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Epstein Release Interview Victim Statements Evidence Maxwell
← Back to Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct. 2009)
Extracted Text

Inc on Behalf of Naples Syndications LLC Chaluts So 3d Fla 2d DCA citation omitted To rule on a motion to dismiss a courts gaze is limited to the four corners of the complaint including the attachments incorporated in it and all well pleaded allegations are taken as true U.S Project Mgmt Inc Pare Royale Dev Inc So 2d Fla 4th DCA citations and quotation marks omitted All reasonable inferences must be construed in favor of the nonmoving party Jackson Shakespeare Found Inc So 3d Fla After nearly seven years days or six years and seven and a half months Rothstein belatedly surfaces for the first time through a filing which was not made by Rothsteins own counsel but was made instead by Jack Scarola counsel of record for former co-Defendant and current Counter-Plaintiff Bradley Edwards Notwithstanding who may have actually penned the Motion in Rothstein name the Motion is premised on the specious argument that the operative complaint fails to properly plead the elements of civil conspiracy to commit abuse of process because Epstein does not allege with whom Rothstein entered into an agreement to commit the tort of abuse of process Rothstein also argues that Epstein has not adequately pled damages necessary to sustain a civil conspiracy claim As is readily apparent from even a cursory review of the Second Amended Complaint Rothsteins arguments have absolutely no merit and should be summarily rejected The elements of a claim for civil conspiracy are a an agreement between two or more parties to do an unlawful act or to do a lawful act by unlawful means the doing of some overt act in pursuance of the conspiracy and damage to plaintiff as a result of the acts done Epstein filed the operative Second Amended Complaint on August under the conspiracy MP LLC Sterling Holding LLC So 3d Fla 3d DCA emphasis added citation omitted Rothstein does not argue that Epstein fails to allege the core elements for civil conspiracy Rather Rothstein frivolously advances dismissal on the grounds that the operative complaint fails to identify the alleged other party to the agreement Mot at But Rothstein fails to point to any case law and despite an exhaustive review the undersigned can find none which requires a plaintiff to expressly identify the co-conspirator by name This is because Florida imposes no such requirement Furthermore even if the law requires an allegation that one or more parties other than Rothstein are involved the operative complaint more than sufficiently alleges that Rothstein did not act alone in the conspiracy Nonetheless Epstein has alleged all the required elements to adequately plead a cause of action for civil conspiracy It is undisputed that Rothstein engaged and had an agreement to engage in a Ponzi scheme with others and Epstein was damaged by the acts done by the conspiracy For example in the Introduction of the Second Amended Complaint Epstein summarizes his allegations in pertinent part Through the law firm of Rothstein Rosenfeldt and Adler P.A RRA Rothstein and others in this criminal enterprise conducted a billion Ponzi scheme which was perpetrated with fake agreements forged signatures and a fundamental corruption of the many legal protections that the legal system has in place By claiming to be engaged in what was essentially legal extortion Rothstein persuaded investors that he could pressure defendants including Epstein into paying astronomical settlements and further defrauded investors by convincing them to purchase fake interests in assignments of fictitious structured settlements including those falsely claimed to have been reached by RRA for Edwards clients with claims against Epstein to the detriment of the Plaintiff The United States government has stated that Rothstein conspired with others to use RRA as a criminal enterprise to conduct a racketeering activity including mail and wire fraud money laundering and conspiracy Second Amended Complaint pp emphasis added The Second Amended Complaint also contains specific allegations of the conspiracy Rothstein conspired and entered into an express or implied agreement to engage in the tort of abuse of process as part of a plan to defraud investors and further the Ponzi scheme Rothstein knew or should have known of Edwards efforts to make illegal improper and perverted use of the civil process The actions described in paragraphs through and through constitute overt acts in furtherance of the conspiracy As a result of the conspiracy Epstein has been damaged by incurring additional and unnecessary attorneys fees and costs and the cost of installing an enhanced security system and retention of security personnel for the safety of Epstein and to protect his property Second Amended Complaint i,i In its own Complaint the Government alleged that others in Rothsteins firm were co conspirators and it is an indisputable matter of public record and knowledge that Rothstein had guilty co-conspirators In fact there is easily ascertainable public news that at least four others pled guilty Epstein properly alleged there was a conspiracy to engage in a Ponzi scheme between Rothstein and others at his firm and nothing in Florida law requires Epstein to name any of these individuals or anyone else in order to civilly sue Rothstein for his criminal and destructive Public news sources reported that Howard Kusnick of Tamarac Stephen Caputi of Lauderhill William Corte of Plantation and Curtis Renie of Fort Lauderdale were expected to plead guilty to one count of conspiracy to commit wire fraud in o-conspirators-set dates-for-guilty-pleas-6452603 behavior Epstein is not required to prove anything at the pleading stage Nonetheless Epstein did name others who were involved in the abusive litigation tactics RRA employed a team of investigators on the Epstein Actions including Michael Fisten Fisten and former Broward County Sheriff and convicted felon Ken Jenne Jenne Fisten and Jenne were the primary investigators assigned to Edwards and routinely reported to Edwards and Rothstein regarding their investigations of Epstein In October Rothstein directed Edwards investigative team to bring case files into a conference room at RRA to be examined by potential investors Then Fisten and Jenne brought in the case files for the Epstein Actions which numbered as many as nineteen boxes Although Edwards has given sworn deposition testimony that only a few attorneys employed at RRA were directly involved in the prosecution of the Epstein Actions a privilege log prepared by Edwards and other documents clearly reflect that more than eighteen RRA lawyers were involved in prosecuting the Epstein Actions Additionally four RRA investigators and several legal assistants and paralegals were involved in the Epstein Actions On multiple occasions and in contrast to Edwards sworn testimony many RRA attorneys conferred and were involved with the prosecution of the Epstein Actions described in detail in Second Amended Complaint Beginning in October the level of communications by and between Edwards and others including Rothstein described below increased dramatically as Rothstein was running out of money and was in search of new victims in order to continue to perpetuate the Ponzi scheme and coincided with Rothsteins efforts to get the investments for the Epstein actions concluded described in detail in Second Amended Complaint Second Amended Complaint r,r In addition Epstein alleged that Rothstein pied guilty and ultimately was sentenced to a 50-year prison sentence for fraud and racketeering based on an alleged billion Ponzi scheme designed among other things to infuse funds into RRA his own pockets and those of his cohorts Second Amended Complaint Based on the allegations in the Second Amended Complaint taken as true and together with the inferences drawn from them in favor of Epstein a trier of fact could find that Rothstein and/or members of the Rothstein firm conspired and entered into an express or implied agreement to engage in the tort of abuse of process as part of a plan to defraud investors and further the Ponzi scheme a finding that encompasses the first element of civil conspiracy which Rothstein challenges Rothstein also argues that Epstein has not adequately pied damages necessary to sustain a civil conspiracy claim Mot at Epstein however did plead damages in paragraph as quoted above and in paragraph as follows As a result of the above the Plaintiff has suffered damages by incurring additional and unnecessary attorneys fees and costs to defend these abuses of process In any event Epstein is not required to plead those damages and a general claim is enough Hutchison Tompkins So 2d Fla It is well established in Florida that where the allegations of a Complaint show the invasion of a legal right the plaintiff on the basis thereof may recover at least nominal damages and a motion to dismiss should be overruled Petitioners failure to allege specific damages does not foreclose them from attempting to prove See Second Amended Complaint at general damages at trial General damages that is those damages which naturally and necessarily flow or result from the injuries alleged need not be specifically pleaded citations omitted Therefore it would be inappropriate for the Court to decide damages in the context of a Motion to Dismiss Importantly when Edwards moved to dismiss Epsteins Second Amended Complaint this Court found that the damages alleged were sufficient to survive a Motion to Dismiss Specifically in August through the same counsel who filed the instant Motion Edwards moved to dismiss claiming among other things that the Second Amended Complaint fails to articulate a cognizable theory of damages proximately caused by any wrongdoing on the part of Bradley Edwards Edwards Motion to Dismiss Exhibit A Those damages incurred by Epstein to defend against the abuse of process alleged in the Second Amended Complaint are the same damages pied by Epstein to have resulted from Rothstein civil conspiracy This Court previously rejected the arguments that those damages were inadequately pied and denied Edwards Motion Exhibit This Court should again reject the same arguments which are no more persuasive now than they were when filed seven years ago on behalf of Edwards The Underlying Tort of Abuse of Process May be Discerned From the Operative Complaint Epstein has stated a cause of action for civil conspiracy based upon an independent tort specifically the tort of abuse of process In the operative Second Amended Complaint filed on August Epstein alleged the underlying tort of abuse of process both in general allegations and specific allegations against both Edwards and Rothstein The elements for abuse of process are that the defendant made an illegal improper or perverted use of process that the defendant had ulterior motives or purposes in exercising such illegal improper or perverted use of process and that as a result of such action on the part of the defendant the plaintiff suffered damage I Investments Payless Flea Mkt Inc So 3d Fla 4th DCA In the General Allegations of the Second Amended Complaint Epstein alleged that in Rothstein pursued a criminal course of conduct which included a scheme to defraud investors into purchasing fake interests in assignments of fictitious structured settlements by showing them boxes of case files in the Edwards cases against Epstein which high dollar settlements were falsely claimed to have been reached by Rothsteins law firm on behalf of clients Second Amended Complaint The purpose of the fictitious investments was to enrich Rothstein along with other members of RRA and others to sustain the law firm and raise capital Second Amended Complaint Epstein plainly alleged that Rothstein and others in his firm many of whom have pied guilty to federal crimes were pursuing this Ponzi scheme Id at In fact one need only glance at the twenty-eight paragraphs of General Allegations of the Second Amended Complaint in order to glean the abuse of process by Rothstein and others Rothstein employed a team of investigators approved litigation costs of to on the Epstein actions to advance the massive fraud on investors assembled investor groups including to review the Epstein case files in a conference room Id et seq In short the Epstein case files were being shown and touted to investors for Rothstein to close the deal with the investors particularly here the magnitude of the potential settlements in the Epstein Actions was a key selling point Id at Therefore the elements of the tort of abuse of process can be perceived from the Second Amended Complaint Rothstein also appears to argue that his illegal Ponzi-scheme activities are protected by the litigation privilege because three cases that were part of his Ponzi scheme were actual pending cases against Epstein Such an argument is absurd on its face The litigation privilege is not an absolute bar for any act occurring during the course of a judicial proceeding Rather acts that bear no relation to and are not in furtherance of the proceedings do not have immunity Levin Middlebrooks Mabie Thomas Mayes Mitchell P.A United States Fire Ins Co So 2d Fla SCI Funeral Services of Florida Inc Henry So 2d Fla 3d DCA nothing that a cause of action for malicious prosecution is not barred by the litigation privilege The Second Amended Complaint identifies numerous instances of conduct by Rothstein outside the parameters of the litigation privilege Edwards likewise raised these arguments in his Motion to Dismiss Exhibit A The Court however disregarded those arguments and found that the allegations in the Second Amended Complaint were sufficient to plead a cause of action for abuse of process against Edwards Exhibit The Court should similarly find that the allegations are sufficient against Rothstein as well Dismissal with Prejudice is not Warranted Lastly even if for some reason this Court should find merit in the claim that the Second Amended Complaint fails to state a cause of action for civil conspiracy dismissal with prejudice would improperly deny Epstein the opportunity to allege additional facts to support his cause of action something which should be denied only where the privilege to amend has been abused See Gamma Dev Corp Steinberg So 2d Fla 4th DCA Leave to amend should be liberally given and a dismissal with prejudice is not proper unless the privilege to amend has been abused or it is clear that the pleading cannot be amended to state a cause of action Here Epsteins Second Amended Complaint was filed in response to the Courts Order granting Edwards Motion to Dismiss the Amended Complaint and giving Epstein leave to amend Rothstein argues that Epsteins year delay in pursuing his purported claim against Rothstein has resulted in unreasonable and undue prejudice Rothstein himself however delayed moving to dismiss or taking any action in this case during the more than six years the Second Amended Complaint was pending although his counsel was copied on all court filings Furthermore Rothstein did not articulate what undue prejudice he has suffered This Court has now determined that Epsteins claims against Rothstein and Edwards claims against Epstein will be tried separately In a case such as this one therefore it can hardly be found that Epsteins request to file a Third Amended Complaint should the Court grant Rothstein Motion would in any way be abusive To the contrary Rothstein moving to dismiss more than six years after the Second Amended Complaint was filed through Edwards counsel as a means to open issues so the claims could not be tried together is the only abuse that has taken place Rothstein and Edwards should not be rewarded for their own abusive tactics by dismissing the Second Amended Complaint with prejudice without leave to amend CONCLUSION Based on the foregoing Plaintiff Jeffrey Epstein respectfully requests that this Court deny Defendant Scott Rothsteins Motion to Dismiss While the Court granted Edwards Motion to Dismiss the Amended Complaint it gave Epstein leave to amend to plead with more specificity Epstein did just that and the Second Amended Complaint withstood Edwards Motion to Dismiss directed to it CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on July through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration Jack Scarola Karen Terry David Vitale Jr LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Philip Burlington 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 dvitale searcylaw.com scarolateam searcylaw.com terryteam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards West Palm Beach FL pmb FLAppellateLaw.com 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 Co-Counsel for Defendant/Counter-Plaintiff Counsel for Defendant Scott Rothstein Bradley Edwards Jack A Goldberger Paul Cassell Atterbury Goldberger Weiss P.A University Australian A venue Suite Salt Lake City UT West Palm Beach FL cassellp law utah edu goldberger agwpa.com Limited Intervenor Co-Counsel for L.M E.W smahoney agwpa.com and Jane Doe Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Jay Howell Jay Howell Associates Cesery Blvd Suite Jacksonville FL jayhowell.com Limited Intervenor Co-Counsel for L.M E.W and Jane Doe EXHIBIT A JEFFREY EPSTEIN Plaintlff vs SCOIT ROTHSTEIN individually BRADLEY EDWARDS1 indivldually,and L.M indivldually Defendant support thereof would show I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE ARDS moves this Honorable Cqurt to im for failure to state a cause of action and in Second Amended Complaint is nothing more than conclusory surplus ge nt intended to defame Edwards under the protection of the litigation privl1 i for the filing of a fedeml complaint that did not name Epstein and was app served on him the Amended Complaint fails to identify the Clprocess alleged to b.e on whom it Is claimed to have been served or when it is claimed to have been servedi Paragraph oftbe Second Amended Complaint referenc6s a federal civil action with which Edwards was never served Prosumably,_since the complaint is alleged to have been filed by Edwards the allegation was meant to have referenced J3psteht rather than Edwards Edward ndv 1!:pstcln Edward Motion to Dismiss Second Amended Complaint C11se No JOXMDAG the Amended CQmplaint fails to articulate a cognizable theory of damages proximately caused by any wrongdoing on th.e part of Bradley Edwards the Atnend Compluint fails to identify any conduct outside the pro litigation privilege whioh could give rise to a_ny.Jiability on.the part of Bradley all legal arguments and authorities as contained in the previously filed Motion for Summary Judgment end Motion to Assort Clalm lt!ve Damages are incorporated herein by reference WHEREFORE BRADLEY EDWARDS de issal of the Second Amended Complaint against him I HEREBY CERTIFY that a true of the foregoing has been furnished by Fax and U.S Mall t.o all Counse Scarola Barnhart Shipley each Lakes Boulevard Beach Florida Fax Attorneys for BRADLEY EDWARDS Edwards all Epstein Edwards Motion to Dismiss Second Amended Complaint Case No COUNSEL Ll Martin Weinberg Esquire Martin Weinberg P.C Park Plaza Suite Suffolk MA Phone Fax Jack A Goldberger Esquire Atterbury Ooldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Phone Fax Fanner Jaffe Weissing Edwards Fistos Lehnnan,PL Andrews Avenue Suite Fort I:.auderdale FL Phone Fax Mnrc Nurik Esquire Lnw Offices of Marc Attorney For Scott Roth Ono Broward Blvd Fort Lauderdale FL Phone Fax Josep Esquire Fow ett P.A A Epstein est ve ach FL EXHIBIT IN THE CIRCUIT COURl OF lHE RITEltNTH JtJD1CIAL cmcuIT OF FLORIDA IN AND FOR PJ LM BEACH COtJNTY CIYIL DlVJSION CASE NO AG JEFFREY EPST.ElN Pliuntiff VB SCOT ROTHSTEJN etc et al Defendant THIS CAUSE c.ame before the Court The Court revlewcdJhe Second Amended Compl I the Plalntlfrs Response ci other Memoran urns filed rv"d August ndants fotlon the Motion The Court lias also re ewed th t!ea cited by the parties Based upo review of the Ye a ell a fin erwise ully advised in the prernlses It ls i CONS.IDEREO OR fE YOJUDGED as ro lows lt is ll eptabliahed oHo to Dl mise that thJe Co ls llntited_ to review of the four comers of plafut and the well pied allega:Uona therein A Motion to Dismiss for failure bite iie of o.otion:a ita 267well pled facts in the Complaint and reasonable me horefrom and the allegations must construed in thtflight most fav rab l1 265ntlff Applying this standard to the four ome a of the Complaint filed by tiff th Co rt nds th he atiegatlons IUe suffic to pl a cnuae bi action for a use of process against the Defendant 267EDWARDS Tht ov.erwhelming I majority of the Plalntlfrs Motion to Di miss and Suppl mental Motfon to Dlainlss de with I the truthfulness orthe allegatl ns against the Defendant affirmative defenses tlia.t may be availab.le to the lJefeD:dant E:DWA DS a.a wctf.a.s the reforences outside the four comers of the C-ompl nt These matters are ore appropriately the subject matter 267ofa Mot,lon for Summary Judgment and or efense at at sed 265pon the ego ti?n to Dis ss is here ied 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