JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendants I IN THE CIRCUIT COURT OF THE th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO cJ1 DEFENDANT L.M ANSWER AND AFFIRMATIVE DEFENSES Defendant L.M individually hereby files her Answer to the Complaint filed by Plaintiff JEFFREY EPSTEIN in the above-styled matter on December as follows ANSWER GENERAL ALLEGATIONS Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M admits that Defendant BRADLEY EDWARDS is an individual residing in Broward County Florida and is licensed to practice law in the State of Florida otherwise Defendant L.M denies the balance of the allegations contained in Paragraph and demands strict proof thereof Defendant L.M admits that she is an individual residing in Palm Beach County Florida represented by Defendant EDWARDS who was an attorney at RRA for a short period of time during the representation Otherwise Defendant L.M denies the balance of the allegations contained in Paragraph and demands strict proof thereof Defendant L.M admits that non-party RRA is a Florida Professional Service Corporation with a principal address of East Las Olas Boulevard Suite Ft Lauderdale FL and it conducted business and filed lawsuits on behalf of clients in Palm Beach County Florida Otherwise Defendant L.M denies the balance of the allegations contained in Paragraph and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M does know however that she is not a party to any criminal RICO action Defendant L.M admits that RRA held itself out as legitimately and properly engaging in the practice of law Otherwise Defendant L.M is without knowledge to either admit or deny the balance of the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M admits the allegations contained in Paragraph Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M admits that the identities of the victims of sexual abuse committed by Epstein were shielded in the civil lawsuits through the use of initials All other allegations of Paragraph are denied and Defendant demands strict proof thereof Defendant L.M admits that EDWARDS represented her against Epstein and that for a small period of time he did so while an attorney with RRA All other allegations of Paragraph are denied and Defendant demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and thereby denies these allegations and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph except that L.M admits the evidence against Epstein was in fact real and therefore denies the remaining allegations of paragraph and demands strict proof thereof L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph except that L.M specifically denies that she engaged in or had knowledge of any of the alleged unethical or illegal conduct and denies ever receiving any up front money and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph except that L.M specifically denies that she engaged in or had knowledge of any of the alleged illegal conduct and otherwise denies the remaining allegations of paragraph and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph a and and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph and therefore denies these allegations and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M admits that L.M gave a sworn taped statement to the FBI and a subsequent deposition in the civil proceedings The best evidence of the content of these statements is the transcript of each and L.M otherwise denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M admits or denies the allegations contained in Paragraphs as previously set forth herein Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M admits or denies the allegations contained in Paragraphs and as previously set forth herein Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M is without knowledge to either admit or deny the allegations contained in Paragraph except Defendant L.M admits that as of the filing of this Complaint criminal charges have only been brought against Rothstein otherwise Defendant L.M denies the balance of the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M admits or denies the allegations contained in Paragraphs and as previously set forth herein Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M admits or denies the allegations contained in Paragraphs as previously set forth herein Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M admits or denies the allegations contained in Paragraphs and as previously set forth herein Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M denies the allegations contained in Paragraph and demands strict proof thereof Defendant L.M has retained the undersigned attorneys to defend this action against her and has agreed to pay them a reasonable fee and costs All allegations not otherwise expressly addressed are denied WHEREFORE having fully answered the claims against her L.M demands judgment in her favor and an award of fees and costs pursuant to the prevailing party provisions of the applicable statutes pursuant to which Epstein has brought his claims as well as section Fla Stat AFFIRMATIVE DEFENSES Epstein is barred estopped and/or has waived any claims asserted herein by virtue of the fact that he has invoked the th Amendment in response to questions posed to him in the underlying sexual abuse litigation and has plead guilty to criminal charges based upon the same underlying facts CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S Mail to all counsel on the attached list on December J7 Gary Farmer Jr Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Ave Suite Fort Lauderdale FL fax Attorneys Defendant Robert Critton Jr Michael Pike Esq COUNSEL LIST BURMAN CRITTON LUTTIER COLEMAN Banyan Blvd Suite West Palm Beach FL Attorneys for Plaintiff JEFFREY EPSTEIN Jack Scarola Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Defendant BRADLEY EDWARDS
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