EFTA01247151Set 9
2009-11-2036p8,997w
Civil Actions.
42. In furtherance of their illegal and fraudulent scheme against EPSTEIN,
ROTHSTEIN, EDWARDS (who either know or should have known) and, at times,
in her Civil Action against ... made
in her testimony prior to her representation by EDWARDS/RRA and after she
hired ROTHSTEIN, EDWARDS and RRA.
48. As a result of the fraudulent investment or (Ponzi) ay knowingly ... Epstein thus discovery, would be tantamount to barring him from mounting a
.
defense?
50. ROTHSTEIN, EDWARDS an' actions constitute a fraud upon EPSTEIN
as RRA, ROTHSTEIN and the Litigation Team
https://www.justice.gov/epstein/files/DataSet%209/EFTA01247151.pdf
EFTA00729404Set 9
2009-11-20103p24,512w
Civil Actions.
42. In furtherance of their illegal and fraudulent scheme against EPSTEIN,
ROTHSTEIN, EDWARDS (who either know or should have known) and, at times,
in her Civil Action against ... made
in her testimony prior to her representation by EDWARDS/RRA and after she
hired ROTHSTEIN, EDWARDS and RRA.
48. As a result of the fraudulent investment or (Ponzi) scheme ... Epstein thus discovery, would be tantamount to barring him from mounting a
defense."
50. ROTHSTEIN, EDWARDS and M.'s actions constitute a fraud upon EPSTEIN
as RRA, ROTHSTEIN
https://www.justice.gov/epstein/files/DataSet%209/EFTA00729404.pdf
EFTA00190026Set 9
2009-11-2036p8,414w
Civil Actions.
42. In furtherance of their illegal and fraudulent scheme against EPSTEIN,
ROTHSTEIN, EDWARDS (who either know or should have known) and, at times, L.M.
in her Civil Action ... made
in her testimony prior to her representation by EDWARDS/RRA and after she
hired ROTHSTEIN, EDWARDS and RRA.
48. As a result of the fraudulent investment or (Ponzi) scheme ... Epstein thus discovery, would be tantamount to barring him from mounting a
defense."
50. ROTHSTEIN, EDWARDS and L.M.'s actions constitute a fraud upon EPSTEIN
as RRA, ROTHSTEIN
https://www.justice.gov/epstein/files/DataSet%209/EFTA00190026.pdf
EFTA01084224Set 9
2009-10-1316p4,379w
clients with claims against Epstein, all to the detriment of the Plaintiff.
Defendants Rothstein, Edwards, and others, conspired to induce investors to fund the prosecution
of the civil claims against ... WEST, 777 SOUTH FLAGLER DRIVE.. WEST PALM BEACH, FLORIDA 33401
EFTA01084224
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
these underlying actions, using improper investigatory tools ... POINT WEST, 777 SOUTH FLAGLF.R DRIVE, WEST PALM BEACH, FLORIDA 33401
EFTA01084225
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
7. The purpose of the investments
https://www.justice.gov/epstein/files/DataSet%209/EFTA01084224.pdf
EFTA01084208Set 9
2009-10-1316p4,434w
clients with claims against Epstein, all to the detriment of the Plaintiff.
Defendants Rothstein, Edwards, and others, conspired to induce investors to fund the prosecution
of the civil claims against ... WEST, 777 SOUTH FLAGLER DRIVE.. WEST PALM BEACH, FLORIDA 33401 •
EFTA01084208
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
these underlying actions, using improper investigatory tools ... POINT WEST, 777 SOUTH FLAGLF.R DRIVE, WEST PALM BEACH, FLORIDA 33401 •
EFTA01084209
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
7. The purpose of the investments
https://www.justice.gov/epstein/files/DataSet%209/EFTA01084208.pdf
EFTA00808816Set 9
2009-12-0738p7,270w
engaged in numerous felonies, including forging federal judges' signatures. Epstein
further alleged that Rothstein, Edwards, and . defrauded him and engaged in
racketeering and civil theft, as well as abuse ... only remaining claim is his conspiracy to commit
abuse of process claim against Rothstein.
Edwards then amended his counterclaim, which included a malicious
prosecution claim against Epstein (App.3). Essentially, that ... stipulation provided:
What, if any damages were sustained by Epstein and proximately
caused by Rothstein? (Edwards does not agree with this language for
the reason that the issue as stated
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808816.pdf
EFTA01082338Set 9
2009-10-1315p4,334w
SOUTH FLA0LER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044
EFTA01082338
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
underlying actions against Epstein, making unfounded allegations ... SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044
EFTA01082339
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
8. At or near the time that Rothstein ... SOUTH RADLER DRIVE, WEST PALM BEACH, FLORIDA 33401. (561)802-9044
EFTA01082340
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
(8) That one of the RRA clients felt
https://www.justice.gov/epstein/files/DataSet%209/EFTA01082338.pdf
EFTA00584212Set 9
2009-10-1316p4,327w
been described by a United States
Attorney as a criminal enterprise. Its founder, Scott Rothstein — Edwards' partner, is currently
serving a 50-year sentence in federal prison for selling fake ... Edwards' clients with claims against Epstein,
to the detriment of the Plaintiff. Defendants Rothstein, Edwards, and others, conspired to induce
FOWLER WHITE BuRNEET P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH ... FLAGLER DRIVE. WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044
EFTA00584212
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
investors to pay fictitious settlement participations by the prosecution
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584212.pdf
EFTA00807470Set 9
2018-03-1318p5,538w
December 7, 2009, Epain filed a civil Complaint in this action against
Rothstein, Edwards and M. (12/7/09 Complaint, Jeffrey Epstein v. Scott
Rothstein, et at, 15th Judicial Circuit Court, Palm
https://www.justice.gov/epstein/files/DataSet%209/EFTA00807470.pdf
EFTA01084240Set 9
2009-10-1317p4,664w
been described by a United States
Attorney as a criminal enterprise. Its founder, Scott Rothstein — Edwards' partner — is currently
serving a 50-year sentence in federal prison for selling fake ... Edwards' clients with claims against
Epstein, to the detriment of the Plaintiff. Defendants Rothstein, Edwards, and others, conspired
FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE ... WEST PALM BEACH, FLORIDA 33401 •
EFTA01084240
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
to induce investors to pay fictitious settlement participations by the prosecution of exaggerated
civil
https://www.justice.gov/epstein/files/DataSet%209/EFTA01084240.pdf
EFTA00223265Set 9
2009-12-09106p25,783w
Civil Actions.
42. In furtherance of their illegal and fraudulent scheme against EPSTEIN,
ROTHSTEIN, EDWARDS (who either know or should have known) and, at times,
in her Civil Action against ... ARDS/RRA and after she
in her testimony prior to her representation by EDW
hired ROTHSTEIN, EDWARDS and RRA.
zi) scheme, may knowingly
48. As a result of the fraudulent investment ... Epstein thus discovery, would be tantamount to barring him from mounting a
defense."
50. ROTHSTEIN, EDWARDS and C's actions constitute a fraud upon EPSTEIN
as RRA, ROTHSTEIN
https://www.justice.gov/epstein/files/DataSet%209/EFTA00223265.pdf
EFTA00793693Set 9
2018-03-0824p4,964w
while it has its genesis in the original action filed by
Epstein against Rothstein, Edwards and L.M., the fact
that simply because it has its genesis there ... case had its genesis in the fact that Epstein
originally brought the claim against Rothstein, Edwards
and L.M., . . . [Tr. 26: 18-23]
. . .albeit having its genesis in the original Epstein ... Hearing Transcript at App. 19.
I0
EFTA00793702
It had the genesis in Epstein versus Rothstein, Edwards
and L.M. case so as to permit Edwards to bring the claim
against Rothstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793693.pdf
EFTA00584195Set 9
2009-10-1317p4,666w
been described by a United States
Attorney as a criminal enterprise. Its founder, Scott Rothstein — Edwards' partner — is currently
serving a 50-year sentence in federal prison for selling fake ... Edwards' clients with claims against
Epstein, to the detriment of the Plaintiff. Defendants Rothstein, Edwards, and others, conspired
FOWLER WHITE BuRNEET P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE ... WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044
EFTA00584195
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
to induce investors to pay fictitious settlement participations by the prosecution
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584195.pdf
EFTA01126056Set 9
2009-10-1318p4,484w
them into purchasing fake interests in
FOWLER WHITE BURNETT PA..
EFTA01126056
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
assignments of fictitious structured settlements, including those falsely ... Edwards -clients with claims against Epstein, all-to the detriment of the
Plaintiff. Defendants Rothstein, Edwards, and others, conspired to induce investors to pay
fitctious settlement participations by €und-Ekethe ... state of Florida.
-2-
FOWLER WHITE BURNETT P.A.
EFTA01126057
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
5. Beginning in April, 2009, and at all relevant times, Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA01126056.pdf
EFTA00795588Set 9
2009-11-20103p23,937w
furtherance of their i O w
a fraudulent scheme against EPSTEIN,
ROTHSTEIN, EDWARDS (who either know or should have known) and, at times, L.M.
in her Civil Action against EPSTEIN ... made
in her testimony prior to her representati ARDS/RRA and after she
A..‘
hired ROTHSTEIN, EDWARDS and
48. As a result of the fraudulent investtrie or (Ponzi) scheme ... thus discovery, would be tantamount toV rri g him from mounting a
defense."
50. ROTHSTEIN, EDWARDS and L.M.'s,4os lonstitute a fraud upon EPSTEIN
as RRA, ROTHSTEIN
https://www.justice.gov/epstein/files/DataSet%209/EFTA00795588.pdf
EFTA00286283Set 9
2009-11-2036p8,598w
EPSTEIN,
42. In furtherance of their illegal and fraudulent
have known) and, at times, ■.
ROTHSTEIN, EDWARDS (who either know or should
in her Civil Action against EPSTEIN:
al action ... ARDS/RRA and after she
in her testimony prior to her representation by EDW
hired ROTHSTEIN, EDWARDS and RRA.
i) scheme, may knowingly
48. As a result of the fraudulent investment ... Epstein thus discovery, would be tantamount to barrin
defense."
a fraud upon EPSTEIN
50. ROTHSTEIN, EDWARDS and ■.'s actions constitute
d themselves to be acting in
as RRA, ROTHSTEIN
https://www.justice.gov/epstein/files/DataSet%209/EFTA00286283.pdf
EFTA00607531Set 9
2009-11-2036p8,599w
furtherance of their illegal and fraudulent
have known) and, at times, L.M.
ROTHSTEIN, EDWARDS (who either know or should
in her Civil Action against EPSTEIN:
federal action in
a) Included ... RDS/RRA end after she
in her testimony prior to her representation by EDWA
hired ROTHSTEIN, EDWARDS and RRA.
scheme, 'M. may knowingly
48. As a result of the fraudulent investment ... from mounting a
Epstein thus discovery, would be tantamount to barrin
defense'?
50. ROTHSTEIN, EDWARDS and Ss actions constitute a fraud upon EPSTEIN
ented themselves to be acting
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607531.pdf
EFTA01093224Set 9
2009-10-1316p4,352w
been described by a United States
Attorney as a criminal enterprise. Its founder, Scott Rothstein — Edwards' partner, is currently
serving a 50-year sentence in federal prison for selling fake ... Names YE. WEST PALM BEACH, FLORIDA 33401 • (561)802.9044
EFTA01093224
‘stein v Rothstein, Edwards
Case No.: 502.v09CA040800XVOGABAG
Corrected Second Amended Complaint
including those falsely claimed to have been reached ... SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044
EFTA01093225
stein v Rothstein, Edwards
Case No.: 502u09CA040800XXXXMBAG
Corrected Second Amended Complaint
The Ponzi Scheme
6. During 2009 Rothstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA01093224.pdf
EFTA00607583Set 9
2009-10-1316p4,352w
been described by a United States
Attorney as a criminal enterprise. Its founder, Scott Rothstein — Edwards' partner, is currently
serving a 50-year sentence in federal prison for selling fake ... Names YE. WEST PALM BEACH, FLORIDA 33401 • (561)802.9044
EFTA00607583
‘stein v Rothstein, Edwards
Case No.: 502.v09CA040800XVOGABAG
Corrected Second Amended Complaint
including those falsely claimed to have been reached ... SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044
EFTA00607584
stein v Rothstein, Edwards
Case No.: 502u09CA040800XXXXMBAG
Corrected Second Amended Complaint
The Ponzi Scheme
6. During 2009 Rothstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607583.pdf
EFTA00596488Set 9
2009-11-2082p19,382w
Civil Actions.
42. In furtherance of their illegal and fraudulent scheme against EPSTEIN,
ROTHSTEIN, EDWARDS (who either know or should have known) and, at times, L.M.
in her Civil Action ... S/RRA and after she
in her testimony prior to her representation by EDWARD
hired ROTHSTEIN, EDWARDS and RRA.
me, L.M. may knowingly
48. As a result of the fraudulent investment ... Epstein thus discovery, would be tantamount to barring him from mounting a
defense."
50. ROTHSTEIN, EDWARDS and L.M.'s actions constitute a fraud upon EPSTEIN
as RRA, ROTHSTEIN
https://www.justice.gov/epstein/files/DataSet%209/EFTA00596488.pdf