communicate with him, According to federal euthorilleS and numerous media reports, Rothstein helped set up two employees of Me Star CrecuUve Protection & liwestkration, a local security film that had ties to the mall., and Roberto Settineri, an alleged Sid:lan maha connection In South Panda. Ad three were hit with federal Indictments after Rothstein aregeoly asked them to launder money and destroy evidence of Ns Pond scheme. This comes after the Rest sealed document was feed in flothsteireS criminal case, which is a Ronal that might mean the reds are recommending a lighter sentence because of cooperation. KIN Nuke Mask naletreadv admitted to creating a smokescreen of misdirection so that the public end certain alleged criminals would think that Rothstein was flaunting federal jurisdiction before he was arrested. here's the relevant teat of flunk's request for a later sentencing date: - SeedflallY, the defendant Is presently in protective housing outside of thls Strict and treated differently than other inmates. Undersigned counsel's contacts with his clad must te arranged and approved in advance through the government, witch creates delay. - There have been numerous occasions in the past few months when understined counsel has been unaware of his client's location and has been repeatedly out of contact with Ns client for substantial periods of time, Including one period for over two weeks. 'Given these limitations, in the past five weeks, counsel has only been able to meet with his caent on two occasions. Currently, there is no Mary t0 Amall the defendant, and phone contact is very coated. even the sending and receipt of legal mail takes longer than the norm." Rothstein was to be sentenced May 6. De new date Is )une 9, at 9:30 e.m. telegeMESSIIIIServito. Coati ihe fatli#010$ POOS.SSABSIONO. IWctlurR.Ro0ma9sir.d AO conlenls of this Site ID American CilyButhiess Journals Inc. AU rights reserved. http://southflorida.bizjournals.com/southflorida/blog/picking_up_the_pieces/... 5/4/2010 EFTA00622933 Scott Rothstein figure accused of making threat - 03/19/2010 - Miamtheral... Page 1 of 3 ZheRliamiHeralb Posted on Fri, Mar. 19, 2010 4.P Scott Rothstein figure accused of making threat By JAY WEAVER tweavernMiamIHerald.com Roberto Settineri, the reputed Sicilian mafioso snagged by Ponzi schemer Scott Rothstein in an FBI sting, had a little brush with the law in January. As he was eating al fresco at Soprano Cafe on Lincoln Road, Settineri opened his leather jacket to flash a handgun at a private security officer, a police report states. "I will put this gun in your f-----g mouth," Settineri told the security officer, the report says. "I know where you live. I'll go to your house and kill you and your family." Miami Beach police eventually caught up with Settineri, who denied threatening the guard with his firearm. The cops arrested Settineri, 41, of Miami, on an aggravated assault charge, a third-degree felony. But that's the least of his problems. Last week, FBI agents arrested Italian-born Settineri, a naturalized U.S. citizen who works as a wine wholesaler, on obstruction of justice and money laundering charges in connection with Rothstein's $1.2 billion investment scam. Federal authorities also accuse him of being connected to the mafia's Colombo and Gambino crime families. At the same time, Italian National Police officers flew to Miami and revealed charges accusing Settineri of belonging to the Sicilian mafia and participating in a slew of violent crimes. Settineri was a regular on Lincoln Road, where he sold wine to resta lining the popular pedestrian way. JANUARY INCIDENT Michael Catalano, Settineri's lawyer, said his client was eating with of other men at Soprano Cafe on Jan. 8 when he had the run-in with the http://wvvw.miamiherald.com/2010/03/19/v-print/1536775/rothstein-figure-... 5/11/2010 EFTA00622934 Scott Rothstein figure accused of making threat - 03/19/2010 - MiamiHeral... Page 2 of 3 security officer, Cesar Mainardi, who was on his patrol bike. He worked for Security Alliance, a company contracted with the city of Miami Beach, Catalano said Mainardi confronted Settineri over a woman they both knew. Mainardi "weaved his way through a tight crowd and intentionally harassed him," Catalano said. Settineri "told the security guard to leave him alone, and he made up these allegations." But Mainardi, in an interview with The Miami Herald, denied the fight was over a woman. In his police statement, Mainardi accused Settineri of threatening him for no reason: "Apparently he did not like the way I looked at him, and I noticed his reaction and wanted to talk to him, but he acted aggressive." 'HEATED ARGUMENT' Mainardi told police that Settineri flashed the semi-automatic weapon, which was in a holster on his belt. But "he never took it out," Mainardi said. Settineri left the restaurant after the confrontation, but Miami Beach police reached him on his cellphone. According to the police report, Settineri admitted having a "heated argument" with the security officer but denied "threatening him with any type of gun." Settineri said he owned four guns, but they were all at his Brickeil Key condo in Miami at the time of the incident. Police found no weapon on him. State records show that Settineri has a concealed-weapons permit. ROTHSTEIN LINK Rothstein, who came to know Settineri through a Broward security company he had hired for protection, allegedly talked Settineri into shredding documents and laundering $79,000 in November from the Fort Lauderdale lawyer's Ponzi scheme, according to an indictment unsealed last week. Rothstein, 47, who pleaded guilty to racketeering and other charges in January, faces up to 100 years in prison at his sentencing in May. But he may end up spending less time behind bars; the feds plan to put him in prison under the witness protection program for helping sting Settineri in the FBI undercover operation. lutp://www.miatniherald.com/2010/03/19/v-print/1536775/rothstein-figure-... 5/11/2010 EFTA00622935 Scott Rothstein figure accused of making threat - 03/19/2010 - MiamiHeral... Page 3 of 3 Italian authorities charged Settineri along with 19 other people allegedly linked to the Sicilian mafia. The charges: extortion, drug trafficking and attempted murder. © 2010 Miami Herald Media Company. All Rights Reserved. http://www.miamiherald.com hup://www.miamiherald.com/2010/03/19/v-print/1536775/rothstcin-figure-... 5/11/2010 EFTA00622936 I-Team: Rothstein Helps Take Down Alleged Mafia Player - cbs4.com Page 1 of 3 the ClitSI bTeam's Most Popular Mvssfgabons lateolw Descate e The Downs Of Satan eels Wade • dm Sapar. T he Priest and The Mt o AP Travers DirtyUMW Swat • (Moog Any Maim Jobs. Pent E•ma Pita Slums Comments (2) /Or K. 20 tit 4:44 pa US/taseem I-Team: Rothstein Scams Alleged Mafia Player Rothstein Hired Security Firm For SISK/Day 7. Coss TSMe4Mlnw6aants 111 WM (CHU I•TEAM) — In Sough Fiala: where Maslen sal chats we an overplay fad cads. Scott Rothstein may be remembered a vie vestal maw el tam &Lawyer who rose from abeam* to bulk one tithe most pr/ally powered law fins In Pe state, Rothstein new shut comikkal of blUag era and strangers Mkt. TM $1.2 bison Pond schwa he napalm adiestrated la Ow 1519511 to SANS Florida Wan He bed, tricked and deasked nosey everyone he met Md the Jim Deane tinge he caus*Smay Ilieltef be matted. Ems I Out Redislelka amid cm may Kama be the one he hee done on behalf of the fades* government The CBS. I-Team has leaned from muitka sources thst Rothstein was the key Mute In baba; down a aspected Halle tome Moths FBI ha been trying to catch for year,. ow trims of I test week, U.S. Marna Jeffrey Simian announced Me erten ol Oita IMMOusle, Including Roberto Mead, who der prosecutor Scott Rani& COS described se the W ben. , tot to OstribM0 other aganttadal is Brooklyn and La C. Hata n Pent. SPcy. Related Slideshowa Those areas were pen der IOW US sod Haan law enfoicement salon; Stoma sea dudog Wednaday's press conference. 2010 KM TowneMOM AI the same one Seined wes errata by en F81 SWAT Team at Ha home on Warn, Snack Ova staged marks' of to SetectIon °ambito cane May wens latest In Droner. and minty members of as Siam mW. rereenli•Oen. Santa Mn de Gnu, CPS. In We were aka Into custody Li Palermo. Community Taken Into custody In Saes Fiala Slav with Set6ned was Dane Dromerhausa A Odd indkidual. Enrique Ros of Pembroke Pints was 'Merged Sol wee out a this country Swot* rata look piece. CA Chsmdlonsko Day 4 Seamed, Ofornetheuser as Roe wow Soma with one count of oonairecY lot:Ulna MOW and be counts a WelroMon as snowman Soobstruct federal proceedings. one ccuM of cosailray to launder money sod fivecounts ot substendve money Related SiOria kunailng N corMcard d d dew counts the mon cc'ld oath be Roamed to 110 yeas n prison. Although Rotelelka name ova appears M M Indiarnent not wee 4 mentioned Outing Wedneridayie pies* conerence el Po U.B. bTearr Rothstein Hired kidney' CISCe,C1384 fan ha leaned OM to man et the watt Of Sts at. Is none oaf then Scott Rothstein. Sectary Flan For 3101(tDry (3/17.2010) lawn Rogssimit returned from lairoCcocelNomMbae 3, he inmeceately began cafferating Sit prosecutor's Hunkered don In a bola monk barna of Sorel agents quad:ad ROthsteln Mays about everyone he has wet done business win. One name, Moser, ROW; stood out - Roberto Satinet 01014Crukrie deIOW OfOrnithiltier and Roses `OSIOCIftlele OIS•tanell They 09110100 a Ware away rim Wed Me Mar exeCuirre PielOCIOn a Invesbeacer Atoning to et temmoy kr Oromorboosot For Star Old extensive work for Rothstein. prosaic Sassily for Rea:Rase tat end Ns businesses. They were kit hired by Rotoion ward yam ago to pro✓de walk for Can Camaro - Ow (nowt Venue µmelon - ellar pothatern bcoghl Da plop.ly. 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ROtherern had lo PORNIr the mrq.%tEnn NI wee rot {_+opereLp v...1). the FBI. • EXHIBIT http://cbs4.com/iteam/Scott.Rothstein.M 5/11/2010 • EFTA00622937 I-Team: Rothstein Helps Take Down Alleged Mafia Player - cbs4.com Page 2 of 3 On Neoember 9th. It • more oirstily cgclusse•Md by federal agents. Rothstein Messed up el he Cistutil WO fora meant Tit vØ was men posed by Browsed New Testes. Centes,pap We aende. Pothsloks Not same ay gmeiled en Santee with Chimed 7. Once gain. he 'Mood he kennel cooperating wIth Wet& sulhoniSM Mee yeses ~nine ethers to mete tonne doh. Rothstein was now using Wows Wile on tie turf of the twtewit government Md me kids ay he was ecorewhil, 'AI eiltged In Wei IMIetmerni Steamed. Dromerhautte end Rol were owl of • compact to launder 10 n•lkon tri as funds.' Ginoe Raid Owing isilerinesdayis press cardensnoe. In January, el legend agents In Miami ~Mind to bold a case sgeonst %Me& a htgh lewd mate look pace St II*. Arta and Proffeffagrs Bea Fan and MOOeffs. as wen as Judder Oeparlmentoffioels from Wes/lepton. ers v ecresS He Mang, to net »di fAa Wan counserparle Whin peosecoso ware working on • mashie W•latrrienl egepr Nor*/ suspected ~whets o4 die Pahsrmo.Sseed CM* ongtffeelicn. Semi Mena de Oat Md 41 New York prosecutorsvote beading • seen% case mogul three staged members of the Gandåsto «Wm fans. The Weal au InveivIng Setting:I bed finely eaten them the Mk they had been~ for. nervous agreed trey world goorrantrle Uwlr cuss we mete the easels *Muffsneousty. Reftarge OMIT asks ~or In the Ulan National Pollee. *Mime In South Boas Isetweek with • handful of agent. to monene tel Skinmm operaion, The ~twit Intennedlary In Me US was Robert Seine& • nun frail Palermowho has been Bang In taking foe a tang P'rito; Grassi said. 'He has Impotent bee to the ~aka Ma, Iambi. el ~Oho end Coloenta Throe»Rolutrb &desert, Le Cosa Now. Wes Wag to µan new comedian' In the Us end Ws conneceent would enable the listen organtratan so lone» amen...Made' -Midrib a sery importeM day In the NM against the atmirtet Grp* itz«Ion of La Cosa Noses.' Grant *ski Today• resin. are the Basta very conseceded Invesegellon aided mkt by the lumen State PeSert together *oh tel FBI bows n hay end the Udad Steles" Jun how compile-Wed was the Inveatigsgont Net wrong to reveal Rothstein to» n phi Caw US ~nay Snosten oily catered this cryptic wagons* when asked whit trough. We Wan& end tel Americans together. Wks Sad meal InSmaltS that overlapped w/thno a who; he said. 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CBS Broackcaseug Inks ti Meta Revered.) kang (Been floe Never Been Ealiorl Ooksg Gien To PtgoaTour Horns • EcoZone: Store Seas EPP-RINI* Pan Keys Wonwo Go Hiked rot A Good Cause k Omarks OW: Hew Te Grow Orion Fanlo Weans Parli.ln To Go Green 160 Comment To peel totreente,ww Mod tOg lolly ~dap hem Need e log Wi kr)0101hero Yew Name Year EaleR L_ -1•ViLlnol be dstffeyed with cornmeal sung.«sox kFk ...1 -...72 111• eg Murk mwmonrynebew opmi http://cbs4.comAtearn/Scott.Rothstein.Mafia.2.1563707.html 5/11/2010 EFTA00622938 1-Team: Rothstein Helps Take Down Alleged Mafia Player - cbs4.com Page 3 of 3 YourContimenti Post CenMeil 10210WOCSNI torterp la *Wilmer* Ms diansalere in No plebs' Ckiz Mt keno lo robots vet Mw ISO Show Comments (2) http://cbs4.com/iteam/Scott.Rothstein.Mafia.2.1563707.html 5/11/2010 EFTA00622939 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50 2009CA040800XXXXMB AG JEFFREY EPSTEIN r O7 3 F Plaintiff, M ° -rt n. v. r n n' rn SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, _ig :c individually, and L.M., individually, m -na3 r- Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO ROTHSTEIN'S MOTION TO SET ASIDE DEFAULT Plaintiff, JEFFREY EPSTEIN, submits his response in opposition to Defendant, SCOTT ROTHSTEIN'S ("Rothstein") Motion to Set Aside Default, and states: Background and Procedural Posture 1. Epstein filed the instant action against Rothstein and others on December 9, 2009. 2. Rothstein was the former Chairman and CEO of the now defunct law firm, Rothstein, Rosenfeldt & Adler, P.A. ("RRA"). Rothstein was a licensed, bona fide litigator, not a lay person unfamiliar with lawsuits and legal process. 3. Rothstein was indicted and pled guilty to five counts including racketeering, money laundering and fraud related to a massive Ponzi scheme he conducted through RRA. His sentencing is scheduled for June 9, 2010. 4. On December 09, 2009, Rothstein was personally served with the summons and Complaint in this action. See Verified Return of Service attached as IEWilbit A and Affidavit of Carlos Aguirre, process server, attached as Exhibit B. EFTA00622940 5. As set forth in Mr. Aguirre's affidavit, Rothstein was in a hallway, out of his cell, with other prisoners, when a guard called his name and he came forward. See Exhibit B 115. Mr. Aguirre then -personally placed the Complaint and Amended Summons in Mr. Rothstein's hands and advised him that he was being served with a lawsuit. Mr. Rothstein turned and walked away with the papers l served him." kJ, 8. On December 31, 2009, Epstein filed a Motion for Default due to Rothstein's failure to respond to the Complaint. 7. A default (attached as Exhibit C) was entered by the Clerk on January 21, 2010. 8. Over two months after being served with the Complaint, Rothstein filed a Motion to Set Aside Default on February 17, 2010. 9. Several weeks later and on the eve of the hearing on the Motion to Set Aside Default, Rothstein filed an affidavit on March 8, 2010 in support of his Motion to Sot Aside Default (attached as Exhibit D). 10. The next day, March 9, 2010, a hearing was conducted on Rothstein's Motion to Set Aside Default and the Court deferred ruling so the parties could conduct discovery related to the motion (3/9/10 Order attached as Exhibit E). 11. On April 15, 2010, Epstein filed a Motion to Strike Affidavit of Scott Rothstein because Epstein was unable to depose Rothstein. 12. On April 23, 2010, the Court denied Epstein's Motion to Strike Affidavit of Scott Rothstein and granted an additional thirty (30) days to depose Rothstein (4/23/10 Order attached as Exhibit F). 13. However, Epstein has been unable to locate, let alone depose, Rothstein. 2 EFTA00622941 14. Indeed, Rothstein's own counsel has had considerable difficulty locating and communicating with his client. In an April 22, 2010 article in the South Florida Business Journal (attached as Exhibit G), it was reported that Rothstein's counsel, Mark Nurik, Esq., was unaware of his client's location 'for substantial periods of time and has only had limited contact with Rothstein. 15. Moreover, Epstein's counsel has made the numerous efforts to locate and depose Rothstein, to no avail: a. Telephone conference with Lisa Kaye, Case Management Coordinator/Legal Liaison at the Federal Detention Center in Miami — was advised they do not have custody of Rothstein, have no information on his whereabouts and could not assist in coordinating his deposition; b. Telephone conference with U.S. Marshal's office — was advised they are not responsible for coordinating depositions and would not give provide any information regarding Rothstein. c. Telephone conference Bureau of Prisons Inmate Locator in Washington D.C. — was advised they have no record of Scott Rothstein; d. Telephone conference with Port St. Lucie Jail — was advised they had custody of Rothstein for brief period, but had no information on his whereabouts; e. Two voicemalls for Bureau of Prisons — never returned a call; f. Two letters and two voicemails for United States Attorney Paul Schwartz — never returned a call or responded to letters; and g. Voicemail for United States Attorney Jeff Kaplan — never returned call. Legal Standard — Setting Aside Default 16. It is axiomatic that a party moving to set aside a default must establish (1) due diligence in moving to set aside the default; (2) excusable neglect in failing to respond to the complaint; and (3) a meritorious defense to the allegations of the 3 EFTA00622942 complaint. See Hill v. Murphy, 872 So. 2d 919, 921 (Fla. 2d DCA 2003). 17. The party seeking to set aside the default bears the burden of demonstrating excusable neglect, a meritorious defense and due diligence. See Zivitz v. Zivitz 16 So. 3d 841,849 (Fla. 2d DCA 2009) 18. The standard of review for an order denying a motion to vacate a default is whether the trial court abused its discretion. See Szucs v. Qualico Development. Inc., 893 So. 2d 708, 710 (Fla. 2d DCA 2005). Rothstein's Affidavit Does Nothing to Establish a Meritorious Defense 19. Courts have repeatedly held that to establish a meritorious defense, the defendant must tender either a defensive pleading showing the defense or a sworn motion or affidavit stating the facts supporting the meritorious defense. Sep Hill v. Murphy, 872 So. 2d 919, 921 (Fla. 2d DCA 2003). 20. In it the defendant filed an affidavit in support of a motion to set aside a default in which he asserted that he did not enter into an agreement with plaintiffs. See hill 872 So. 2d at 921. The court found that a[w]hile this assertion does constitute a factual allegation in an affidavit, it does not establish a meritorious defense" because the causes of action against the defendant (negligent supervision, civil conspiracy and FI`UTPA) "[do not] depend on the existence of a contract between [the parties]." Id The court went on to note that "[a] factual allegation that does not meet the substance of the allegations against the affiant does and cannot state a 'meritorious' defense." it (Emphasis added). Accordingly, the court concluded that the trial court did not abuse its discretion in refusing to set aside the clerk's default. Id. 21. Rothstein did not tender a defensive pleading and his affidavit is a far cry 4 EFTA00622943 from establishing a meritorious defense. While he claims to have "many meritorious defenses to the Complaint: he only purports to describe one, which constitutes neither a factual nor legal defense to any of the counts in the Complaint. 22. The crux of Rothstein's purported defense is that co-Defendant, Bradley Edwards (a former RRA attorney), filed lawsuits against Epstein on behalf of his clients prior to joining RRA and that these "were and are real cases, with real plaintiffs that have real claims against Epstein." See Exhibit D ¶9. Then, without any explanation, Rothstein makes the conclusory assertion that these facts "go[j against several counts in the Complaint, including, but not limited to, the RICO count." 23. From his affidavit, it appears that Rothstein has still not read the Complaint. 24. The Complaint, in no uncertain terms, acknowledges that L.M., E.W and Jane Doe are in fact real plaintiffs who have filed real cases. Indeed, the Complaint alleges that Rothstein liaised investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) 'up front' money such that plaintiffs would refuse to settle the Civil Actions." See Complaint ¶31.c. So it is unclear what defense Rothstein is attempting to establish by asserting that L.M., E.W. and Jane Doe are real plaintiffs with real cases, a fact alleged in the Complaint. 25. What is clear Is that Rothstein's affidavit falls woefully short of demonstrating a defense, let alone a meritorious one, that would support setting aside the default and the Court should therefore deny Rothstein's motion. "A factual a;legation that does not meet the substance of the allegations against the affiant does and cannot state a 'meritorious' defense." See Hill, 872 So. 2d at 921. 5 EFTA00622944 Rothstein's Failure to Respond to the Complaint Was Not the Result of Excusable Neglect 26. To set aside a default, Rothstein must also demonstrate excusable neglect in falling to respond to the complaint. See Hill 872 So. 2d at 921. Rothstein's affidavit does not controvert the fact he was personally served and demonstrates that he essentially ignored this lawsuit. Such indifference to legal process is inexcusable. 27. In Medcom USA, Inc. v, Ryder Homes & Groves, Co., 847 So. 2d 594, 596 (Fla. 2d DCA 2003), defendant moved to set aside a clerk's default and filed affidavits of its president, vice president and chief counsel, which asserted that defendant "had not been served with process; that [defendant's] first knowledge of the suit was the receipt of the final judgment ... and that the company had immediately retained counsel to take appropriate steps to respond to the action.' The court affirmed the trial court's refusal to set aside default under these circumstances because the defendant's "bare allegations that [defendant's CEO) had not been served with process are not sufficient as a matter of law to impeach the process server's return of service and sworn statement that she personally served (defendant's CEO)." Id. See elle Marceca v. Southeast Bank, N.A., 521 So. 2d 156, 156 (Fla. 4th DCA 1988) (affirming trial court's denial of motion to set aside default where defendant's counsel intentionally or through gross neglect ignored the necessity to respond to the complaint and summons); The Vanguard Group, Inc. v. Vanguard Security. Inc., 409 So. 2d 1219 (Fla. 3C DCA 1982) (holding trial court properly denied defendant's motion to set aside default where defendant's assertions showed only that defendant ignored the complaint). 6 EFTA00622945 28. Rothstein does not contest the fact that he was properly served with the Complaint and Summons. Instead, he asserts that "I do not recall being served with this lawsuit" and "[i]f I was properly served with this lawsuit, it has been misplaced within the pile of numerous lawsuits and voluminous amount of other legal papers and has not been located." See Exhibit D ¶6. That Rothstein is the target of "numerous lawsuits" as a result of his fraudulent scheme does not excuse his failure to respond to the instant suit. 29. Rothstein also asserts that he "did not have knowledge of [this lawsuit] until February, 2010." See Exhibit D ¶2. However, if Rothstein was personally served with the Complaint and Summons (which he does not contest), it follows that he must have had knowledge of the lawsuit. Since Rothstein's affidavit does nothing to controvert the verified return of service or affidavit of Carlos Aguirre (Exhibits A and 8, respectively), the Court must assume that the Complaint and Summons were properly served. See Medcom USA. Inc., 847 So. 2d at 598 (holding that bare allegations that defendant had not been served with process are not sufficient as a matter of law to impeach the process server's return of service and sworn statement that she personally served defendant). 30. Indeed, Rothstein had to be taken from his cell into a separate room to be served with the lawsuit, a fact he admits in his affidavit. See Exhibit D ¶4. This is a not a situation where, for example, a defendant's counsel's secretary misplaced a complaint and forgot to calendar a response deadline. To the contrary, Rothstein was an attorney (although disbarred) and former CEO of RRA, a law firm which employed over 70 lawyers, and was personally served with this lawsuit. Rothstein's affidavit does nothing 7 EFTA00622946 to establish that his failure to respond to the Complaint was a result of excusable neglect. 31. Rothstein's counsel, Mark Nurik, also asserts that he did not have knowledge of the lawsuit until "recently." See Motion to Set Aside Default ¶6 — 7. 32. However, nine separate news articles (attached as composite Exhibit H) including The Palm Beach Post (12/08/09), The Sun Sentinel (12/10/09), NBC Miami (12/08/09), The ABA Journal (12/09/09), South Florida Lawyers (12/10/09), huffingtonpost.com (12/11/09), The AmLaw Daily (12/08/09). Business Insider (12/10/09) and Courthouse News (12/16/09), reported Epstein's lawsuit against Rothstein. Notably, the articles were published within days of Rothstein being served with this lawsuit (December 9, 2009). Thus, Rothstein's and Nurik's assertions that they had no knowledge of this case until "recently" are belied by the widespread media coverage. 33. Given the foregoing, it can hardly be said that Rothstein ignoring the properly served Complaint and Summons constitutes excusable neglect. 34. Unlike Medcom where the defendant asserted he was not served (and in which the court nevertheless found said assertion insufficient), Rothstein does not even contest the fact he was served; he just does not remember it. How convenient, yet insufficient. 35. As his assertions do not come close to rising to the level of excusable neglect, the Court should deny Rothstein's Motion to Set Aside Default. Rothstein Fails to Establish Due Diligence in Moving to Set Aside the Default 36. Last, Rothstein must establish he acted with due diligence in moving to set 8 EFTA00622947 aside the default. a t Hill, 872 So. 2d at 921. 37. Rothstein, in his affidavit, asserts that he learned of the lawsuit and default at some unspecified time in February, 2010 and then Immediately contacted [his) attorney and advise him of same which prompted the filing of my Motion to Set Aside Default and this Affidavit in Support thereof." See Exhibit D ¶8. 38. However, Rothstein fails to explain how he learned of this lawsuit or exactly when in February, 2010 he learned of It. 39. Rothstein filed his Motion to Set Aside Default on February 17, 2010. If Rothstein learned that a default was entered against him on February 1, 2010, for example, but failed to file anything for over three weeks, it can be argued he failed to exercise due diligence in moving to set aside the default. 40. But since Rothstein does not articulate how or exactly when he learned of the default, it is unclear whether Rothstein acted with due diligence in moving to set aside the default entered against him. 41. Accordingly, Rothstein has failed to meet his burden to establish the due diligence element. See Zivitz 16 So. 3d at 849 (holding that the party seeking to set aside the default has the burden to demonstrate due diligence in seeking relief from default, excusable neglect and a meritorious defense). Conclusion 42. Since Rothstein has failed to establish a meritorious defense to the allegations in the Complaint, excusable neglect in failing to respond to the Complaint and due diligence in moving to set aside the default, the Court must deny Rothstein's Motion to Set Aside Default. EFTA00622948 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this day of May , 2010: Gary M. Farmer, Jr., Esq. Jack Alan Goldberger, Esq. =armar, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, P.A. & Ishrman, PL 250 Australian Avenue South 425 N. Andrews Avenue, Suite 2 Suite 1400 =ort Lauderdale, FL 33301 West Palm Beach FL 33401-5012 Fax: - fax Co-Counsel for Defendant Jeffrey Epstein Attorneys for Defendant, L.M. ack Scarola, Esq. Law Offices of Marc S. Nurik Seamy Denney Scarola Barnhart & Counsel to Scott Rothstein Sh'pley, P.A One East Broward Boulevard, Suite 700 2139 Palm Beach Lakes Blvd. Fort Lauderdale, FL 33301 Beach, FL 33409 F Attorneys for Defendant Bradley Edwards BURMAN, CRITTON, LUT nER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Palm Beach, FL 33401 -ax By: e D. Critton, Jr. +)Ift lorida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 10 EFTA00622949 VERIFIED RETURPINF SERVICE I IN THE 15Th JUDICIAL CIRCUIT IN AND OR PALM BEACH COUNTY FLORIDA TYPE OF WRIT: AMENDED SpMMONS & COMPLAINT . CASE NO: 502009CA040800XXXXM8 AG •- PLAINTIFF DEFENDANT(8) JEFFREY EPSTEIN vs. SCOTT ROTHSTEIN, individually et-el., i. TO: Scott Rothstein. Register 091258-004 do FCC, Miami 1. Federal Detention Center 33 NE 4^ Street Miami, FL. 33132 it PURSUANT TO THE REQUEST OF: ROBERT O. CRITITON, JR., ESO.,WHOSE OFFICE IS LOCATED AT: 303 BANYAN BLVD.. SUITE 400, WEST PALM MACS. FL. 33401 ',CARLOS AGUIRRE C.P.S 0 810 RECEIVED THIS PROCESS ON: 1219/09 0 8:00am AND SERVED THE SAME ON: 12/9/09 0 8:45am IN BADE COUNTY FLORIDA. ( X ) INDIVIDUAL SERVICE: BY SERVING THE PERSN NAMED HEREIN A COPY OF THE AMENDED E SUMMONS COMPLAINT, PETITION OR INITIAL PL ING. COMMENTS: DESCRIPTION OF PERSON SERVED: WHITE MALE, 47 YEARS OLD. ABOUT 6'7 ABOUT 200Ibs., GREY SHORT HAIR. I ACKNOWLEDGE, THAT I AM A CERTIFIED PROCESS SERVER IN THE CIRCUIT IN WHICH THIS PROCESS WAS SERVED AND THAT I HAVE NO IN REST IN THIS MATTER. UNDER PENALTY OF PERJURY, I DECLARE THAT liREAD THE FOREGOING VERIFIED RETURN OF SERVICE AND THE FACTS STATED IN IT ARE TRUE. CARLOS AGUIRRE C.P.S III 810 )1. -ry .1/6 EXHIBITIL EFTA00622950 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA REV PPSTEIN Complex Litigation, Pa. R. Civ. Pro.1201 Plaintiff, CASE NO.502009CA040800XXXXMB AG v. t3CtrT Roil 'STEIN, Individually, ; IRADLEY O. EDWARDS, individually, n/ n Individually, Defendants. / \(): 16 goP 4C AMENDED SUMMONS (Have not attempted to serve — Amended only as to Place of Service) PERSONAL SERVICE ON A NATURAL PERSON TC DEFENDANT(S): Scott Rothstein, Register #91256.004 c/o FDC, Miami Federal Detention Center 33 NE 41h Street Miami, FL 33132 IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this stir:mons !s served on you to file a written response to the attached complaint/petition with the Clerk of this Court. A phone call will not protect you. Your written response, !ncluding the case number given above and the names of the parties, must be filed if you want the Court to hear your side of this case. If you do not file your response on t!me, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attorney right away. if you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book). SHARON R. BOCK Clerk & Comptroller P.O. Box 4667 West Palm Beach, 33402-4667 EFTA00622951 vs. Casa No: If you choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to :is `Plaintiff/Plaintiffs Attorney named below. 10BERT D. CRITTON, JR. 3URMAN, CRITTON, LUTTIER & COLEMAN 303 Banyan Boulevard Suite 400 West Palm Beach, FL 33401 561/842-2820 7HE STATE OF FLORIDA: TC EACH SHERIFF OF THE STATE: YOU ARE COMMANDED to serve this summons and a copy of the complaint/petition In this action the above-named Defendant. DATED ON December 8, 2009 SHARON R. BOCK CLERK OF THE CIRCUIT COURT (SEAL) EQNA SMITH BY: DEPUTY CLERK (See Reverse Side) (Vease al :eves) (Voir de L'autre cote de) EFTA00622952 VS. Case No: IMPORTANTE Usted ha sido demandado legalmente. Tine 20 Dias, contados a partir del recibo de esta notificacior•., para contestar la demanda adjunta, por escrito, y presentada ante este tribunal. Una llamada atelefonica no. lo protegera. Si usted desea que el tribunal cor.s!clere se defensa, dobe presentar su respuesta por escrito, Incluyendo el numero del caso y los nombres de las partes Interesadas. Si usted no contesta la demanda a tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existen ostros requisitos legales. SI lo desea, puede usted consultar a un abogado immedlatamente. Si no conoce a un abogado, puede llamar a una de las oficinas de asistencia legai que aparecen en la gula telefonica. Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal usted enviar por correo o entegar una copla de su respuesta a la persona deominada abajo como "Plaintiff/Plaintiffs Attorney" (Demandante o Abogado del Demandante). 1MPORANT Dos poursuites judiclares ont ete onterprises contre vous. Vous avez 20 jours consecutifs a partir de la date de l'assignation de cette citation pour deposer une reponse ecrite a la plainte ci-jointe aupres de ce tribunal. Un simple coupe de telephone est insuffisant pour vous proteger. Vous etes oblige de deposer votre reponse ecrite, avec mention du numero de dossier ci-dessus et du nom des indios nommees ici, si vous souhaitez que le tribunal entende voutre cause. Si vous ne deposez pas votre reponse ecrite dans le reta'. requis, vouc risquez de perdre la cause alnsi que votre salaire, votre argant, et vos biens peuvent otra salsis par la suite, sans aucun preavis ulterieur du tdbunal. II y a d'autres obligations juridiques et vous pouvez requerir les services irnnediats d'un avocat. SI vous no connaissez pas d'avocat, vous pourriez telephoner a ur service de reerence d'avocats ou a un bureau d'assistanco juridique (figurant a l'annuaíre de telephones). Si vous choisissez de deposer vous-mame une response ecrite, II vous faudra egalement, en memo temps que cette formalite, faite parvenir ou expedier une copie de votre reponse ecrite au uPlaintiff/Plaintiffs Attorney" (Plaignant ou a son avocat) nomme d-dessous. EFTA00622953 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND Case No. 50 2009CA040800XXXXMB AG JEFFREY EPSTEIN Plaintiff, AFFIDAVIT OF CARLOS AGUIRRE STATE OF FLORIDA ) MIAMI-DADE COUNTY ) BEFORE ME, the undersigned authority personally appeared having personal knowledge and being duly sworn, deposes and says: 1. I, Carlos Aguirre, am certified by the State of Florida to serve legal process, C.P.S. 0810. 2. I was hired by the law firm of Burman. Crittor., Luther & Coleman to serve process in this matter on the Defendant, Scott Rothstein. 3. On December 8, 2009, I contacted the Federal Bureau of Prisons via facsimile requesting to serve process on Scott Rothstein. 4. On December 9, 2009, I arrived at the Federal Detention Center in Miami, Florida and personally served Scott Rothstein with the Complaint and Amended Summons at approximately 8:45 a.m. 5. Mr. Rothstein was in a hallway, out of his cell, with other prisoners. A EXHIBIT B EFTA00622954 guard called Mr. Rothstein's name and he came forward. I personally placed the Complaint and Amended Summons in Mr. Rothstein's hands and advised him that he was being served with a lawsuit. Mr. Rothstein then turned and walked away with the papers I served him. FURTHER THE AFFIANT SAYETH NAUGHT. Carlos Aguirre STATE OF FLORIDA MAMI-DADE COUNTY I hereby Certify that on this day, before me, an officer duly authorized to administer oaths and take acknowledgments, personally appeared Carlos Aguirre krown to me to be the person described in and who executed the foregoing Affidavit, who acknowledged before me that he/she executed the same, that I relied upon the following form(s) of identification of the above named person: [ s/J' nd that an oath was/wee-fel taken. WITNESS my hand and official seal in the County and State last aforesaid this gj~j i dav of , 2010. PR1N (SEAL) NOTAI&Y PUBLIC/STATE OF FLORIDA COMMISSION NO.: e °04.7: Notary Pubic Slate of Butte Jason Roberts iry lay Conmission DC10193419 2 -loge Expbes Dint/2014 EFTA00622955 F IN THE .C.`1.11T COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case Number: 502009CA040800XXXXMB Division: AG its REY EPSTEIN Plaintill(s), SCOTT ROTHSTEIN, individually, BRADLEY S. EDWARDS individually and L.M. individually Defendant(s), DEFAULT A default is entered in the above styled cause against: SCOTT RO'FIIS'TEIN, Individually for failure to serve a pleading at the time required by law. DONE AND ORDERED at the Clerk's Office, City of West Palm Beach, this 21 day of JANUARY, 2010. Sharon R. Bock Clerk & Comptroller By: KIMBERLY BRADLEY Deputy Clerk Copies furnished to: BURMAN, CRITTON, LOTT=& COLEMAN LLP 303 BANYAN BLVD., STE 400, WEST PALM BEACH, FL 33401.4349 SCOTT ROTHSTEIN, INDIVIDUALLY C/O FDC, MIAMI FEDERAL DETENTION CENTER, 33 NB 4Th STREET, MIAMI,FL 33132 GARY FARMER , BSQ , 425 N. ANDREWS AVENUE, SUITE 2, FT. LAUDERDALE, FL 33301 JOHN SCAROLA , ESQ , 2139 PALM BEACH LAKES BLVD WEST PALM BEACH, FL 33409 PADULA & GRANT, PLLC 365 B. PALMETTO PARK ROAD, BOCA RATON, FL 33432-S013 7:1)(H933rr C.{ EFTA00622956 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 2009 CA 040800 XXXXMB HONORABLE JUDGE DAVID F. CROW JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, BRADLEY J. EDWARDS, and LM, Defendants. AFFIDAVIT OF SCOTT W. ROTHSTEIN IN SUPPORT OF MOTION TO SET ASIDE DEFAULT STATE OF FLORIDA ) ss.: COUNTY OF Before me, the undersigned authority, personally appeared, SCOTT W. ROTHSTEIN, who after being by me first duly sworn, on oath, deposes and states as follows: 1. I am a Defendant in the above•captioned matter. 2. I did not respond to the Summons and Complaint in this lawsuit because I did not have knowledge of its existence until February, 2010. In February 2010, I learned that this lawsuit was filed against me and that a default judgment had been entered against me for failure to respond. 3. From December 1, 2009 until March I, 2010, I was detained at the Federal Detention Center in Miami, Florida'. On March I, 2010,1 was transferred to the Pon St. Lucie jail. Flt1661522:1 EXHIBIT. D EFTA00622957 4. During that time frame I was pulled out of my cell many times by the Bureau of Prisons staff to receive service of lawsuits at all hours. 5. Inasmuch as the Bureau of Prisons rules and regulations do not allow a prisoner to hand any documents to any visitors, including counsel, upon service of various lawsuits, I simply informed my attorney who would then look up the case with the appropriate court and contact the attorney for the plaintifffs) in such cases and/or take whatever appropriate action was necessary. 6. To the best of my knowledge and belief, I do not recall being served with this lawsuit. If I was properly served with this lawsuit, it has been misplaced within the pile of numerous lawsuits and voluminous amount of other legal papers and has not been located. Even to date, I have not located the Complaint or Plaintiffs Motion for Default.2 7. 1 state in good faith that if I had actual knowledge of this lawsuit I would have advised my attorney as I have done with various other lawsuits currently pending against me. 8. As soon as I learned of the lawsuit, I immediately contacted my attorney and advised him of same which prompted the filing of my Motion to Set Aside Default and this Affidavit in Support thereof. 9. I have a viable defense to the allegations contained in the Plaintiff, Jeffrey Epstein's ("Plaintiff" or "Epstein"), Complaint. Without providing a detailed response to the Complaint herein, just one of many meritorious defenses to the Complaint is that at least one, if not more, of the lawsuits against Plaintiff which he references as the basis of this instant lawsuit (the "Civil Actions"), was filed with the court on behalf of certain clients by a defendant herein, Bradley Edwards ("Edwards"),prior to his employment as an attorney at the law firm Rothstein Rosenfeldt Adler ("RRA"). The fact that Edwards, prior to his employment with RRA, and prior 2 Since learning of this lawsuit, my attorney obtained a copy of the Complaint 2 EFTA00622958 to our introductions with one another, already had client(s) suing Epstein in Civil Actions, goes against several counts in the Complaint, including, but not limited to, the RICO count. In fact, the Civil Actions filed by Edwards and/or other attorneys at RRA were and are real cases, with real plaintiffs that have real claims against Epstein and, this instant lawsuit is Plaintiff's feeble attempt to take advantage of my unfortunate circumstances to disqualify claims by real persons that deserve to have their day in court. 10. I respectfully submit that if the Court were to disallow my Motion to Set Aside Default, not only would I be extremely prejudiced inasmuch as I have viable defenses to the allegations contained in Plaintiffs Complaint, but the plaintiffs in the Civil Actions that Edwards and others at RRA filed against Epstein which he references in his Complaint in this matter, would be prejudiced as well. A default entered against me in this matter would have the same effect as my admission to the assertions made by Plaintiff which would, in essence, allow Epstein to prevail against the plaintiffs in the Civil Actions on the basis that they are frivolous and fraudulent lawsuits, which they arc not. Under penalties of perjury, I declare that I have read the foregoing affidavit and the facts stated in it are true. voranamm• 3 EFTA00622959 STATE OF FLORIDA Y r k).3c14. C-tmrs.1.0 )ss.: BEFORE ME the undersigned authority, personally appeared SCOTT W. ROTHSTEIN, who after being by me first duly sworn on oath deposes and says that he is the Defendant in the above-styled cause; that he has read the foregoing Affidavit and the facts contained herein are true and correct. SWORN TO AND SUBSCRIBED before me this VS day of t nerdn 2010, by SCOTT W. ROTHSTEIN, who is personally known to me or who has produced Cix,,, as identification. fRtt.iO TARY PUBLIC Typed or Printed Nand; Notary Public My commission expires: NOTARY KM/Pa P PIAtnDA eTiAjt & MUM O tt ISEIM2013 RONDO MO ATIAVI IC KetIMGCO, see 4 EFTA00622960 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JE TREY :iPSTEIN Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT RO'UISTEIN, Individually, BRADLEY J. EDWARDS, dIvIdually, and L.M., Individually, Defendants.. ORDER ON DEFENDANT SCOTT ROTHSTEIN'S MOTION TO SET ASIDE DEFAULT THIS CAUSE came before tho,Court on Defendant Scott Rothstein's Motion to Set Aside Default, and the Court having heard argument of counsel and being fully advised in these premises, It is hereby ORDERED and ADJUDGED that said Defendant's Motion is hereby .grantedt _denied-- ,lert.(c4- I 6'/ 009.? cc. kit nsrt • 9/ P. / 1MY Ove-t) /et 4.e,(61 ///1077 cM DONE AND ORDERED at Palm Beach County-C rthouse, ost P=Im Beach, Florida, this • day of /4112iall-• • , 2010 i David F. Crow Circuit Judge iNT E Copied furnished to: ROBERT D. CRITTON, JR., ESQ., Burman, Dillon, Luther & Coleman, 303 Banyan Boulevard, Suite 400, West Palm Beach, FL 33401, MARC S. NURIK, ESQ., Law Offices of Mark S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301, GARY M. FARMER, JR., ESQ., Farmer, Jaffe, Welssing, Edwards, Fistos & Lehrman, PL. 425 N. Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301, JACK SCAROLA, ESQ., Searcy Denney Scarola Barnhart & Shipley. PA. 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409, and JACK ALAN GOLDBERGER, ESQ., Atterbury Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401.5012 EFTA00622961 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA .; iPSTEIN Complex Litigation, Fla. R. Clv. Pro.1201 Plaintiff, Case No. 60 2009CA040800XXXXMB AG V SCOTT ROTHSTEN, individually, AAOLEY J. EDWARDS, !ne!vidualiy, and L.M., individually, Defendants. • I ORDER ON MOTION TO STRIKE AFFIDAVIT OF SCOTT ROTHSTEIN THIS CAUSE came before the Court on Motion to Strike Affidavit of Scott Rothstein, and the Court having heard argument of counsel and being fully advised in these premises, it is hereby ORDERED and ADJUDGED that said Motion is hereby ih b-itezAer., Attrn wri / -42., 5 0 do-e3,...s -7‘.) 4,4 A-f-fr -76 O67‘,,-; eitziortfrey es, 4 It- .1 :erth DONE AND ORDERED at Palm Beach C fir Courtho se, esLealm-Beach, Florida, this faelay of ara 20 CUL David F. Crow Circuit Judge ft "*.larn .....ikfludJ I Copied furnished to: ROBERT D. CRITTON, JR., ESQ., Burman, Critton, Luster & Coleman, 303 Banyan Boulevard, Suite 400, West Palm Beach, FL 33401, MARC S. NURIK, ESQ., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301. GARY M. FARMER. JR., ESQ., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL. 425 N. Andrews Avenue. Suite 2, Fort Lauderdale, FL 33301, JACK SCAROLA, ESQ., Searcy Donney Smola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409, and JACK ALAN GOLDBERGER, ESQ., Allerbury Goldberger & Weiss, PA., 250 Australian Avenue South, Suite 1400, West Palm Beach. FL 33401.5012 I. EFTA00622962 South Florida Business Journal: Rothstein sentencing moved to June 9 Page I of 2 ihmobwrit WI01Doi iheyxn., gl om Mtn. ****n-Kit tort Answer: .Set advice., .1 . retain Pal CONTOff Camel ntapoln.nines% Pilaf IMES fl P I" 5; 4 mibla' eet Ilorlda lin I Ig••• I Yaws I at Ration. BUSINESS JOURNAL anwaPetaniCnir: South node Keywords roue Ma Watt MINOR) SALLS uXTG Rent MUSE DENTS , DIRECTORY CROWS Titartl WORE TOPICS I! aniness ann vet Waren OW* Math ibmilakris a..kallYN Ilusaurbil •4 Ind NOM anauseak r.lear kalithat tailleFirti • Va Mann Wwwe rewleJwall SWAP MORE Sow Rea stela Pain, Up Blog: Scott Rothstein: Picking IS Pinar up the Pieces _1= ewe kg lakIntes na.aannew Paul Brink Rothstein Sentencing Moved Raped.' maw To June 9 Coss% P • Fnalnat NV' 12 MN sttem RUT 1 Moved Thriday.froll72 20i0. 1.40pm Pen e-ai mare.* moo commis IbOCCEROPOSItt. " 0 14,, ,AUMIA:ttl A Nage has moved PON/ Sthellter SOMRethateln'S Stiltentlil beck mole than • nsorith. :1;41 1.011.;••€7 op inaftao,lov,, • Oust is not nemssaely so twining, tut the reasons sewn pretty watt Thews • meson flan Rothstein's attorney, Marc Nan. hers unlike Inlyaing Inn soon In a ten case recentry. I, ITC l'illl;ii .11•11181.1.A.M y1•11:, • • e‘ :IAN:FS+-of iy.f4(.. Moak clans that ItOttateln's cooperation with loyal &Lifeline, by 0 magi t c.stry li f %tr e `n providing evidlniaa lot alleged walla slangs has Interfered with iturik's :121 -Y • eliaty to thmawnkete with Mn. rayirSiebuilnemoon SWOPEN' Recording to federal authorities and numerous media rigor% itOttritthi helped eel up Oa Employees of fns Star f mortars Protection IL Scott Rothstein: Picking up the lavestigatke, a local security Rem that had On to the maw, and Roberto Pieces Archive Settincn. an ahead Sicilian man. Mclennan In Swath Florida. Al throe etatalitili Rufttiftlelel were hit with federal indictments arty Rothstein *leveed, asked them to Mean aal0(11) primarob ea wonder money end destroy evWenat of his Pont; scheme. lin a* -a'-222112) iltssolist2S41121) this comes after the first sealed document was thed In Rotinteirts mkrinel case, which is a nivel that might moan the lids are leconvninOlnq a lighter sentence because of cooperation. EtitatliShaLtfinblabl Ninth MIAthalsbLgthMthal to anent, • smelmscrem of reimewhon so that the pal* and • galabf.seathattectiaL•ed arta% alleged criminals wculd tl'ata that Rothlten was flatatim federal paisthcbas bekre g_tm• tan i nsauadm um .... P. mu evicted. • inifisznIdthethatill • any Demur how Into FATAIP Hues the reevaM text of Nurilfs request for a Wet untenclip date: •a ro •tenclo.a.; ▪ P ilaffal r ad, • Ow iteuritinalith2 maga •SeeCtcallYr the defendant is presently in pieta-WO lousing Outside of this district and treated aftrenlly than other Imsates. Undersigned es:winters contacts with Ms cant wrest be • gitea.SWSatelf arranged and approved in advance through the gOverimoM, which creates delay. 'there have teen inalleten *Xenia'''. In the past ren Milan when undersigned counsel has been unaware el his client's Ithatim and has been repeatedly out ea OMNI With Ni clent substanthil needs of that. Incluang one peeled for over two meas. 'Given these IngtatUns, In the past five rade, counsel has only been able to meet with his client on two occasions. Cuireatiy, there is no Sly to mind the dtrendet, had phone contact is very kilted. Even the sending and receipt of legal mall Daft kinder than the nom * DISABILVIIP MAO it A 4 r o° Rothstein was to be senteraed May 6. The new date Heine 9, at 9:30 ast fillwammiLtiaLimous reg•Cr Saw ;wit," • As.a.L.,”1 1.1?: )3i? r. GET THE *ACTS P Ni lEttubal. CYYALIRhto ---- FOR FLORIDA 4 Pinny., Pig • OSTIM1ENED WeSICCHYPtirt0 re • Innen *peal aI•eon a wan kol3w Ada smarm* e corvine • hiacit.te lJ Anl s grigy NowestRnt • isa,tgagamanss fv -12thastio tarsi - 15wnitt or RS5 • thrbillaiWthiLlecthetaillimitzl • saeanaaslestato • fLgarainutornathalasethatt tiCsriZilenannalfa CV, f fi fir r ia tarn .; ;J. If http://southflorida.bizjournals.com/southflorida/blog/picking_up_the_pieces/2010/04/roths... 4/23/2010 EFTA00622963 South Florida Business Journal: Rothstein sentencing moved to June 9 Page 2 of 2 la Aracs, motto 1- w.lat'ASykeis moiSatat." l, SMALIVOLITION. Slat Icon %Os .0.1C *aut.: now .04ISTOCilleenOVII I=1". a u aoasaN.N HItosa.as >.ashaa ez US V Aatiirel el elf4 MAIL MOILISSI I leo, bAaalIlan imMMMlYN411b I ILICI11 Wad Witt I I /Wan I CL6l.W1fL naa; Ma* linty tgacw agagralst pA 4M It•IHrohlacedsbireqtkai 'rot motto I (MOW 11'44 • WHIMS fr eth21Ithia, float! P AlallasitaILThillI Myra Ntral I hanklifillikra I ISZTA10 id* Vt Idta 40441IJ Apt.ISMS fl male co atm • .'na waaa•gai. asavad Mr a•ta. caM.3 te• oars.' am. 114141'1 abanvaaresam a aaheal. hup://southflorida.bizjournals.com/southflorida/blog/picking_upiho_pieccs/2010/04/roths... 4/23/2010 EFTA00622964 Rothstein, Epstein scandals converge with sex offender claiming he was used in swindle Page 1 of 2 ' i he Palm Beach Post Pau Ibis page Close Rothstein, Epstein scandals converge with sex offender claiming he was used in swindle By JANE MUSGRAVE Palm Beach Post Staff Writer Updated: 7:51 p.m. Tuesday, Dec. 8, 2009 Posted: 917 p.m. Monday, Dec. 7, 2009 Two of the biggest scandals to rock South Florida in recent years merged today when attorneys representing billionaire sex offender Jeffrey Epstein filed a lawsuit claiming the part-time Palm Beach resident is the victim of accused swindler Scott Rothstein. Rothstein, who is accused of running a $1.2 billion Ponzi scheme from his Fort Lauderdale-based law firm, trumped up civil lawsuits against Epstein, according to the complaint filed in Palm Beach County Circuit Court. He then lured investors by telling them Epstein had agreed to settle the lawsuits for as much as $200 million and they could get a cut of the cash. The problem for investors, according to the lawsuit filed by West Palm Beach attorney Robert Critton, is that Epstein never agreed to settle the lawsuits filed on behalf of women who are identified only by pseudonyms, such as Jane Doe. "The offer of a $200 million settlement by Epstein was completely fabricated," Griffon wrote. "No such offer had ever been made.' Epstein faces roughly two dozens lawsuits filed by women who claim they were teenagers when he lured them to his Palm Beach mansion and paid them for massages and sex. The lawsuits started rolling In after he pleaded guilty In 2008 to felony solicitation of prostitution and procuring teenagers for prostitution. He was released from jail in July after serving 13 months of an 18-month sentence. Attorneys who worked for Rothstein, induding Bradley Edwards and former Palm Beach County Circuit Judge William Berger, handled the three lawsuits the firm filed. But, they said, those represent only a fraction of the young women who Epstein molested. Wet the evidence is really going to show is that Mr. Epstein .. . has every single day of his life made an attempt to sexually abuse children," Edwards said at a July court hearing. 'We're not talking about five, we're not talking about 20, we're not talking about 100. we're not talking about 400 . . . we're talking about thousands of children." Such talk was part of a carefully orchestrated scheme to convince investors they stood to make millions by investing with Rothstein, Critton said. Likewise, Critton said, Edwards has said he intends to depose various luminaries to testify against Epstein. Former president Bill Clinton, business mogul Donald Trump, former Sony Record president Tommy Mottola and magician David Copperfreld have all been Identified in court papers as people that will be deposed. While friends or acquaintances of Epstein, they have no information about the women involved In the lawsuits, Clifton said. "The sole purpose in the scheduling of these depositions or listing high profile friends/acquaintances as 046,f>4k„, potential witnesses was, again, to 'pump' the cases to investors," Critton wrote. r• • ttX:Itrarl http:/Avww.palmbeachpost.com/newskrimc/rothstein-epstein-scandals-converge-with-sex-... 3/29/2010 EFTA00622965 Rothstein, Epstein scandals converge with sex offender claiming he was used in swindle Page 2 of 2 Neither Edwards or Borger responded to phone calls for comment. Clifton Isn't the first to make allegations that Rothstein fabricated cases as a way to lure Investors. Fort Lauderdale attorney William Scherer, who has filed a $100 million lawsuit against Rothstein on behalf of scores of investors, has made similar claims. In a 147-page lawsuit, Scherer also said Rothstein told an investor about the phony $200 million settlement offer from Epstein. "He would use . . . cases as bait for luring investors into fictional cases," Scherer was quoted as saying. "All of the cases he allegedly structured were fictional. I don't believe there was a real one." Rothstein, a potent political fund-raiser who turned a small, unknown law firm into a powerhouse in seven short years, has pleaded not guilty to charges of RICO conspiracy, money-laundering conspiracy, mail fraud and two counts of wire fraud. His kingdom collapsed in late October when the feds raided his firm, Rothstein, Rosenfeldt & Adler. It Is now closed. He has been disbarred. Find this article at: hltp://ww.g.polntheachpost.cominewsktime/rothatein•epsieln•scondals-converge•wIth•sex•offender•ctaiming.100327.html Print Ibis page Close •• r: .,Flecluost Info Now, , Autittor'sf Brytec ONLINE in as little as 15 Months' A,Coloratto Study days. nights, or weekends, Whenever and wherever you choose. "\\ N5 t --.... . — http://www.palmbeachpost.coinhicwskrime/rothstein-cpstein-scandals-converge-with-scx-... 3/29/2010 EFTA00622966 Epstein Claims Rothstein Link In Lawsuits - Sun Sentinel Page of 2 y veritori Y,. raen re > C.wwre0v> Lbnuit my by 15300. Epstein Claims Rothstein Link In Lawsuits new e Lower • Fret indyk. Alva LaWY*, In ~wear MOM I INReeMetemv• see Pate thaw eon Variance Sayer Term • Oat* Tour Cs»Howl Same the scclim ...?..tbagnut~ tea the Mall trick hi the book when it Chinn to dodging agatOns Of WWI abule.*Werdolg »allemey$ yawls tolen lowedlis reprnendng more than a dozen wornen who two 94M) Pan Beach tht4Obah Jew Epstein, claiming no pad them Head Week tea. wean ref nude massages and sax %Wm they were a9 young aS 14. injury, ocher ~fill Norio. Free CORSI Epstein filed suit Monday In PantBeach County Crewe Cowl, saying Poor scheme suspect SC0ll RoMslein humped sin Vaancy.fy 101 up /acres against Nm as pad of a bitted moneymaking planOut wade ablbd Mt* Fort Laudeidale attorney, eta ratting more than an Wert to tatnish Me women, teak &borne» weld Tuesday. BtfieCciatoenere Herotine Helaine iniatad Vices. For Mg by 000g» Adat01.1.001 25 yre. Gel a Free Lent Consultedon Neal n.nin erne...weeny o I rip e?.a Vat Belly bloom of tRafigenoet Denture Cream Lawsuit Find Out II Yo Have re Ca. No Lapel Fees Side Effects After Denture Cream Cut dawn. 3 lbes tiniest You SuCCCIA IN »cam rt.ry Cron pen Use? Get Help Now. Free Case ohattr belly, SeLl Review etsten,` week s: Free Case Evaluelloh Feel dworiss abOyl y CUI by-using, tfik, case Serrtng F:cride ins 1970 » gre•Mb1030 weird tip. . raNDS-0nE STORESM30UT 'We l*e a SlAPP add attorney Sd Garda, who is mortise,»no a women who says We was 17 when she was • larrtfie melesrtd by We 66.yeabold lifilibb4. Epstein pleaded eadlY le EON to San of flictSMeirto and prowing teenagers for proSteulien and sewed 13 roeas CI an IllfiroSolh samemte. • PON•Sebebl An acronym lor 'Wale& lawsul againel debit) part(ipalon: SLAPPs ale most canmerwused by developers le ilene trela by *owing them weh the prospect of huge legal bals. FEATur/E0ARTICLES its mealy not cRecCed al Relhabin: Garcia aid of Ms lawsuit. Tals an allemid10 make his viC6w4 loess bad by Sae be Vdee yenmom ear aesectellen? Geentio Epar S. re. I 1:0» Anent« ~car teton. boo won a cceeldeneel settlement from Epstein la one woman end is redrawing snouts, Underage ate word ss batenale• n a pending MwSuf. agreed. WA In the lawsiM Med by Wail Palm edam Varney Robed Callen, Epsteincleans Rothstein used me lawsuits le lure Faewaregema:We Fen acted* investors es pad of a 51.2 Wien Pond scheme. Tnyrpefing the chance to him a gulch profit, Remsten falsely byeyb Ikeb. reported that Epstein had agreed to safe the lawsuits la as hunch as 5200 rorfon Ry pare a died:anted tale up trorrt, they coved ~teat Cale in hewn thi sellierrent was paid in he Rofillahl, Worse laer firm collapsed an lederel agents raided It In late October, last week pleaded not gurily to charges Mel he made mittens running soloar &them:441cm 2006 Crillon Negro nereten. wed the la trt attorney Bradley Edwards, wig waited to Nm pumped up haters by telling them May would call such luminaries se byror distant Bill Clan,hotness tycoon Donald Trump and magasn David Copperield to testily against Epstein. The message was that 441Enwaled pay tog le patted NS Celebrity blonde. Ma by bOoft Insurance claim? Not etti what ou deserve? Free consultation with attorneys 12INen http://articles.sun-sentinel.com/2009-12-10/news/0912090393_1_ponzi-scheme-lawsuit-cl... 3/29/2010 EFTA00622967 Epstein Claims Rothstein Link In Lawsuits - Sun Sentinel - Page 2 Page I of I AstnoSser.n4 RENT IT WHILE IT'S STILL A NEW RI LEASE 1:3121/2= -het 0 go . soft )(co: StovSyne-ol.coer. Coleceoni > Laos0' • oy ;:oof.• Epstein Claims Rothstein Link Ai Lawsuits Oo0totoi 10,2009 I By Jos,Moose.. 'IMPS, Own Pon gam id 2) In the tawsue, Craton alto goes altar cne of the three women vko were represented by ROINIIO'n'S rim Calm peens up conhaelleren• a sworn *Wel/wenn Illa woman, ItlyWISIO only as I 1.4 , made lo feu awn compared wen those she made ones the lawma was led. in an WeMew with an PSI aged In 2007, she deSetiled Epstein as *an awesome man' and deadened named as • ponied*. She said nears or Ire GUIs she leak to Epstein ever COMpleiled.'inoy'dOeg me. you trncrar, fortis to go toJetkeys house because they love Jollity. Alloy is a roapee.sful man, she said. Ads oyG000t Inotri THE BLIND SIDF, Slaw.% Sondra Bullock • ....44) ,.., .• Yaz Lawsuit Fxperionted Attorneys Fighting For • 0 i Your Rights. Call Morgan& Morgan. www.ForThaPoople.corn RENT. Ilil: VISAIII4E4., irS STILL A NEWiRJECEASkr .•.:i !m_s ..„ Ina September detwoidon, her storychange& TOYS they were there, they we seared out Oa ben nand; she halt 'eboy OW It any way, and tarns of them walked out and mod, I ga dolt ever do use tone again, Ties Is the wont el® Mal ever happened to me.' oP.IO liege STORIES MOW CIIROn Said n000 of the women who we suing EpiloIn for add0ne wens drugged or coerced. They came to las Palm • tarnot Stash mansion freely. Many came 20, 30 or 40 erns. son* wee atter they Wined IS. Fuller, he salt many either were or lain became prosamies or swans Any psychological problems they had had muned well beton they • Pens Sdiero hooked up well Epstein. Kevin said such CltelS miss the pOIM. FEATURED ARTICLES *TM* case a POW whether or rot a tong ow has the capably to consent to inaPP0Phila s0aual • I 4- See TM %%to Poen heath hoc yeaocei asked an adult lo 00 Gel drunk Ws the add(' responst‘ty lo slop her tm4 lo dine het to Me bar, he said Gamow Jams enbAft. In INse cams, he saki, Fristeln We bed underage guns fox sex *into* le KO weems• g•mcond to en beano. pa boos Yaz Birth Control Lawsuit Fo0lpol Mints sotto eon lici0odol• Legal Bafflement& for Victims Of Birth Control - Free Legal Consult. twos Sat. www.YazAttomey.net Pan I l2 Indo by reerwad I Mate by bass I PreetY Polly I Ten.d sense {Rip:Hariicies.sun-sentinel.com/2009- 12-10/news/0912090393_1_ponzi-scheme-lawsuit-cl... 3/29/2010 EFTA00622968 Pervy Billionaire a Rothstein "Victim" I NBC Miami Page 1 of 2 4 MIAMI ca P RI NT TH IS Powered by alckabilit y Pervy Billionaire a Rothstein "Victim" Billionaire sex offender suing alleged Ponzi schemer ily,AtAN HAMACHER t Melee 1:30 ?hi CM Tot. On e,1007 AP Billionaire sex offender Jeffrey Epstein isn't exactly a sympathetic figure, and Ms alleged weakness for underage prostitutes may have made him a target for accused con man Scott Rothstein. The Palm Beach mogul is accusing the alleged Fort Lauderdale Ponzi schemer of filing trumped-up sexual harassment lawsuits against him to help proliferate his massive $1.2 billion scam, run through his Rothstein Rosenfeldt Adler law firm. In a lawsuit filed today, Epstein alleges Rothstein told investors they'd get their hands on the nearly $200 million in settlements that Epstein had worked out with RRA, according to the Palm Beach Post. Problem is, Epstein hadn't agreed to pay out. "The offer of a $200 million settlement by Epstein was completely fabricated," the suit reads. "No such offer had ever been made." Mtp://www.printthis.clickability.com/ptkpt?action=ept&title=Pervy+Billionaire+a+Rothst... 3/29/2010 EFTA00622969 Pervy Billionaire a Rothstein "Victim" I NBC Miami Page 2 of 2 To make matters worse, Rothstein's lawyers were planning on calling some of Epstein's high profile buddies to testify in the cases, including Bill Clinton, Donald Trump and David Copperfield. "The sole purpose in the scheduling of these depositions or listing high profile friends/acquaintances as potential witnesses was, again, to 'pump' the cases to investors," the lawsuit reads. Rothstein, 47, is currently being held in a Miami federal prison, after he was charged last week with five counts related to his scheme, including fraud and racketeering. Epstein, 56, is a successful financier who pled guilty to procuring teenagers for prostitution in 2008 and did 13 months behind bars. Ant PublisInd: Utc 5, 20091:11 PM EDT Find thta article at: httplhuvivcnbcmlemi.corninevisilocal-beatiPervi-llillionelre•e-Rolhsleln•Victim.76784972.html Check are box to Include the list of links referenced in the article. 0 NEC I 'nitatM,Inc.' All Rightt RtICIVS http://www.mintthis.clickability.com/pt/ept?actiorPept&title=Pervy+Billionaire+a+Rothst... 3/29/2010 EFTA00622970 Billionaire Sex Offender's Racketeering Suit: Rothstein Lawyers Lied About Me - News -... Page 1 of 1 Teri aka Billionaire Sex Offender's Racketeering Suit: Rothstein Lawyers Lied About Me Posted Dec 9, 2009 6:50 PM CDT By Manta Nen Just when it might have seemed that alleged wrongdoing related to the spectacular downfall of Rothstein Rosenfeldt Adler could not become more bizarre, a billionaire convicted sex offender has filed a civil racketeering lawsuit against two onetime partners of the South Florida law firm. Contending that they prejudiced his defense of criminal and civil actions related to his alleged sexual activities with underage teens by lying about the facts in order to "pump' a $1.2 billion Ponzi scheme that made use of the law firm name, Jeffrey Epstein is seeking injunctive relief, unspecified damages in excess of $15,000 and attorney lees. Among other allegations, his Palm Beach Circuit Court suit contends that Scott Rothstein, as well as others at the firm, falsely claimed to investors in the Ponzi scheme that Epstein had offered to make a $200 minion settlement and acted illegally and unethically in civil litigation against him that is still ongoing. A copy of the eon:gain( (POF), which was filed Monday, is provided by the Am Law Daily. In addition to criminal practices and racketeering counts, it asserts claims for abuse of process, fraud and conspiracy to commit fraud. Factually, it alleges that Rothstein and unspecified co-conspirators forged federal court orders and opinions, improperly intercepted conversations and pursued a litigation strategy unrelated to the merits of their clients' cases and their dents' interests in order to further the claimed Ponzi scheme. Rothstein told investors that he represented 52 female clients In Epstein related matters, the suit says, when in fact he had filed only 'weak" cases on behalf of exactly three young women. As detailed in earlier ABAJournal.com posts, Rothstein, who until recently was the RRA firm's managing partner and chief executNe officer, is now jailed in a federal fraud case and the dissolving taw firm is in receivership, facing multiple lawsuits. Rothstein also agreed to give up his Florida law license. Attorney Marc Nurik, a former RRA partner who Is representing Rothstein in the criminal case, was not immediately available for comment, the Am Law Daily states. Epstein's suit was filed by attorney Robert Critton Jr. of Burman Critton Luttier & Coleman in West Palm Beach. Additional coverage: ABAJOYMPLeellne "Billionaire's Secret Sex Case Plea Deal Shows What a Good Defense Can Do* ABAJournejsom "Fifing: Rothstein Made $35M in 2008; Name Partner: I Wasn't Paid $6M- faintheach Post: "Billionaire sex offender says he's a victim of Scott Rothstein" Palm Beach Pest: 'Victims' lawyers say sex offender's lawsuit aimed at scaring female victims' Copyright 2010 American Bar Association. All rights reserved. http://wvAv.abajoumal.conthiews/article/billionaire_sex_offenders_racketeer_suit says rot... 3/29/2010 EFTA00622971 South Florida Lawyers: Parsing the Epstein v. Rothstein Suit Page I of 6 Share Report Abuse Next Slog* Create Slog Sign In ket. I" • .:•,Wri tx5ARS..4.--efr 4f • .£-: -rita A Ong devoted to the lawyers of South Florida; their goings and doings, their peculiarities and reff1O21211ities... all dune with humor, Myr, jealousy, mark,and just a little bit of . . THURSDAY. DECEMBER 10. 2009 C,, mitu No.. -- C.-S I I .-arsing the Epstein v. Rothstein Suit An ADA Journal Top 100 Blowy! Subsoil* To Sit 0 Post: Picarnments— Cil Palm Beach lawyers Robert Critters and Arise( Plise have filed suit on behalf of Palm Beach billionaire Jeffrey Epstein against Rothstein and former MA attorney Bradley J. Edwards in Palm Beach state court. Anonymous Tips You can read the complaint hen. ,outhIllawvenS9 in Art ennis http://southIloridalawyers.blogspot.comf2009/I2/parsing-epstein-v-rothstein-suithtml 3/29/2010 EFTA00622972 South Florida Lawyers: Parsing the Epstein v. Rothstein Suit Page 2 of 6 Much of the suit is a rehash of the POnZI scheme allegations, and how Burnook Rothstein would talk up all the victims his firm represented that were David O. Markus SO FL Bloc reaching settlements with Epstein, except for some reason Epstein Cocaine Princess always had to pay out over time, even though the victims wanted the money right now. Slogs I Read AMAullyilsm In actuality, according to the suit, RRA only represented three victims in pending litigation one in federal court, and two in state court. Abovethetaw The complaint alleges that Epstein has been harmed in his defense of ?laws Review these salts, fo., a number of reasons. froward Slog In particular, the suit really goes after Edwards, alleging that he knew ?reward Bulldog or should have known that Rothstein was using the existing cases for proward Law 84o2 purposes of promoting the Ponzi scheme. The complaint alleges that Carlos Miller the RRA litigation Team served discovery that was unrelated to the three claims they were handling but with the sole purpose Copyrights and Competent of 'pumping' the Fonzi Scheme and Wang new Investors. Courtney Schoenfeld 9BR•s Inside Traci Specifically, the complaint alleges that RRA went after records of Rights aboard Epstein's private Jet where high-prof:le celebrities were Discourse allegedly on board when sexual assaults supposedly took place, and Eve on Miami that the Litigation Team sought the depositions of these celebrities. (LA Politics Glenn Greenwald Edwards allegedly took unnecessary depositions of the pilots, and asked Inflammatory questions allegedly for the purpose of `pumping" Hands On Miami the attractiveness of the Renzi scheme. &hi Law Blot The witnesses allegedly on Edwards' deposition list Included The Donald, Alan Dershowitz, Bill Clinton (of course), Tommy Mottola, and Menage a Law Illusionist David Copper,Saki(?). Allegedly Rothstein would then go on My Law t kense to tell potential investors that Epstein Is settling all these cases in MO's The Corner order to protect his high-profile friends. Qpinlo Judi The complaint goes on to detail other alleged discovery Irregularities, Podia including a deposition of Epstein (In which Russell Adler was in BandonFixelt attendance), where lots of inflammatory questions were allegedly Riptide asked so the video of the deposition could be shown to new Investors. Scotusbloc The complaint also alleges that Edwards went overboard at hearings, gat and wildly overstated the extent of Epstein's alleged crimes again just Shoot The Lawyers to pump the scheme. Further, the complaint alleges that confidential The Cvber Sleuth client files of the three existing RRA cases against Epstein were shown to potential investors to induce them to invest, and that as a result The Daily Pulp the attorney-client privilege has been waived. The Legal Satvricot THR, Eso The claims sound in Florida RICO, fraud, abuse of process etc. What to make of all this? US Law Slogs Wolcott Since the alleged discovery abuses occurred in the context of pending civil suits. Epstein's complaint raises the obvious ouestion why the wonlsrtte http://southfloridalawyers.blogspot.com/2009/12/parsing-epstein-v-rothstein-suit.hunl 3/29/2010 EFTA00622973 South Florida Lawyers: Parsing the Epstein v. Rothstein Suit Page 3 of 6 Blog Archive presiding judge In those cases should not be dealing with the alleged lawyer misconduct? ► 2010 (152) ♦ 2009 (588) Moreover, the allegations against Edwards alt Involve serving allegedly ♦ December (63) outrageous discovery, making outrageous statements in court This is The Year That Was, hearings, or doing outrageous things in pleadings. That places the allegations of the complaint at odds with the traditional protections Tom lemon Talks/Buys Wine. afforded attorneys In the performance of their legal duties. In the NYT 3d DCA Watch Dinq Dort I have no kin whether the allegations against Edwards are Dint Donq meritorious, or perhaps Epstein is trying to leverage the Rothstein 'Loan Me Fifty Dollars. revelations to assist him In defense of his pending suits. Marc Randazza Continues To Rule Our (Cyber) World... Esther way the case Is likely not going very far, and Epstein probe* Kim Kardashlan Sued will have to seek his remedies if any in the pending cases where the Over *COW* Diet" Tweets! alleged discovery misconduct took place. Phish Food The more Interesting jurisprudential question Is what remedy, if any, passim the MA Financials could Investors (as opposed to Epstein) have If they were induced to Pulu Banton Hireamad Oscar invest as a result of the lawyer activities detailed In the complaint? Markus! Herald New Math When you step back, the entire Rothstein saga, with Its many sad and mgrachitsunksaftell pathetic twists, should cause the courts and policymakers to define a bit more clearly the extent to which lawyers should be afforded Judo Martinez Reversed On protection when they practice law •- which in the normal Forum Non Banana Boat circumstance certainty makes sense as opposed to allegedly misusing and abusing the law and a Bar license in order to execute an Merry Christmas Darling Incomprehensibly massive (not to mention illegal) moneymaking 3d DCA Watch Geometric fraud. ggggragt a petalls of the Rothstein Labels: Bradley J. Edward' etichttel,Lfilke Robert D. Critton Jr Audio() Russell S. Adler, Stott Rothstein iYaktOL.5410£1114211/ Christmas Dream 8 corwerts: Thanks Joe! detention center Junkie said... SFL Monday Welcome Winter( Epstein's suit Is a crock KIDDZZZ,leave the lawyers alone LOVE What Happened To Canis '(All gorge December 10. 2009 2:40 PM 511. Friday •• A Piece of the ACM Anonymous said... Don't Be That Guy. Where did SFL find the Robert Critton welt sticker set? Mete ICalikimaka For Cheapskates Only December 10, 2009 3:01 PM When's The Right Time To Anonymous said... Rabe Rule 11 in A Plea& The complaint talks about Judge Berger too. Exclusive Inside Marc Hunks 8rietcasel December 10.2009 4:15 PM Id DCA Watch lager And hup://southfloridalawyers.blogspot.coraf2009/12/parsing-epstein•v-rothstein-suitininl 3/29/2010 EFTA00622974 Jeffrey Epstein Sues Accused Ponzi Schemer Scott Rothstein For Misusing His Name Page 1 of 1 March 29, 2010 This is the print preview: Back to normal view Jeffrey Epstein Sues Accused Ponzi Schemer Scott Rothstein For Misusing His Name First Posted: 12.11.09 11:17 AM j Updated: 12.11.09 12:27 PM It's hard to know who to root for when two disgraced Florida financiers duke it out In court. CityFilo reports that billionaire money manager Jeffrey Epstein, who served 13 months in jail for soliciting a oenage girl for prostitution, Is taking aim at accused Ponzi chemer Scott Rothstein. Earlier this year, state authorities charged Rothstein, a prominent Florida lawyer and powerful political fundraiser, with running a $1.2 billion Ponzl scheme. According the suit, Rothstein and his law firm's partners used Epstein's name to lure investors into his alleged scheme. Essentially, the suit says, Rothstein's firm claimed to have secured a $200 million settlement with Epstein, and used that amount to 'pump'. a fraudulent investment scheme. The suit also argues that Rothstein's firm claimed to represent 52 women who claimed to have been sexually abused by Epstein. In fact, Rothstein's firm only represented three such women in cases the suit describes as "weak." Is Epstein, he of the allegedly egg-shaped penis, just piling on Rothstein's misfortunes? Read the complaint for yourself (hat tip to ABA Journal). Story continuos below rothstoin-complaint-1. hup://www.huffulgtonpost.com/2009/12/11/jeffrey-epstein-sues-accu n_388787.11tml?vie... 3/29/2010 EFTA00622975 Billionaire Slaps Scott Rothstein With Suit Page I of 5 1.w owe was Newswire LAWARIL1 =SORE mm a Le &biotic ARAL:4na sea gIVIIELAW DAILY • allittreak • LarchLYisb seam . a..* Go HQE THE A M LAW DAILY LITIOAMON DAILY BAngra MAGAZINE ADVER1LSR SUBSCRIBE FREE ArcFM THE AM LAW DAILY • nitEinn.1 . The Wock • TheSsete • lbtiaban • The Tilt% • The AUIRLIIMOI e The Weds' • Thal iti SURVEYS AND RANKINGS Ahtf nvi AMIMIS1 AM LAW TECH A.UST FLORAL 100 CORPORATE SCORECARD DEALMAKF.RS OF 311S YEAR MIDLEVEL ASSOCIATES SURVEY RUMMER ASSOCJATE.S SURVEY rao BONG SCORECARD LMGAT1ON DEPARTMENT Of 111F. yme, LATERALS REPORT Lifetime Achiever., Intelliemet MAGAZINE • fluent life • prermes • $earch Archive http://a.-nlawdaily.typepad.conVamlawdaily/2009/12/rothsteinsuit.httnl 12/9/2009 EFTA00622976 Billionaire Slaps Scott Rothstein With Suit Page 2 of 5 JAW FIRM INC ',Wootton 2008 FOCUS EUROPE STUDENT EDITION VIDEOS gall of Fame INCISIVE MEDIA EVENTS SUBSCRIBE ADVERTISE ABOUT US FEATURED SPONSORS • Martindale .10141.19£119I • Counsel Financal Sconce* • pips Inc • ltilmY La NETWORK Sites Jobe Yastista Lataralea s= tit Orgine CIL LicyaLloWlizsost Urals Resources Law Firm Paws C.Ould.84PABICS I nal Dictionary The Work December g. 20097:$0 PM Billionaire Slaps Scott Rothstein With Salt Posted by Brian Baxta the almost daily developments in the bizarre saga of disbarred Fort Lauderdale lawyer Scott Rothstein seem almost too oudamfish to bo hue. Herds the latest. On Monday. sibling publication the Pally Business Renew ;emoted that the fedtal government will have first dips on Rothstein's seised properly if hell convicted, noting that the Raid allegations against Rothstein have hit the $1.6 billion mark. Now, another notorious Floridian has entered the picture. Billionaire money manager and convicted sa offender Jeffrey Epstein has filed suit against Rothstein. claiming that thedisbarred lawyer towed a fictitious $200 million sexual harassment settlement that Epstein was witting to pay as a guise to Imo investors Into his Pouf scheme. Epstein. represented by Retell Clieen, le, of West Pales Beech's Jim asan Rttoat ldMitt & relegate hied his civil suit in Palm Beach County Circuit Coon has Monday. h0p;//ernlawdaily.typepad.com/amlawdaily/2009/12/rothsteinsuit.html 12/9/2009 EFTA00622977 Billionaire Slaps Scott Rothstein With Suit Page 3 of 5 According to the ?Soon comet *kg Epstein Sans Rothstein of 'engaging Ina orient ofreckeleoing that bathed a staggering series of gravely serious obstructions ofjustice, alienable (nude, sot. . . egregious civil litigation abases' that damaged Epstein and others. The complaint also accuses Rothstein of forging federal court orders and opinions. Man inlcnritw with The Am Law Daily, Critton lashed out at Rothstein for fraudulently claiming tut his client had agreed to pay $200 million to sane civil sexual hirusmait charges filed against Epstein by several women after the scandalous allegations against him rant veer InFelt in TOM (In June 20011 Epstein's gE•stsr keelIris negotiate:denim to two orostilidion dorms that infuriated Palm Bead's police chief, who had weedy written • lever critiagjag rnaggloa; Epstein was released this July after serving almost a year in prison.) Three of the sexual hwassmers suitswere filed by lawyers working for Rothstein. Critton says those urn. lawyers Ethely Claimed to represent many more women with potential claims against Epstein. The additional women never sanely existed, Cotton says, adding that they were toady iMioductd to entice investors to fund litigation against his chem. Asa result, Critters says Epstein had to spend more money on his defense io thoseaiminal eases, and his lawyers wound up engaging In frivolous discovery and depositions. The additional cost was between $100,000 to E2C0,000,Crinon says adding that the whole matter has only complicated efforts to resolve parent Casa pending against the billkoatre, instead of • defendant having a legitimate discussion with. plalatiff to resolves case, [Rothstein's] out there pitching millions In dollars from Mn other cases he claims to have,' he ssys, Critton adds that Rothstein 'abusive litigation tactics' included eying to depose estrancoos individuals' that would emturrass Epstein. Those individuals include Bill Clinton, David Copped-old, and Donald Tnsesp.a/I close friends of Epstein who traveled with the money manager on his private plane. (Rothstein sought access to flight records end other information that he could show to potential investors to boost his daim to • ninc-figwe settlement.) Crieton declined to comment on the damages Epstein is widen (MIS Rothstein mar the alleged mu/einem claim& though ha hinted that the amount will be at least $100,000 and more than that if damages are tre/Aisti. Critton has yet to hear from lawyers for Rothstein on the civil suit and says he HMI yet decided whether claims will be brought against other members of Rothstein** deflect firm, Rothstein Rounfeldt Adler. taking baby steps on this, says Critter, gg seretwa to Iiithotohle se. wits RotIntein's criminal lawyer, Marc Nusik, a former partner at RRA, was not immediately available for comment. Mater a seminal Commags0) See & Fareheok I Dat it Iota I Distil!Erma RestdituA.Prefthliftes Comments Report offensive comments to The Am Law Daily Post a comment If yea have a TypeKey or TypePad scow. please Po In Name: Email Address (Not displayed with comment ) URL fl Remember personal info? Comments tyre Mx : Lp__ -7.— st) l'en.i.ar Pages Today I NOIhnininal rum 2. Rope Cco:tv Gibson Dunn Simms.. in Coffee Wan ism* 3. pp, Abandons I oclisteg vin hap://amlawcia ily.Typepad.com/aniIa wda ly/2009/12/rothsteinsui t.himI 12/912009 EFTA00622978 Billionaire Slaps Scott Rothstein With Sult Page 4 of 5 4. Bifklarol Noria New ChNE lues S. 7he Am Unie Dail< won 6. BilliBFBIE.SLADI kot( Rothotin With Soit it" 7. iheAml.awDaiJyusw 8. tirattgoluicaságbalikantadá *88 9. Waringins Helilw Heloinv BofA Bond Eek« New BEO uni 10 ?US Frank. Paul Winti Advite on ShounirteSago ino Ohm N GS 151man L SIONDF tor FREE EAVdt.NEWEL4TfERS > Arr. L1W Dany > LingatIon OaNy inonowsneonaw~ Fret, Ika Law.com Netrovire lome Coutt Beitels Emir *outst, Or AtiOlOtY•Clitril Privike Detenninalions in Rara Vrom Detnvoise Suu Blieft Ovu 16 Killen in Unoani »BIE Jlitl Courtlustjus TakaAimII fonts! StUkti Lew Cao Toch SS1IURRtle1IniMMIlaiU112 Dlintuliklanik012111.91AnEs12 " DSEKII~172 n Vaal Bios Walgt. bv rroni thriew a snarsz Afkrast:Jim Aduribr na1 ARE You CREATIVE A ACTIVIST Crcati, o Visioen 11.44444tigo vies media R tM atv ns itepiro wed tVpirtlfI neetín atlivlus w ho AtIleve la the penvcr of iodividali toeloopt au walt! Wttarklwt. -- e"-.1.RGATIVE karn non V IS I O nS .-www.,„ FOUNDATION zwiwooncliCion51P11114V Policy http://amlawdaily.typepad.com/ainlawdaily/2009/12/rothsteinsuit.html 12/9/2009 EFTA00622979 Billionaire Slaps Scott Rothstein With Suit Page 5 of 5 MadMAIINOwlin critOotlerretwin G:p1ght 2C09.ALM uses PxperWl lta)1310Va rawest eALM aveaysesqn•Cerraw http://arn:awdaily.typepad.com/amlawdaily/2009/12/rothsteinsuit.html 12/9/2009 EFTA00622980 Billionaire Sex Offender Sues Scott Rothstein For Lying About S200 Million Settlement ... Page 1 of 2 3USINESS INSIDER Review Billionaire Sex Offender Sues Scott Rothstei $200 Million Settlement Offer r Geigsr Smith I Dec. 10, 2009, 7:43 AM 892 I 44 "Just when It might have seemed that alleged wrongdoing related to the spectacular downfall of Rothstein Rosenfeld) Adler could not become more bizarre, a billionaire convicted sex offender has filed a civil racketeering lawsuit against two onetime partnere of the South Florida law firm." Thus begins Martha Neil's article for the ABA Aurae! about jailed Florida now-former attorney Scott Rothstein, and really, there is no other way to begin. According to the complaint, plaintiff ..irt:ey Epstein is a defendant in See Also: th:ee civil actions alleging sexual assault filed by Rothstein's former firm. The complaint alleges the RRA we. Georgia Supreme Court Nixes Medical Malpractice Caps attorneys lied about the facts of Lateral Moves Plunge In Texas In 2009 Epstein's case to support their ?onzi scheme. First Health Care Suit Is Filed Courtesy Of State Attorneys General The suit says that Rothstein and other RRA lawyers said Eptstein had offered a $200 million settlement. Epstein said no such offer was ever made. lutp://www.businessinsider.com/billionaire-sex-offfender-sues-scott-rothstein-for-telling-li... 3/29/2010 EFTA00622981 Billionaire Sex Offender Sues Scott Rothstein For Lying About $200 Million Settlement ... Page 2 of 2 'rho complaint alleged the defendants filed false court documents, improperly intern( :!tigation strategies designed to aid their scheme, rather than what was in their client Tags: Law Firms. Ponzi schemes, White-collar crime, Litigation Share: Twitter Facebook Buzz Digg StumbloUpon Buzz R Embed Newsletter OVEN Foamy d ("Jun Cul ra ix; ;•• %nth I • t I In .1 al, t• I:1 4i .ri• . • : III Ii. SO..: lir Itu.••1 ". I '; 1•.4.. Si} F. : t• • . I;• <I. h•rulainn,nd re•mrialx: I.I + p h 4111 $1' .Ii .Iiii m, be' miull PAY 1)i:C.01) • I 1.4 Ilk,. • • ..• %NJ" tarn Nit It. . Hein Geiger Smith Is Editor of Law Review of Business Insider. Re( Ex-I eamilh businessinsider.com Poe hit:worths to her twitter feed Sup 4 Comments _ i Gordon on Dcc 10, 7:48 AM said: Epstein? Rothstein? rm seeing a trend here! Reply black swan on Dec 10, 8:20AM said: hup://wmnv.businessinsider.com/billionaire-sex-offfender-sues-scort-rothstein-for-telling-li... 3/29/2010 EFTA00622982 • Courthouse News Service Page 1 of 2 - • - neon nag MOW in (WAMM. deouraet MofflfenvI OLUMAC Mittésiafflt [MOM • moMilellsallOPmonesromairlhel • engamer. • Courthouse News Service Vt.tairg. para.« 16,.20» ass 1.-tttee 231Ay in DI-nett Chia Ael•Mnid.ned Means WWI ere« Erlain PM.M Atari, ea)' A Peen DtahhiFkettere tontine ofmikilird sec loin ohm«. s steed MetedPoel rhea opciatot &on Renteln. a dlabatted *Ilene, <WainIteehatien used Ike Jamul in/Wegener' se a rodnAboard to tempt folvohlus onolestotton setts Plaintiff.lolftty Rpsldn, • weakhy money manner dilelaCtil ia an ttekneprOgitctION scandal, sei Rothgen ttitd I9 apnea, cm the tonletka by anoxia/tat clients to (decide it.4tgetliefto ofnatal gait? ItsInttln was muted le November In tonnreGan sal* en deed Sr 2 Wilton laraiment ram. Re Kai beta gel:ng Inseµesa theycodd make ?Jute profits by umnienIngin • fund ilme tonaht am cured settlement mathedilm, FRI CetvealtatOrs My. MecedInseo the RH. Rsetutein teld o»duped 'tweeter. tbatles cilmote wo Mel Owls Onestelt ottettoont de l...wend vegn wittln to/ails» the right to cceehot.lvessnaclowel payments in mcluase foe 'damaged lee sum Ras tuthiceln me, bins ail the , Mk. oha FRI eye. Itmelireeenae Relied's emu organised the onmhme of the oeveirsbles.eml Ow many else se•.tleen/ets M adetaloed here far. Rothstein %en! so ex as ha show Invekas baps cowl down:eat, to /um than Into IM eheme. Iramthmitea Mr. Mans the ellesteGy phony seltleawnls ems a $300 otillban parsedui Rollmieln thorned Epstein had missed for more One ho rital•ra of raved esteem and mcleenatinet In his ronvIelm in Palm Limb faulty Court Feick seat lent 'settlement' was one of Rolhucln'soneOak s.Ralsitln ass simply tryinglo cash In on the pule.* ronmundir‘ the meicluthanInvestigation. KpAtin sap. Pamela claims that kotlumln heed up. der of fewileus mewl &malt end moltelsolonlawiults lot emna who Eperio says were taint sectrodoers. Wadley Ykraeola an .nee ley et Mollie«. bps ands defendant Is Y.pelein's menpla!m. forwarded pamicelertymaJetealkpdena.tpalele says. Tw inielawr I. say/ens to Mow Moat) Fderin .. hv.every Ilntle day e1Ms life, made on ananam to tamedIyakeue tbAfren.Were sot talkies ahem five. %%Woe nol le/felns *boo se Werr got »Dint abm 4000alich I ',Mee le the numb« Imosm to lawerdoecenett.We're Mein/about °tweedsofchideen." Edwards allegey selld ken coud pgending tit.à in Ensteietioteslalm. Tex ester:Ions me 'braid. Emeln sad. The Palm Beach Mkt Demur-toes InerstigadatofEpstein maymeekate hit (JStele.reti. The notice invœthsetion Mega that lo 3003, EPlidnMilted a Ifle-3, :4d id I. Rauh hlth *that elaromateo to ahlt Man (as *alums.," atlas Palm Sent manta. Eeneein paid the Yell Sa40 to $3o0 per nail so strip cam cad memos. him walk he etearond Wendt/Ile Ild roeblownoff %alien the range of We eits,cten Is.mid trepan:2,1.6nd ilmeerapadm. *mule's randier and doe tethhne.tkmoveledied shoe theyknew wtut In expeet.dttectives sw.Atttedeas to the Imestit .Phi nerned thflahxd she thisMw would happen In F.pueln's mason< mom,Mood*le the pollee tenon. 4i:tincat a deed with feted awnle to plead odlly lo penmen Nihon (or mosemtion %%re thr scandal wow réheixel.hordes of Yom1Pecono comae of the woo/1.mA messing rewindmaml homey. Many of a., nevhsnt cow tuna dlontuod,IndsodIng that of tooniteadefedolodtf MaxirelloCedfle• Ernteso tlentu that llotlaeln). <rents le the eats seeing loins{mkndeda oaf. demoted pœUnne who changed Mr sloryrepeatelly. In an early Intemiew sitto FBI eanu.otcd In rpoteliscormiaiet. she I:denial/4 hboadmated iolsmini(reputedly brtaghl)oas m:men to Epstein'. house for we work claimed liver/gaol thai Ibreethl ioleffnes saM.hrr were Atio Nth II... Mal or girls besed toe robins Ilion back Cot We /MA«. 3ied 13 br as I knew. we sllhs4 fun Mom.' But *Jut my. that she. Rtnbsida mcnelted ter.na Meat In *meal assault molt the poostitute mitred her tone. 'Come (the eds1seno lea restein'OlOnse4 they-tie acted out of IheirenImIt They dil enhways. and »PM of them vatted nut aad said. Don't rwr do this los me eta's,' Ole woman gated In 3 titesitIon. Crooteln demand...Inner loom ItonnteIn foe conaplomy tad alias e emorm. Ills lead Mooney is Robert Crime Jr. : I Imp://www.courthousenews.com/2009/12/16/Dizzying_Claims_Against Disbarred_Attom... 3/29/2010 EFTA00622983 Courthouse News Service Page 2 of 2 tits &sultan asitalattimaka !train tthamk eM CsaLiztib http://www.courthousenews.com/2009/12/16/Dirrying_Clahns_Against_Disbarred_Attorn... 3/29/2010 EFTA00622984