EFTA00619811Set 9
2017-06-3017p5,616w
Scott W. Rothstein, et at, Case No. 09-
062943(19) (hereinafter referenced as the "Razorback Complaint"), for the fraudulent scheme
perpetrated at RRA involving, among other deceptive practices ... Deposition Transcript of Jeffrey Epstein, p. 23; line 4-p. 38; line 22. The
Razorback Complaint specifically avowed that such fraudulent discovery and pleadings in the
Epstein Cases were being ... world famous celebrities, politicians and other dignitaries associated with him. See Epstein
Affidavit; Razorback Complaint. Specifically, the Razorback Complaint stated:
purported settlements, albeit fraudulent, were based on actual cases being
https://www.justice.gov/epstein/files/DataSet%209/EFTA00619811.pdf
EFTA00612483Set 9
2015-10-2035p8,537w
Scott W.
Rothstein, et al., Case No. 09-062943(19) (hereinafter referenced as the
"Razorback Complaint"), on behalf of some of the Ponzi Scheme
investors.
Upon reviewing the Razorback Complaint ... learned that the Razorback
Complaint detailed the use of the Epstein Cases (i.e., the cases being
litigated against me by Edwards) to defraud investors in the Ponzi
Scheme; including ... discovery practices and
other methods to bolster the cases?
Among the allegations in the Razorback Complaint regarding the Epstein cases are the
following. "Representatives of D3 were offered `the opportunity
https://www.justice.gov/epstein/files/DataSet%209/EFTA00612483.pdf
EFTA00583952Set 9
2010-03-2330p9,571w
Scott W. Rothstein, et aL, Case No. 09-062943(19) (hereinafter
referenced as the "Razorback Complaint"), against Scott Rothstein and others alleging a
fraudulent scheme perpetrated at RRA involving, among ... litigating against Epstein (the
"Epstein Cases").4 It was specifically alleged in the Razorback Complaint that such fraudulent
discovery and pleadings in the Epstein Cases were being used ... line 4-p. 38; line 22.
5 Among the allegations in the Razorback Complaint regarding the fraudulent conduct in
the Epstein Cases in connection with the Ponzi Scheme are that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583952.pdf
EFTA00808205Set 9
2014-05-1917p4,342w
Scott W.
Rothstein, et al., Case No. 09-062943(19) (hereinafter referenced as the
"Razorback Complaint"), on behalf of some of the Ponzi Scheme
investors.
Upon reviewing the Razorback Complaint ... learned that the Razorback
Complaint detailed the use of the Epstein Cases (i.e., the cases being
litigated against me by Edwards) to defraud investors in the Ponzi
7
EFTA00808211
Scheme ... support the operation and activities of RRA, to expand
Among the allegations in the Razorback Complaint regarding the Epstein cases are the
following. "Representatives of D3 were offered `the opportunity
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808205.pdf
EFTA00799339Set 9
2010-03-2326p8,044w
Scott W. Rothstein, et aL, Case No. 09-062943(19) (hereinafter
referenced as the "Razorback Complaint"), against Scott Rothstein and others detailing abusive
litigation practices specifically in active RRA cases ... line 4-p. 38; line 22.
5 Among the allegations in the Razorback Complaint regarding the Epstein cases are the
following: "In certain instances, the purported settlements, albeit fraudulent, were ... firm to run a $1.2 billion investment racket.").
The litigation practices described in the Razorback Complaint did indeed take place in
the Epstein Cases, as did other litigation practices
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799339.pdf
EFTA00806915Set 9
2009-11-0241p12,898w
Scott W. Rothstein, et at, Case No. 09-062943(19) (hereinafter referenced as
the "Razorback Complaint"), on behalf of some of the Ponzi Scheme investors.
9. Upon reviewing the Razorback ... Complaint, I learned that the Razorback Complaint detailed
the use of the Epstein Cases (i.e.. the cases being litigated against me by Edwards) to
defraud investors in the Ponzi ... Complaint in the Action, consistent with the allegations made by
the press, in the Razorback Complaint, and in the Rothstein Information, it was clear that
the activity in the Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00806915.pdf
EFTA00313643Set 9
2009-07-245p1,231w
Scott W. Rothstein, et al, Case No. 09-062943(19)
(hereinafter referenced as the "Razorback Complaint"), on behalf of some of the Ponzi
Scheme investors.
9. Upon reviewing the Razorback ... Complaint, I learned that the Razorback
Complaint detailed the use of the Epstein Cases (i.e., the cases being litigated against me
2
EFTA00313644
by Edwards) to defraud investors ... Complaint in the Action, consistent with the
allegations made by the press, in the Razorback Complaint, and in the Rothstein
Information, it was clear that the activity in the Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00313643.pdf
EFTA00313265Set 9
2009-07-245p1,234w
Scott W. Rothstein, et al., Case No. 09-062943(19)
(hereinafter referenced as the "Razorback Complaint"), on behalf of some of the Ponzi
Scheme investors.
9. Upon reviewing the Razorback ... Complaint, I learned that the Razorback
Complaint detailed the use of the Epstein Cases (i.e., the cases being litigated against me
2
EFTA00313266
by Edwards) to defraud investors ... Complaint in the Action, consistent with the
allegations made by the press, in the Razorback Complaint, and in the Rothstein
Information, it was clear that the activity in the Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00313265.pdf
EFTA01733722Set 10
2009-07-245p1,241w
Scott W. Rothstein, et al., Case No. 09-062943(19)
(hereinafter referenced as the "Razorback Complaint"), on behalf of some of the Ponzi
Scheme investors.
2
EFTA_R1_00008496
EFTA01733723 ... Upon reviewing the Razorback Complaint, I learned that the Razorback
Complaint detailed the use of the Epstein Cases (i.e., the cases being litigated against me
by Edwards) to defraud investors ... Complaint in the Action, consistent with the
allegations made by the press, in the Razorback Complaint, and in the Rothstein
Information, it was clear that the activity in the Epstein
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01733722.pdf
EFTA01122209Set 9
2013-11-0411p3,629w
Scott W. Rothstein, et at, Case No. 09-062943(19) (hereinafter referenced as
the "Razorback Complaint"), on behalf of some of the Ponzi scheme investors. In the Razorback
Complaint ... Razorback Amended Complaint; page 17; ¶ 49
(emphasis added). (The relevant portion of the Razorback Complaint is attached for
reference.)
The deposition subpoenas and discovery requests to which the Razorback Complaint ... Motion, questionable litigation practices
in the Epstein Cases, including those described above in the Razorback Complaint, intensified
drastically in the short six (6) months during which Edwards was a partner
https://www.justice.gov/epstein/files/DataSet%209/EFTA01122209.pdf
EFTA00801507Set 9
2010-03-2318p5,756w
Scott W. Rothstein, et at, Case No. 09-062943(19) (hereinafter referenced as the "Razorback
Complaint"), on behalf of some of the Ponzi scheme investors. Mr. Scherer asserted the
following ... emphasis added). All of these deposition
subpoenas and discovery requests to which the Razorback Complaint refers were served and
filed by Edwards at the time that Edwards was a partner ... filed by Epstein dated December 9, 2009, pages 13-20. The
allegations in the Razorback Complaint that the Epstein Cases were used to lure investors in the
Ponzi Scheme were
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801507.pdf
EFTA01112494Set 9
2010-03-2327p8,305w
Scott W. Rothstein, et at, Case No. 09-062943(19) (hereinafter
referenced as the "Razorback Complaint"), on behalf of some of the Ponzi scheme
investors. Mr. Scherer3 asserted the following ... emphasis added). All of these
deposition subpoenas and discovery requests to which the Razorback Complaint refers
were served and filed by Edwards at the time that Edwards was a partner ... filed by Epstein dated December 9, 2009, pages 13-20. The allegations in the Razorback
Complaint that the Epstein Cases were used to lure investors in the Ponzi Scheme were
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112494.pdf
EFTA01112467Set 9
2010-03-2327p8,263w
Scott W. Rothstein, et at, Case No. 09-062943(19) (hereinafter
referenced as the "Razorback Complaint"), on behalf of some of the Ponzi scheme
investors. Mr. Scherer3 asserted the following ... emphasis added). All of these
deposition subpoenas and discovery requests to which the Razorback Complaint refers
were served and filed by Edwards at the time that Edwards was a partner ... filed by Epstein dated December 9, 2009, pages 13-20. The allegations in the Razorback
Complaint that the Epstein Cases were used to lure investors in the Ponzi Scheme were
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112467.pdf
EFTA01102325Set 9
2013-10-116p2,197w
Scott W. Rothstein, et at, Case No. 09-062943(19)
(hereinafter the "Razorback Complaint"), on behalf of some of the Ponzi scheme investors.
The Razorback Complaint alleged the following ... these famous individuals, or ever being on
Epstein's plane, as cited in the Razorback Complaint. All of these deposition subpoenas and
discovery requests to which the Razorback Complaint refers ... Street, Fort Lauderdale, FL 33301•
EFTA01102328
such as those alleged in the Razorback Complaint, intensified drastically in the short six (6)
months during which Edwards was a partner
https://www.justice.gov/epstein/files/DataSet%209/EFTA01102325.pdf
EFTA00597312Set 9
2013-10-116p2,202w
Scott W. Rothstein, et at, Case No. 09-062943(19)
(hereinafter the "Razorback Complaint"), on behalf of some of the Ponzi scheme investors.
The Razorback Complaint alleged the following ... these famous individuals, or ever being on
Epstein's plane, as cited in the Razorback Complaint. All of these deposition subpoenas and
discovery requests to which the Razorback Complaint refers ... Street, Fort Lauderdale, FL 333010 954.467.1223
EFTA00597315
such as those alleged in the Razorback Complaint, intensified drastically in the short six (6)
months during which Edwards was a partner
https://www.justice.gov/epstein/files/DataSet%209/EFTA00597312.pdf
EFTA01734350Set 10
2013-10-115p1,567w
Scott W. Rothstein, a at, Case No. 09-062943(19)
(hereinafter the "Razorback Complaint"), on behalf of some of the Ponzi scheme investors.
The Razorback Complaint alleged the following ... these famous individuals, or ever being on
Epstein's plane, as cited in the Razorback Complaint. All of these deposition subpoenas and
discovery requests to which the Razorback Complaint refers ... Lauderdale, FL 33301• 954.467.1223
EFTA_R1_00012253
EFTA01734353
such as those alleged in the Razorback Complaint, intensified drastically in the short six (6)
Tonja Haddad, P.A. • 315 SE 7" Street
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01734350.pdf
EFTA00788112Set 9
107p21,462w
motions on pages five
12 through seven, specific sections of the
13 Razorback complaint is cited to the Court.
14 It states that purported settlements, albeit
15 fraudulent, were based ... cases, as well as the
10 filings in the federal court, and the
11 Razorback complaint itself, which was one of
12 the largest settlements in Broward County ... investors were able to get all of their
17 money back.
18 The Razorback complaint was a
19 successful suit. And at the time
20 Mr. Epstein filed the suit
https://www.justice.gov/epstein/files/DataSet%209/EFTA00788112.pdf