Filing E-Filed AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff/Counter-Defendant PART6 SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS APPENDIX OF DOCUMENTS IN SUPPORT OF HIS REVISED OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein Epstein files this Appendix of Documents in support of his revised Omnibus Motion in Limine No Date Document Epsteins Motion to Amend Complaint D.E Plaintiffs Motion to Strike References to Non-Prosecution Agreement or in the Alternative to Lift Protective Order Barring Jane Does Attorneys from Revealing Provisions in the Agreement D.E Jane Doe Jeffrey Epstein S.D Fla Case No Plaintiffs First Amended Complaint D.E Jane Doe Jeffrey Epstein S.D Fla Case No Jeffrey Epsteins Deposition Transcript Excerpts pp E.W Jeffrey Epstein th Judicial Circuit Case No FILED PALM BEACH COUNTY FL SHARON BOCK CLERK AM No Date Document Plaintiffs Motion for Injunction Restraining Fraudulent Transfer of Asserts Appointment of a Receiver to Take Charge of Property of Epstein and to Post a Million Bond to Secure Potential Judgment D.E Jane Doe Jeffrey Epstein S.D Fla Case No 08-cv-80119-MARRA/JOHNSON Order Denying Plaintiffs Motion for Injunction etc D.E Jane Doe Jeffrey Epstein S.D Fla Case No MARRA/JOHNSON Letters from Edwards re depositions Complaint D.E L.M Jeffrey Epstein S.D Fla Case No NIA Court Docket L.M Jeffrey Epstein S.D Fla Case No Re-Notices of Taking Videotaped Deposition of Donald Trump Jane Doe Jeffrey Epstein S.D Fla Case No Plaintiffs Request for Entry Upon Land D.E E.W Jeffrey Epstein th Judicial Circuit Case No Epsteins Motion for Protective Order Regarding Depositions of Lawrence Visoski and David Hart Rogers D.E L.M Jeffrey Epstein th Judicial Circuit Case No Article South Florida Sun-Sentinel Scott Rothstein investment deals seemed too good to be true Article New Times Broward-Palm Beach Scott Rothstein The Jeffrey Epstein and Bill Clinton Ploy Verified Complaint for Forfeiture In Rem D.E United States of America Scott Rothstein Forfeiture Action S.D Fla Case No Article South Florida Sun-Sentinel FBI doubts Rothstein ran a Ponzi scheme alone No Date Document Complaint without exhibits D.E Razorback Funding LLC Rothstein 17th Jud Cir Case No Amended Verified Complaint for Forfeiture In Rem D.E United States of America Scott Rothstein Forfeiture Action S.D Fla Case No Article South Florida Sun-Sentinel Youre in a town full of thieves Article The Miami Herald Feds Scott Rothstein Ponzi scheme paid salaries at law firm Amended Complaint without exhibits D.E Razorback Funding LLC Rothstein 17th Jud Cir Case No Information D.E United States Rothstein S.D Fla Case No Complaint without exhibits D.E Affidavit of Jeffrey Epstein D.E Bradley Edwards Deposition Transcript Excerpts pp Bradley Edwards Deposition Transcript Excerpts pp Bradley Edwards Deposition Transcript Excerpts pp Email from Pricilla Nascimento to Scott Rothstein Email from Bradley Edwards to Priscilla Nascimento Email from Ken Jenne to Scott Rothstein Scott Rothsteins Deposition Transcript Excerpts pp No Date Document Scott Rothsteins Deposition Transcript Excerpts pp Razorback Funding LLC Rothstein 17th Jud Cir Case No Scott Rothsteins Deposition Transcript Excerpts Razorback Funding LLC Rothstein 17th Jud Cir Case No Jeffrey Epsteins Deposition Transcript Excerpts pp Edwards Amended Exhibit List D.E Epsteins Objections to Edwards Amended Exhibit List D.E Edwards Seventh Amended and Supplemental Witness List D.E Jeffrey Epsteins Deposition Transcript Excerpts pp CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on November through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration Jack Scarola LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Angela linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Tanya linkrocklaw.com Secondary Eservice linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL mep searcylaw.com jsx searcylaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards West Palm Beach FL njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein APP Epsleln-v RRA et al Pa A OT lil her FBf statement pre-EOWAROS and RRA L.M testified bout 267ofhei LM brought to the Ep.steln horne 267testlfl wom she b-ro 267ught to EP.STEiNs home we-re e:ager 225.fbdihe,opptirtunlty-ahd 267cotrtent 267ilh their experlen_cas A None of niy girls ever had a problem 267and theyd call me Theyd me you know fQr to go to J.effre.ts ho1Jse because they Jeffrey Jefftey-Js a:respectful man_ fle 267really Is lmean and he all tho 265ght we were of age 267,a1ways this whees so,sad about ft FBI Did any of the girls complain about What h1;1ppened 267after they left there1 A No You-asked me 267th:at question No everyb6dy love.d 267Jeffrey FBI A iEvery girl that I brought to Jeffrey they said they were fine with It and llke for example E:W another of RRA.s clients in the Civil Actions a lot of girls be.gged rne to bring them 267back for the money And as far as I ow _we all had fun there FBI I i i Epstelh RRA etal Page27 Yet with EDWARDS and RRA as her attorneys did a her September deposl.tlon in saying A Once they were thera they were scare.d out ofthelr mind They did If 267anyways arid some.of thern 267w.alked out and said L..M dont v.er do this to me gain Thatwa tl e-worst tbtng that ever happened to me OT A And then a 267Jot of girls werent comfortable DT The above.represent only a few,of the dramatic change.s made i.n het testimony prior to her represer:itatibr.i by EDWARDS/RRA and after she hired ROTHSTEIN EDWARDS and,RRA As a re:sult of the fraudulent investment or Ponzi heme L.M may knowingly compromised her alleged interests her Civil Action oornm ed a fraud on the court RRA an.d 267the litf atlon Team took an ern tlonally drl11en facts involving llegect Jnnorsent1 unsuspecting underage females ahd a Palm Beach Blonalttl and sought to-tum it lnto a gold mine Rather than evaluatlng and re olv!ng the cases,based qn lhe merits i.e facts which fncluded knowledgeable voluntary and consensua.l actions by each of the claimants and substantial pre-Epstein 267psychological and emotlo 267nal c;phditions of each Cif the claimants and substantial sexual experiences pre 267epstelni RRA and the Litigation Team sought 267through prote 267cttve orders and objections to block re1evant discovery regarding their claimants They Instead forged ahead with 267discovery the main p.urpose of which was ta pressure Epstein Into settling the cases i i Epstein RAA et-al Piig ForttJ.nate1y their tactics have not been successful As Magistrate Judge Linnea Johnsonvirote a discove.worder.dated 267September DE Jn Fedsra.l Case l1t9 fo 267tlenylrng P.lalntiffs Mptlo.nfor Prqtectrv,e Order This js his pstelnsI right The Record in this case ls clear that.the childhood of many-of th Plalntlffs was marred by Instance of abuse and negleqt which In tum may have 267resulted In whole or hi part in the damages claimed by the iP:l;liJtitlff lh adtdtioh in a drnntbti1 Order da ober DE In Federal Case Ma_gistrate Judge Linnea Johnson wr-ot irH re the rel!tuest aUsstie goes to the very heart of the Plaintiffs darnage clalms req 265esting iot Ohly general Information relating Plaintiffs sexual history but lnq 265lring as to spei;;!flc Instances wherein Hainttff received compensation cqnslderation for sex acts claim other mafes sexualfy assaulted battere or abu1t her atrd/or"rilalm other:males committed lewd or lasclv.ious acts-on her As a global matter Plaintiffs arly and unequiVocaHy place their exual history In Issue by their allegations that Epsteins actions In this 267case has negatively ffecteo their relationships by among 267other things distrust in me1J sexual intimacy probl diminished 267trust sooial problems problems in personal relatiorrshfps feeling of stress around men premature teenage pregnancy pantlsoclal behaviors and 225hyper-sexuality and promiscuity Considering these allegatlon there simply can be no question that Epstein Is entitled to know wh therPl tintiffs were molested or the subject of other sexual act vityw or lewd I Epste.ln RRA et.at P-aQ.e and 1ast:ivioos condu.otn Iii or-der to determine whether there Is an alternaUve basl c;jf:tl:i ychoJoglcal disorders Plaintiffs claim to hav susta1ned whether Pl intiff ilgaged In prostitutlon or ether similar type acts.and,hci.w e:rtain 260acts Eriie.t1e:d:lri th Compl int inatarlafly affected Plaintiffs refatlonships wiilJ-others or how tliose acts dld not tJ ve such an affect on those relatfohsfiips:anei1.lr whel er Plaintiffs suffered from the alleged emotlonal and psychological dtsordets a result of iher sexu I acts prior to the acts alleged in the Complalnl To deny Epste.fn tl11JS dJspovery 267woufd be tantamount to berrln_g him from mounting a fens ROTHST iN lEtiWARDS and L.M.s actions constitute a fraud upon EPSTEIN as RRA ROTHSTEIN and the Litigation Team represented,themseives to be acting In good 1alth and with the-bests Interests cf their clients rn mind at all times when reality they were 267,E!cflrig in 225furthe.rance of the investment or Ponzi scheme described hereln i TEIN Ju tifiably relied to Ii.ls 267detriment on the re:preseritatlons of RRA and Jefend tnts ROTHSTEU ffiOW.ARDS and LM to how he condu.cted and.defended the CMlActfons brought ag:alnst-hlm As a direct and proximate result of the fraudulent and Illegal Investment or Ponzi i,;cheme orchestra.teo by-ROTHSTEIN and as yet other unknown co-conspirators and-as a,.r.esult dfthe lltlgation tactics 267undertaken by-the Litigation Team and L.M a set forth hereH Plalntlff 267EPSTEIN has incurred and continues to Incur the monetary damages Including but lmlted to having to pay an amount in excess of the Civil Actions true value as a result of them refusing to settle In that a percentage of any payment by Epstein RRA.-et i Page30 I EPSTEIN have beeh promised to third party 267Investors incurring significant adgifional-legal fees and costs as result of Defendants refusal to conduct settfement nagotiatlons in a forthright and good faith manner be:cause any monies pa.lg by E.P T6tN ls In l"eSflty a promised r:etum on an inves.tme.nt and incur:red sighlflcant aftorM.eY,s Jees and costs In 267defending the discovery thi;rt not re.leva.nt rpa r:ial and/or calculated to lead to the admissibility evidence but Wnich was done for the 267sole.purpose of 273.pumping the case to Inv.esters fj TI;IN has al.so been Injured In that the scope oHhe fraud.ul nt and crimin tir raoRete:ering J;i.ctivJty perm ated the RRA flaw ilhn that EP TEtN has been prev ntea from fully and fah1y defending the clvll actkms brought against him In essence the very existen of RRA was based on the continuation of the massive Ponzi scheme orche_strated by ROTHS"fEIN and other co..:consplrator:s In order to contl.ntie-t brfhg-ln monies from Investors ROTHSTEIN and otherco-conspirator.s used tfte-,clvil Actions agalnst EPSTEIN along,wlth other manufactured law.suits as a-rrii:!ans ofobtalnlng m.ass v.e amounts.of money ROTHSTE:IN EDWARDS and L.M are fiabl.e for amages-causGdto-EPST.EiN lndividuafly and Jointly and severally fb-a ra lli..ti sAtt iA!ialt1 Uptnaranaa fts Plaintiff raalJeges and incorpora es paragraphs through a If fully set forth her.sin i i I i I f:pstliln RAA el I i RRA ROTHSTElN EDWARDS rid L.M each ana coffectlvely constltuta an I 267enterprise pursuant to Fla Stat ROTHST IN EDWARDS and LM engag?d In pattern pf crlminEil activity as 267:fl!3TffJed In and Fta Stat As allegetl ha:re1n ROTHST:E1N 267and 1;30WAROS commrtted.multJpl predicate a 267rnvlolation and a Stat1 lncluaing,violatlonsof Florida S.tatutes Ch pter relating to s.ecurltles ltan a Chapter relatlng to fra1;1dulerit practices false pretenses and fraud generally which Includes Chapter relating to forgery reJaUr:,g to extortion which noludt1s l.M and Chapter relating td perjury which lncluaas LM s,,ibstariHally mpre han two predlqate a ts l,t3 tne ell!ii.g of or participation of the i,al of 267fabricated settlements outlined erein irtc!tldint cthe 267Givn Actltms Involving Epstein as well trs the improp litlga11on tactie.s outlfn above occurred within a:_flve year:tlme perlott As a direct and proximate result of ROTHSTEIN EDWARDS a LM_.s V.io a119ns of Fla.-Stat EPSTE.IN has b:een 267injurecf Pursuant to Fla Stat Plaintlff-EPSTEIN ts en ttled to thr.eefoJd of 267his actual dama:ges sustained reasonable atto neys fees and court oosts and such other 267damages as allowed by law WHEREFORE Plaintiff EPSTEIN resp 267ectfully dern.ands the entry of a judgment for damages against atr the named Defendants Cuurit:II.-Flor.1ti 1cb Rgcketeo lnfruoncod:;aitd norhir?JF.Or.frariltntri:11l ct P.1,rstmntd 247ab5iO i,et-se:g filu afiist 9XmOaf f!rn1r;r I I i I Epstein RRA et al Page32 Plaintiff realfeges and Incorporates paragraphs through as If fully 267set forth herein RRA along with ROTHSTEIN EDWARDS ntj LM each arid collectively I During ali tllfles 267relevant hefefor R-OTHSTEJN EDWARDS and LM WrJrg and a.re associated with the enterprise RRA an each-Other a3 Defendants ROTHSTEIN EDWARDS and LM as persons asso fated with the enterprise RRA and 267each o.ther as an eliterprlset unlawfully cQnducted or participated dlrectly or lhclirectly In such an enterprtse through a pattern of ra:cketeering Fl itat as alleged above hereln The bre 267ildth and scope of OTHSTEIN EDWARDS and potentially L.M.s racketeering ctivi.ty continues to Investigated hy the FBI as numerous cMI lawsufts 267against some of the Defendants and others continue to be flied by persons wh0 have oeen df tnaged As of the fiilng of this Cornplalnti crlmlnal charges have only been brought against ROTHST.El!st Substa"htlall more than two predicate acts i.e the selling of faprlcated settlements outlined herein includlngJhe Clvil Actions tnvolvfng Epstein as well as the Improper lltigatron tactics outlined above occurred-within a five year time period Pursuant to Fla Stat ROTHSTEIN and EDWARDS engaged In a pattern of racketeering activity through the commissJ of crimes a defined In a Fla 267stat 1n 267ctuding Chapter relating to securities Chapter relating to fraudulent practices false pretenses nd fraud Including L.M generally I I Epstein RRA et al Page.33 fWV Chapter 267,.relafing:to for;gery relating to extortlon lncludlhg L.M Ch pter S7,.relatin f!b perJury incfuding LM Pursuant to Fla Stat Plaintiff seeks the following relief against Def n.daoiEi RQTHSTEtN,-EDWARDS and L-M a Ordering ROTHSJE1N 267and 267EDWARDS to divest them.selves of 267anytritet lh the.eliterpt!se RRA Enjoin al!,.Defendants from engaging in the same-type of conduct nd activities as described her.e!n:-and temporarily ertjcilnlng ROTHSTEN EDWARDS arid LM from the contlhuatlon of the Civil Actions brought agalhst EPSTEIN Uhtll cr.lmlnal charges have been formally brought against RRA and/or any of fhe Defendants such that EPSTEIN may be allowed 1o-evaluate whether a stay or dismissal of:all Civil Actions iagalnst.hlrn.is merited EPSTEIN further-seeks an award of his reasonable attorneys fees and costs and s.ucli o.th r-reliefthaUhis Courtdeems appro:prlate WHt:REFORE Plaintiff EPSTEIN respectfully demands the entry of a judgment for the rellef sought arid-dam.ages-against the named Defendants Cotintl Abuso of Procoss Atj in A_ ofondants Plaintiff realleges and incorporates parc!graphs through es if fully set forth herein i I Eps RRA ei al Paye34 After Instituting the civil Actions against EPSTEIN the ac ons cif Dsfanqants RD1HSTE1N EDWARDS 267and L.M as alleged In paragraphs tnrough herein constitute an illegal improper or perv rted use of process OTHSTEJN EDV ARbS.and L.M possessed ulterior.motives or rrp es in ie:xerslslrrg such.-1 gal,Atnpro_p_er or perverted use of pro As a resuft ROTHSTEINi EDWARDS and L.M.s actions EP:StEJN sutfered damages WHER FQ Plalhtlff.EP.STEIN respectfully nds the entry of a judgment f9r tiama,ges 267agalfist an the named felitfants Gou nt.lV FraUCf Against All Def en t:Janfs Plaiotiff realle-eJ and Incorporates paragraphs thro:ugh as 267fullY si;,t forth herein ROIBST by and through Defendant 267EDWARDS a LM mad.a false statem nts offaci to EPSTEIN and his attorneys and agents 267known to be 267false at the i:me made and/or lntentlona:lty concealed matetlai infomtatiol fro.m EPt?TEfN and lils attorneys 267and ag 267ents for the purpose of lnducing 267EPSTEiN to.act-in rellanGe thereon EPSTEtN did so act on the mtsrepresentaUowand/or concealment by incurring additional attorneys fees costs and expenses in 1;1ggressively defending the clvil actions Wlier;ea.s In reality because the Civil Actions against Plaintiff we.re being XP.loited-and over-Valued as to lure adqitlonal investors and attempt to extort as much money as possible from EPSf IN so as to continue the massive fr-aud i I I I I I I I I I I I I I i 267.Epsfeln V."RW et-al ia;ge WHEREFORE Plaintiff EPSTEIN demands Judgment against Defendants for dam.age Incurred and for any 9thet relief-to Which he:is eniitled under the law Against All Defelicfarils 267Plalntf realleges and Incorporate paragraphs through and and as if iftil!y set forth 267herein R01HSTEiNt EDWARDS and L.M oonspir dto comrrjit ft ad 267opon EPSTEiN ROTHSTEfN EDWARDS and LM combined by an through concerted aotion s.detailed herein to accomplish an unlawful purpose or accomplish me purpos by unlaWfUl,ma-ans The unlawful purpose was among other thing Alie orchestrating and continuation qf the ma sive fraudulent Ponzi s:cheme and r:eceipt of nies for the 225-contlnu 267ation of the scheme rhe unlawful.means includes but is ndi Omlted to the.use of th Civil Actions against EPSTE1N In an unlawful l1propar 267and fraudulent manner As a direct and proximate rasult of ROTHSTEIN EDWARDS and L.M.s consp1r.acy to defraud EPSTEIN EPSTEIN suffered 225damages WHEREFORE Plaintiff EPSTEIN demands Jud 247ment against Defendants for damaQes Incurred and for an_y other relief to which he Is entitled under the Jaw Jury.Ttla Plahitlff-dsrnands Jury Trial qn all Issues so triable By ROBERT,-J-CRITTON ESO I I Florida t;No I I I I I i i I i I J;tptt ln fmA,.et-at Page-36 i rcrlt bGf 2421aw.com MlGHAEL PIKE ESQ 267Flotldt:i e,at mplke b.1claw,ccom SUJ fy1AN li t;:bl_TTIER COLEMAN iBanyan lvd_.,J i.O.ta West Pa11n,U6ltch F.L Fax Attoma.ys forPlalntlfl i i I APP I Filing 243.:Filed ffl PM PiaintitiiCOt11itei Dcte11cfont vs SCOTT RdfI-ISTEIN individually BRADLEY 247DWARDS it1dividttally IN THE CIRCUIT COURT OF THE pf fTEENTHJI.JDICTAtCIRClJITIN NDl LM BEf CH C:OlJN"fY FLORIDA C:as CA AFFIDA ViT OF JEFFI EY EPSTEIN The undersigned Jeffrey Epstein having first been duly sv,;orn hereby deposes and ays afo dve1 eigl1 ecn yearn ql itricl hit ie pet;:imul Lioi iJeJge of the Tads stated fofrein I um the Counter Defendmil in the above captionectaction the Actloni and submii this Affidavit in surport of my Motion tor Summary Judgmenl ihe ummary Jt1dgmei1t ivlotion vllh respect to 267the Fourth Amended Cotinterciairn the Coui1teh:Jaim Cotinter-Pli11tiff Bi 267adley 267Etfaards Ect,tfrds In his Counterclaim Edwmds has a sole unsuppo1 claim agai lStme for fulicious rosccuti As mon fltll:i de cribcd beli.n at the 1i1e that comnier1ced the Action against Edwards and Scott Rothstein 267Rotbsiein in December I had a gClod faith basis for Ji ling d1,e same sedoi1 the tncts that existed nnlie time I filed suit as set for ii bclchv and.1norc ru11y i11ySimin1arY Judgi11ei11 Motio,i filed the Actioif agai11sLRoihstdn 267and Edwards becaUSI ba ed on he facts descdbed below and in the Summary Judgment Motion lbelie ied at the time of nling my original Com:piaii11 thtil these two ilidividuals nnd other unk110,vn partners of tbeirs at Rothstein Rosenfeldt Adler.f.RRA engaged in serious 1isconductin,1olvi11g a widely publicized illegal Ponzi cherne opelated through their law finn the Ponzi Scheri1e that featured the ve11 civil cases litigiited agi1inst meiby Edwa1ds which.were being used to defraud potential investors in the Ponzi Scheml In arly Noven1bc stories in ihe press on the ws and on the it1tetnet Vere legiOii about.the hfrplosjoil.of RRA the Ponzi Scheme perpetrated at that firm and the misuse in the Ponzi Scheme of.certain civil cases then being litigated against me by Rfu pnrtn Ed,xartjs the cqses Ecl va.rds was litig ting against me ihichi1re scdbedi11 the.SunurniryJudgiue11t 1otio:n the Epstein Cases were being used to defraud inveslorsoulofmillions of dollars ind to tlind ihe RRA P6i1zi Scheme fh November I also became aware of news stories thaLas a result of the Ponzi scheme al RA the florida Bar had commencecUnvt.sligat1011 intll over one halfptthe attorneys emplt1yed by RR.A At 6r nbt ii lhc sufrie tifoe fo No 225.Jenlbcr200 Jalso faccafoe that the law firm of Conrad Scherer tiled a Complaint against Scott Rothstein and others hereinafter retere11ced as tbe 267Razo1:back Co1plaint on behalf of sonie of the Pori Scheme invesioi Upon re 225iewing the Razorhflck Complaint arned that the _Razorback Co1nplainrdetaileti the itse.of the Ej Stein Cases Le the cases being itigated against me by Edwnrds lo defraud investors in the Ponzi Scheme but no limited in1prope1di_scoyery practices iirid other nlethoJs lo bolster thecases I Prior to my fili!1g the initfoi 242omplnint inJhc Action lalso bi:came aw lt thnt the Federnl gi ienifocnl filed an Information against Senti Rothstein which included allegalions ofRRA ns an Enterprise in whi Rothstein and his yet unidentified co conspfrntors engag a n1cketeering conspiracy lOJlC tnundering COlispiracy 11iail a11d iie frfo.id to11spiracy und wire fraud and specifically alleged that a potential inyestors were defrauded by RQthst in nni.l oth co.conspirators who folsi::ly advised that confitlenlial settlement 267agreements were available Jm plirchase wheff the scttlei nt agreements offeied vere fabricated the fabricated settlements greements were allegedly available in amounts ranging from hdndi-eds of tI-io 1sands nf doll rs to millions dfclollar mJd could be purchased at a discount mid repaid to tile ln,:.es!tm a lace alue e1 tinie R6tlistehi uhd 6ther ccH:o,ispirators utilized tbe offices of-,RRA and the offices of oiher:co-conspirritors to convince potential investors of the legitimacy of the and success of the law firms wliich enhanced the credibility of the purported investment opportunity ln hese fictitious Si!Hlements R.othstein a.nd other co coqspirutors LitilizeA ftfadS obtni LfUouglf tile P01izi Sche1 to stipplei1ierit a11d supjJorl the oRenition mid activities of RRA lo expand A 1heJ1ing of additional ahornt!ys.nnd support stall Id fund llaries and bonuses.;a11d lo acquire largciat1d more elaborate office space and etjitipnienL i116rdei Ill eifriclithe pei;sonal iillh or 11ersonse1i1ploye by imil ifasociated I I Prior to filing the initial Compltii1lt in the Action msistenL with the allegaLiuns mmle by the press in 267the Razorback Complaint and fa the Rothstein fnformation it was clear lliat the activity in the Epstein Cases being litigated by Edwards i11tensiffed substantiaJly during he short six _months durii1g which Ed,vnrds was a paruiet at RRA ifom April through the end of October Fwthermore during tfmt six mo!1th reriod qu tionable disc9:,reiy like that detalled in the Razorback C61plaint had takei1 phice,iil the Epstein Cases being litigated against me by Edwards including Edwards noticing the depositions of fan1ous dignitaries and celebrities such as Bill _Clinton and bavitj C.oppelt1eld Hm evei the plnintffts in ti1e1 Epstein Crises ind made no allegations ofimpropei conduct gainst themirnplkating any celebrities or tjignitaries Equally consiste1 with the allegations in the press and the Razorback Complaint.that the Epstein.C,ises 267werebeing:defiberately misused tor purposes unreiutc Lo thelitigation i 6r lef.t6 lure in iesti.m intli the Po 267nzi Sclk1e is the fact tharon July.24 Edwards filed two hundred chiny-four page one fitry six count 267federal complainlagainsi on belrnlfof plaintifr:,LM.for Yihom Edwards was already prosecuth1g i case against n1e in state couit jhyi lvipg the smi1e 1atters alleged in tl1e tedcral coni1llaint The complai11L was filed in federal cliurt hut Was never ei ea on 1e prosecuted le.ading nfo to conclude tlmt the only reason it was filed wusfo enhance the case files shown at the oft1ces of RI A to potentiuHnv1;stors ii th lonijScheme Alsqwhilc a partner at RRA Edwards filed a motion in Federnl court in which he requested thai the coun ordenne 1opost a tilieen million dollar bond in the Jc1e Di,e ease This case according io the Razorback mplaint 1s being touted at that same ti1e to testcin;ii1 the Ponii Scheme In ctimiection 225ith that motion t.dwards filed papers discussig my iet vorth itn filed supplcmenfalpapers purporting ro list in great detail my vehicles plaiies uhd tither iteins orsubs antial value all at a lime when according to the accounts in the press the lnformatio11 nnd tl!e knzorbm:k Con1plnfot the Ponzi Schcnfo was unraveling and hence for new Investors In ihe Ponzi Schemewi1s becoming urgent The courtrejected the Motion cuiling ii dcvoid if cvir.lcncc The facts set forth nbo and in tlfo.Sui1i1ary Judg1freM Motioruvere the facts upon which I relied in a determining that l1Ud_ h1cU11ed damages such as attorneys fees anci disbursements puid to dcfen against abtish 225elitigrition pi 225i1ctices which qppeare to be fofrelrited to the underlying litigation against me and asserting my causes of action agninst Ecl vurds an Rothstein in.th Actkm FURTHER AFFIANT SA YITHNAUGHT JEFFREY EPSTEIN STATE Of NEW YORK ss COUNTY OF NEW YORK Swornand subscribed_ tobcihre me the lin lcrsigned authority by Jeffrey Epsteit1 dh thisJune HABIBE AVDIU N.OTARV PUBLIC-STATE OF NEW YORK No Qualad In Richmond counry MV Commission Expires October 2oio APP IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendants/Counter-Plaintiffs I VOLUME I VIDEOTAPED DEPOSITION OF BRA:DLEY EDWKRD Taken on Behalf of Plaintiff Friday Novernl5er T0TII;J Z0T7 a.m p.m Palm Beach Lakes Boulevard West Palm Beach Florida Examination of the witness taken before Sonja Hall Palm Beach Reporting Service Inc Palm Beach Lakes Boulevard Suite West Palm Beach FL Palm Beach Reporting Service Inc 0J TI TI TI discovered that there were high-profile witnesses onboard Epsteins private jet where some of the alleged sexual assaults took place and showed D3 the potential investors copies of a flight log II Right A Yeah purportedly containing names of celebrities dignitaries and international figures A Right Did the flight log in fact contain names of celebrities A Epsteins flight log does contain names of celebrities Those are the people he hung out with so A A And dignitaries Whats the definition of dignitary I think Good enough for me And international figures Yes Sp Ener:e is Er IEn CE!lli1 RoEnstein is weaving IIT 15ased on ocuments CE flig log CE!lli1 was obtained QY as CE lead trial lawyer in CE J5:encl.ing lawsuits Tne"r:e is Er IEn in CE pendTiig _lawsuits cc saving CE!lli1 wnat RoEnstein was Palm Beach Reporting Service Inc C2 CD IQ QJJ ru CD Q3 doing we a actual eyTiienc"e ill fa15ricated story And QI actual eyTIJ_enc"e was rgferred cm a Ene"s"e flig logs as QI lawyer obtained and broughd bacK cm QI RoEnstein firm rignE maintain QI eyTIJ_enc"e CK aTl Q1 cases aI QI RoEnstein firm Wne"r:e 247rKeci Tnat":;s was coITf irming Does CTI RoEnstein gained access cm CTI and used CTI cm IT fairytale do:e:s does rignE And _gi with El"l"a":Q A So paragraph Yes In this case Razorback this is not Mr Epsteins suit right This is Bill Scherer representing the Razorback client that he represented suing Rothstein is making these allegations A A Yes Right Okay So Mr Scherer do you know Mr Scherer I know him now better than I did then I didnt know him at all then Palm Beach Reporting Service Inc underaged women were onboard There were underage women onboard Epstein knew that So he knows this to be false And no elicit activities took place Epstein knows elicit activities took place on his airplane so he knows that to be false He cant just adopt what Bill Scherer says and say Oh that forms the basis of something I believe It cant possibly form the basis of what he believes because he knows it to be false Ol ay Sp ia Tiyj QI El clients QJJ represented n.TTe were RoEnstein testifiea Eney went on Epstein plane CD TneyJ DQt El Eney DQt con Q3 _Epstein plane Tney were DQt QI victims on QI CD plane CTI Sp QI clients represented I ina.IviauaTly nTTe I QI RoEnstein firm Y.our El clients testifiea or aami ttea EneyJ never QJD travelea on Mr Epstein plane correct CIT Eney testifiea fi ffnfITTiy,J EneyJ 247ula 0J El1 i"g onT remember il Eney were s:Keci question sure A But you know the question is I do know the answer to that question for Palm Beach Reporting Service Inc the many topics that amongst plaintiffs counsel we discussed as the way in which Epstein intended to ultimately defeat these cases which would ultimately prove his serial sexual molestation of minors BY MR LINK evidence A was true A So is your concern something thats And we had a source telling us our concern I understand Okay so have heard aDQt source am as:J.cing Q3 aDQt ey:Ta.ence:J CTQID tora me had concerns CD OJ.cay on:U federal Gude cares aDQt CTI personal concerns ou15J federal udc cI1 cares have source wno wooJ Cg on cm QJD Gill wnenever have fTTed motion Cf junction intend ey:Ta.ence on in front Q1 0J court And CJID as:J.cing wnat ey:Ta.ence ll id Enis federal proceed_yig prove statement pstein was fraudffl transferring assets overseas MR SCKR0LAJ Excuse me CJID going Palm Beach Reporting Service Inc Qfil:g:gjj Counser peectl alSQITf Counser experience CTI stricReri:J Ana QI question as wnat 256Tiience ia tMD Eawaras have C2 MR 1/INK MR SCKROLAJ E3 is a question CZ 15een a"sKeci ana answered 1repea tea.lv filX MR 1/INK Sp wQITla agi haa no acl.missibl"e IQ 256Tiience aI time ITleci Enis pTeacl.Tiig1 QJJ Rola on one secona S,o Yes sir:J CD Enis is 256Til.ence:J Q3 Wnat CTI CD request Cf aamission a"sKeci CTI _Epstein aam are moving financial assets QJD overseas outsia.e Q1 QI irect territorial ac:n Q1 QI ill ana FlorTa.a courts Question ll were a:Ring asset ll transfers with QI intent e:feaf ITyj Gua.-gn it _e_n mig entered against in Enis case or simir cases Twentv-tnree currentry have QI Palm Beach Reporting Service Inc C2 CD IQ QJJ ru CD a:5TlIEY TS TTlTon satisfy Guo.qi_ ill Enis case wr_EfiQf financial or CO:-Elier ca.rffTculTv Ul-FmllQ CIT tola EIT fi fflQ IT wQITla Ana EITI rs wnat EIT aaverse ference requirement aTl:o ff draw IT in response Eno"s"e direct requests ff aamissions EITI llwol illI Frftn Arnencl.menf rig against SeTf-incrimination WfiTcn rs tantamount an aamission S,o i:S 256TIJ.ence ORay S,o EninK EITI EIT aaverse ference Tfiat":;s going pQ in Enis Hang on Let me just make sure I understand You thought when you filed this that having an adverse inference to a question whatever question you asked because he raised the Fifth makes it an admission Thats your understanding of an adverse inference in federal court A I had an admission by Mr Epstein in response to his question That was it You told me he pled the Fifth and didnt answer All Im asking is was it your Palm Beach Reporting Service Inc for identification BY MR LINK And this is a memo from him to you copying Marc Nurik Marc Nurik was a lawyer at Rothsteins firm A One of the criminal defense lawyers And its references Mr Epsteins non-prosecution agreement A Thats what it looks like And it looks like its a message from Mr Adler to you Says Brad Wayne Black and I just had a great conversation with Marc Nurik about the non-prosecution agreement and I need you to please get in contact with Marc and meet with him to discuss the possibilities Bring with you a copy of the agreement Next sentence says We also discussed the assets situation and there are some major possibilities that need to be explored with Marc and others Get on it exclamation point twere reporting AaTer in represent Ellrge Rotnstein c.lients E3 Ellrge Tacl_Tes on prosecute Epstein matters WeTl::;J Enis email is atecl A:pril 2ff0 so Palm Beach Reporting Service Inc C2 CD IQ QJJ ru CD Q3 CD cm I em 0J TI aa cstartectJ I QI tirm:J aa Enere:J Aa.Ter one QI only lawyers naa Rnown fQr years be:E Cg QI firm:J AQd Aa.Ter hano.Tecl sexual aJ:5se cases SQ especiarly ill QI 247ginning EaTKeci alSQIT:E Rina naviqhl Enrough QI complications wi tfi CJ:e:r pstein ana with QI defense was oing on:J S,o Enis appears Wayne Blacq ITd Aa.Ter Wayne was investiq4t_fuj Eney were EaTRing alSQIT:E wnat we neecl.ecl d,o ill QI investigation Yea:tI was et ini tel;_y in vol vea Efien:J He Til.nJ mucfi in QI ay-to-a.ay so on"J want anyfning El1 i"g ITna.erstana.::J GCJID EaTRing alSQIT:E QD1 ARDJ filh Zff0-9 CTI loo me lil fie qi ving Y.Qill instructions QD1 wITI d2:J Y.Qill agree NQt qiving me instructions on wnat a ffil"lBq bring Marc NurTK QI non-prosecution agreement is QI instruction CIT anyfning we are 247rRing EQgeUier wi tfi QI Common qoal A The get on it exclamation point Were buddies Then we were just friends Get on it is lets do this Palm Beach Reporting Service Inc A Sarah Kellen was on the airplane with Jeffrey Epstein and an underaged girl Jeffrey Epstein makes the allegation in the complaint that the proof that Brad Edwards was pumping a Ponzi scheme is that he sought flight logs despite knowing that there were no underaged girls on the airplane Jeffrey Epstein knew that to be false because there were indeed underaged girls on the airplane To the extent that Jeffrey Epstein himself wont say that I knowingly filed this false allegation Sarah Kellen could say I know that Jeffrey Epstein knew that that was a false allegation because I too was on the airplane and so was this underaged girl and he knew that So at the time that he filed this complaint he knew that it was false the allegations that he was making which allegedly formed the basis of his assertion that I was involved in a Ponzi scheme A Okay You lost me but Im not going Read it back I think it makes sense Im not going to try to figure that out D:o anyone Dlli1 Q_ testify aDQUE wnat was ill Mr Epstein mina in Decem.15"er Zff0-9 I Palm Beach Reporting Service Inc QI time QI lawsuit was fiTecl aJ5Quf wny fiTecl II tMD pstein testifiecl Ell"a"Q Otner Ellan MD pstein have ill witnesses are going testify aJ5Quf QI reasons w!IY MD pstein maa.e QI ecision fire QI _lawsuit very 615vious wnyJ fiTecl QI _lawsui IQ 243Qill CT Qfner witnesses Qfner Ellan QJJ MD _Epstein correct have attempted IT attorney"E eposi tions ana Eney have ectea Q3 opportuni tv S,o IT no witnesses can testify CD as fiat was in fil mina I time cm CQ I riglrr em 243Qill are plaintiff in QI counterclaim We will see Enis mTola:"J C52lrr me wrap Enis because have gjj information wnich EninK are nJ simplB questions D,o witness will_ ll testify Qfner tMD pstein aJ5Quf fiat was in IT Tild ill December Zff0-9 aJ5Quf wlfy broughd QI _lawsuit MR SCKROLAJ Direct 256Tiience or Palm Beach Reporting Service Inc C2 CD IQ QJJ ru CD Q3 CD circumstantial exTiience or botn 1ill WITNESS a me EninK aJ5Quf E!iI question AJ5Quf wny IT broug EQ lawsuit Sp Ci fical1cy Ell"a"Q MR 1/INK Can reaa bacK EQ question Cf him please wooT ta E!iI as co"acning I TI ill ITyj event werl one onT Eninl Can CTI bacR Tnereupon EQ requested portion Q1 EQ record was bacK EQ reporter as fily recora.ea.7 WITNESS witness QEner Enan Mr pstein no BY MR LINK Thank you Why was Bill Berger added to the witness list last night A myself You will have to ask somebody other than Do you know what Mr Berger why hes listed as an expert in this case A Again thats a question for the lawyers Do you know when Mr Berger agreed to Palm Beach Reporting Service Inc CD cm I em 0J TI TI TI federal action have anything to do with any factor other than those that you have just described the potential expiration of the statute of limitations and your desire to take advantage of the provisions of the non-prosecution agreement as a potential alternative to the state court claim A That is the only reason that we filed it at that time Did Scott Rothstein have any role whatsoever in that decision-making process A He never had any role in any decision-making process with anything to do with any of these cases so no Dia become aware Q1 Dlli y_our ffipstein-relaTecl fires point in time naa been requested QY S:co:-rr RoEnstein ia become aware EnaT EninK tMIl tow me tFisten:J S:co:-rr RoEnstein wanted see Dlli Epstein-relaTecl ITles il Ell"e"s"e cases went cru trial IT wanted ITy Dlli cases wi tfi me:J HB no Palm Beach Reporting Service Inc A HE S,co:-IT RoEnstein wanted ITy QI case Wl ffi me Tnaf:;s QI explana ion WaS giY And was there anything suspicious about the head partner in the firm telling you that in this high-profile case he wanted to be part of the prosecution team A No If my associate brought in a high-profile case right now I would be the one to try the case despite the fact that she may be the only one who knows anything about it So theres nothing suspicious about that A Files got returned to you Yes files did get returned to me And was there anything about the request for review of the files on the basis that Scott Rothstein was considering participating in the prosecution of those claims that aroused any suspicion on your part A No Was there anything else that went on in the short period of time that you were in that law firm that gave any cause for you to suspect that your files were being used in any way directly or indirectly in connection with any illegal activity of any kind Palm Beach Reporting Service Inc I was told that he was going to try the case with me Period Not more than not less than that Thats just it Not be the lead not be the second not be the third Just try the case with you A Thats what I was told And that was okay because he was head of the firm and he owned the files right A Correct CTQID were an employee in Y.our mina ana ill QJJ was Tilli lawyer Ultimatery Tilli firm responsibTe fQJ Tilli El clients CD Tnere:s seventy lawyers Tilli firm Tney Q3 TI ff filQ Huriarecis ITl::e:s He sJTTl 251ill CD eguity partner Tilli firm so Eney are Tilli firm:s CTI ITl::e:s Tney are una.erstana CTQID tord me earlier Ana Tan:U feal-:r:z:e Enat E!f1 Tilli interest E!f1 Brao.ley Eo.wara naa in El ITies iJ1Ll RoEnstein ana became salary nployee nJ essentiaily A A Gave RBKJ Mr RoEnstein firm correctj RignD tweYe ee:;s:EaoTisnecil 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