Edwards adv Epstein Case No Response in Opposition to Epsteins Omnibus Motion in Limine Page of9 This laundry list of objections seems largely based upon a gross misapprehension of the issues raised by the pending single count claim against Epstein Those issues are A Did Epstein have a good faith basis at the time he filed his civil lawsuit against Bradley Edwards for the following claims he asserted I Violation of F.S Florida Civil Remedies for Criminal Practices Act alleging Mr Edwards engaged in criminal securities violations criminal fraud forgery extortion perjury and improper litigation tactics II Violation of Florida Racketeer Influenced and Corrupt Organization Act alleging Mr Edwards committed the same predicate crimes I Abuse of Process for engaging in improper litigation tactics IV Fraud for using fabricated litigation claims to attempt to extort as much money as possible from Epstein Conspiracy for using civil actions against Epstein in an unlawful improper and fraudulent manner that is to knowingly support a massive Ponzi scheme Epsteins Complaint against Edwards 1s attached as Exhibit with particular relevant language highlighted Were Epsteins unsupported claims against Bradley Edwards motivated by malice Edwards adv Epstein Case No Response in Opposition to Epsteins Omnibus Motion in Limine Page of9 I Was the absence of support for the claims against Bradley Edwards known to Epstein as it surely would be ifhe knew he was guilty of everything with which he was charged II Was the filing of the claims motivated by an effort to extort Bradley Edwards into abandoning or compromising the proper and legitimate interests of his clients in pursuing compensatory damages punitive damages and criminal punishment of Epstein as it surely would be if he knew his claims were baseless and legally unsupportable I To what extent did Bradley Edwards sustain loss or damage as a consequence of Epsteins Malicious Prosecution of claims against Bradley Edwards IV To what extent and in what amount should punitive damages be imposed against Epstein to punish him for his malicious conduct and deter others from engaging in any similar corruption of the civil justice system The accurate delineation of the issues raised by the pending claim makes it obviously clear that the details of Epsteins sordid history of countless child molestations is at the heart of the pending case Epstein could not possibly have had a good faith basis for asserting that Bradley Edwards fabricated and ginned up claims against him if he in fact committed the crimes he was alleged to have committed and the nature and extent of his conduct was as egregious as it was alleged to have been Epstein could not have reasonably relied upon third party sources of information implicating Bradley Edwards in any wrongdoing if Epstein knew what Bradley Edwards adv Epstein Case No Response in Opposition to Epsteins Omnibus Motion in Limine Page of9 Edwards set about proving was in fact true Epstein cannot possibly protest his innocence of tortious conduct when the same conduct formed the factual basis for alleged crimes to which he pled guilty and caused him to pay many millions of dollars in settlements Epstein has no grounds to resist the admissibility of evidence on grounds of irrelevancy or undue prejudice when he explicitly challenges the existence of that evidence in his Complaint against Bradley Edwards Epstein cannot contend that the Non-Prosecution Agreement has nothing to do with this case when he specifically references it in his Complaint Epstein cannot be heard to challenge the propriety of discovery sought by Bradley Edwards in the claims prosecuted against Epstein and then simultaneously restrict a complete explanation of the propriety of each and every discovery effort Epstein cannot defend against the imposition of punitive damages by hiding the full extent of the magnitude of the wrongdoing sought to be punished Indeed the Florida Standard Jury Instructions on punitive damages expressly requires consideration of the nature extent and degree of misconduct and the related circumstances Emphasis added Whether Epstein had a good faith basis at the time he filed his civil lawsuit against Bradley Edwards for the Counts asserted is admittedly not resolved by proof that Bradley Edwards was innocent of the charges leveled against him That does not mean however that Bradley Edwards innocence is irrelevant as it is still probative of the issue of malice A defendant charged with malicious prosecution may be exonerated of liability even though his claims were false if he is able to demonstrate reasonable grounds for having believed the claims to be viable when he brought the claims However no amount of evidence can support Edwards adv Epstein Case No Response in Opposition to Epsteins Omnibus Motion in Limine Page of9 a good faith mistaken belief if the defendant knows the evidence is false or unreliable Therefore what Epstein knew is highly relevant and Epstein certainly knew whether he was in fact a serial child molester Here Epstein is precluded from defending on the basis of a good faith mistaken belief because he has elected by asserting his Fifth Amendment right against self-incrimination to foreclose all discovery into what he knew about the truthfulness of Bradley Edwards claims against him but his knowledge may be proved by other evidence of his guilt What remains is for Bradley Edwards to prove that there was a reasonable basis for every claim he brought against Epstein and every action he took in the prosecution of those claims In other words resolution of the issue as to whether there was a good faith basis for Bradley Edwards actions begins and ends with whether there was a reasonable basis for Bradley Edwards conduct--did he act reasonably in the filing and prosecution of his claims against Epstein But while Bradley Edwards good faith beliefs i.e whether they had a reasonable basis are certainly relevant Epsteins subjective beliefs are not an issue because his Fifth Amendment assertions foreclose his assertion of an issue as to which he refused to permit discovery See Edwards separate memo addressing the consequences of Epsteins Fifth Amendment assertion However Bradley Edwards good faith is a question that has also been conclusively resolved in favor of Bradley Edwards by Epsteins voluntary dismissal of the claims he brought against Edwards on the eve of the hearing on a motion for summary judgment addressing those claims As a matter of law pursuant to the law of this case Bradley Edwards had a reasonable basis to support all of his claims against Epstein and he lawfully prosecuted those claims See Edwards adv Epstein Case No Response in Opposition to Epsteins Omnibus Motion in Limine Page of9 Bradley Edwards responses to Epsteins Motion for Summary Judgment which are incorporated in further response to Epsteins Motion in Limine Given these circumstances and the resolution of the issue of the lack of Epsteins good faith basis for his claims against Bradley Edwards as a matter of law why then do the listed exhibits remain relevant The answer is that even though it has been established that Epstein lacked a good faith basis for his claims against Bradley Edwards it remains to be determined whether Epsteins unsupported claims were pursued as a consequence of simple negligence or was he motivated by malice and ifhe acted maliciously what was the degree of that malice One acts maliciously in instituting a civil proceeding against another if he does so for the primary purpose of injuring the other or recklessly and without regard for whether the proceeding is justified or for any primary purpose except to establish what he considers to be a meritorious claim In determining whether Epstein acted maliciously a jury is permitted to consider all the circumstances at the time of the conduct complained of including any lack of probable cause to institute the proceeding Florida Standard Jury Instruction No MI Certainly all evidence reasonably bearing on the existence ofimproper motives is relevant evidence This would include a desire to intimidate and extort a civil litigation opponent or to extort a person Edwards who was a compelling force behind efforts to see that a serial pedophile Epstein was held criminally responsible for his crimes The required malice in a malicious prosecution action may be one of two kinds actual or subjective malice sometimes called malice in fact and legal malice which may be inferred from circumstances such as the want of probable cause even though actual malice or Edwards adv Epstein Case No Response in Opposition to Epsteins Omnibus Motion in Limine Page of9 corrupt design is not shown Legal malice does not require clear and positive independent proof Fla Jr 2d False Imprisonment Malicious Prosecution Thus it remains to be determined through either direct and/or circumstantial evidence whether Epstein was acting as alleged by Bradley Edwards to try to scare off Bradley Edwards to intimidate him and to extort him into abandoning or unreasonably compromising the legitimate interests of his clients in being fully compensated for the injuries they sustained and their further interest in seeing that Epstein is appropriately punished both civilly and criminally The fact that Epstein was a self-admitted child molester is certainly relevant to that determination The fact that he faced dozens of civil claims arising out of his criminal acts is certainly relevant to that determination The fact that the civil actions Bradley Edwards and others being led by Bradley Edwards were prosecuting exposed Epstein to many many millions of dollars in civil judgments and perhaps hundreds of millions of dollars in punitive damages-is certainly relevant to that determination The fact that as a result of the actions of Bradley Edwards Epstein stood in jeopardy of having a federal non-prosecution agreement vacated which could subject Epstein to years if not decades in a federal penitentiary-that is certainly relevant to the determination of whether Epstein was acting with malice toward Bradley Edwards All of the evidence gathered against Epstein to the extent it contributed to Epsteins awareness of the grave jeopardy he was in and to the extent it was known to and considered by Bradley Edwards impacts directly on the state of mind of both Bradley Edwards state of mind is the lynchpin of his good faith Epsteins state of mind is the key to proof of actual malice Edwards adv Epstein Case No Response in Opposition to Epsteins Omnibus Motion in Limine Page of9 Epsteins Motion in Limine is based upon a grossly distorted view of what this case is about of the issues required to be resolved of the implications of prior proceedings in this action and of the fact that an essential component of a hearsay objection is that the objected-to out-of court statement is offered to prove the truth of the matter asserted and not to prove its impact on the state of mind of the listener or reader When properly considered all of these factors require the denial of Epsteins shotgun assault on Bradley Edwards Exhibit and Witness Lists The motion should be denied I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list this ci1 a of Mail jsx a searcylaw.com and ce"ann searcylaw.com 267mary E-Mail _scarolateam searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Response in Opposition to Epsteins Omnibus Motion in Limine Page of9 COUNSEL LIST William Chester Brewer Esquire wcblaw aol.com wcblawasst gmail.com Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Nichole Segal Esquire njs FLAppellateLaw.com kbt FLAppellateLaw.com Burlington Rockenbach P.A Railroad Avenue Suite West Palm Beach FL Phone Attorneys for Bradley Edwards Bradley Edwards Esquire staff.efile pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews A venue Suite Fort Lauderdale FL Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com Fred FredHaddadLaw.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com efiling tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein JEFFREY EPSTEIN Plaintiff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Complex Litigation Fla Civ Pro CASE CAO OXMB SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendants COMPLAINT Plaintiff JEFFREY EPSTEIN hereinafter EPSTEIN by and through his undersigned attorneys files this action against Defendants SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Accordingly EPSTEIN states SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein Rosenfeldt and Adler P.A for personal greed and enrichment in betrayal of the ethical legal and fiduciary duties to their own clients and professional obligations to the administration of justice deliberately engaged in a pattern of racketeering that involved a staggering series of gravely serious obstructions of justice actionable frauds and the orchestration and conducting of egregious civil litigation abuses that resulted in profoundly serious injury to Jeffrey Epstein one of several targets of their misconduct Epstein RRA et al Page2 and others Rothstein and RRAs fraud had no boundary Rothstein and his co conspirators forged Federal court orders and opinions Amongst the violations of law that are the subject of this lawsuit are the marketing of non-existent Epstein settlements and the sanctioning of a series of depositions that were unrelated to any principled litigation purpose but instead designed to discover extraneous private information about Epstein or his personal and business associates including well-known public figures in order to defraud investors and support extortionate demands for payment from Epstein The misconduct featured the filing of legal motions and the _eursuit of a civil litigation strategy that was unrelated to the merits or value of their clients cases and instead had as its improper purpose the furthering of Rothsteins misrepresentations and deceit to third party investors As a result Epstein was subject to abusive investigatory tactics unprincipled media attacks and unsupportable legal filings This lawsuit is filed and will be vigorously pursued against all these defendants The Rothstein racketeering enterprise endeavored to compromise the core values of both state and federal justice systems in South Florida and to vindicate the hardworking and honest lawyers and their clients who were adversely affected by the misconduct that is the subject of this Complaint Plaintiff reserves the right to add additional defendants co-conspirators as the facts and evidence is developed GENERAL ALLEGATONS This is an action for damages in excess of exclusive costs interest and attorneys fees Epstein RRA et al Page3 Plaintiff EPSTEIN is an adult and currently is residing and works in Palm Beach County Florida Defendant SCOTT ROTHSTEIN ROTHSTEIN is an individual residing in Broward County Florida and was licensed to practice law in the State of Florida In November ROTHSTEIN voluntarily relinquished his law license in the midst of the implosion of Rothstein Rosenfeldt and Adler P.A RRA He was disbarred by the Florida Supreme Court on November On December ROTHSTEIN was arrested and arraigned in Federal Court in Broward County Florida At all times relevant hereto ROTHSTEIN was the managing partner and CEO of RRA Defendant ROTHSTEIN and Stuart Rosenfeldt are and were the principal owners of equity in RRA and each co-founded RRA Defendant BRADLEY EDWARDS EDWARDS is an individual residing in Broward County Florida and is licensed to practice law in the State of Florida At all times relevant hereto EDWARDS was an employee agent associate partner shareholder and/or other representative of RRA Defendant L.M L.M is an individual residing in Palm Beach County Florida At all times relevant hereto L.M was represented by RRA ROTHSTEIN and EDWARDS in a civil lawsuit against Epstein and was an essential participant in the scheme referenced infra by among other things substantially changing prior sworn testimony so as to assist the Defendants in promoting their fraudulent scheme for the Epstein RRA et al Page4 promise of a multi-million dollar recovery relative to the Civil Actions defined below involving Epstein which was completely out of proportion to her alleged damages Non-party RRA is a Florida Professional Service Corporation with a principal address of East Las Olas Blvd Suite Fort Lauderdale FL In addition to its principal office RRA also maintained seven offices in Florida New York and Venezuela and employed over attorneys and support staff RRA also maintains an office at NE 2d Street Hallendale Beach Florida RRA through its attorneys including those named as Defendants herein conducted business throughout Florida and relevant to this action conducted business and filed lawsuits on behalf of clients in Palm Beach County Florida RRA is currently a debtor in bankruptcy RRA is not named as a Defendant FACTUAL ALLEGATIONS The United States in United States of America Scott Rothstein Case No United States District Court Southern District of Florida has brought an action for Racketeering Conspiracy U.S.C against Scott Rothstein who was the chief executive officer and chairman of RRA Within the information which was filed the United States of America has identified the enterprise as being the law firm RRA through which Rothstein in conjunction with his co conspirators not yet identified by the USA engaged in the pattern of racketeering through its base of operation at the offices of RRA from sometime in up through and continuing into November of Through various criminal activities including mail fraud wire fraud and money laundering the United States of America asserts that Epstein RRA et al Page5 Rothstein and his co-conspirators unlawfully obtained approximately billion from investors by fraud in connection with a Ponzi scheme The USA further alleges that Rothstein and co-conspirators initiated the criminal conduct alleged in the instant Information in order to personally enrich themselves and to supplement the income and sustain the daily operation of RRA In essence in the absence of Rothstein and his co conspirators conducting the Ponzi scheme the daily operation of RRA which included payroll compensation to lawyers staff investigators etc accounts payable including unlimited improper harassing and potential illegal investigation on cases including Epstein-related matters would in all likelihood would not have been sustainable A copy of the information is attached as Exhibit to this action As more fully set forth herein RRA held itself out as legitimately and properly engaging in the practice of law In reality ROTHSTEIN and others in RRA were using RRA to market investments as described below so as to bilk investors out of hundreds of millions of dollars ROTHSTEIN and others in RRA devised an elaborate plan through which were sold purported confidential assignments of a structured pay-out settlements supposedly reached on behalf of RRA for clients in exchange for immediate payments to these clients of a discounted lump sum amount Investors were being promised in excess of a return on their investment which was to be paid out to the investors over time While some of the cases relied upon to induce investor funding were existing filed cases it is believed that the confidential structured pay-out settlements were all fabricated Epstein RRA et al Page6 Based on media reports Federal Bureau of Investigation FBI press conferences and releases and the Information the massive Ponzi scheme and pattern of criminal activity meant to lure investors began sometime in and continued through the fall of when the scheme was uncovered by some of the investors and the FBI As of November of civil lawsuits were and continue to be filed against various Defendants as result of their massive fraudulent and criminal scheme This fraudulent and illegal investment scheme is also evidenced by the filing of Amended Complaint For Dissolution And For Emergency Transfer of Corporate Powers to Stuart A Rosenfeldt Or In The Alternative For the Appointment of A Custodian or Receiver by ROSENFELDT and RRA against ROTHSTEIN individually Case No In the Circuit Court of the Seventeenth Judicial Circuit Broward County Florida Complex Business Div hereinafter RRA dissolution action and attached hereto as Exhibit Plaintiff references the RRA dissolution action for the sole purpose that it acknowledges that RRA and ROTHSTEIN were in fact conducting an illegal and improper investment or Ponzi scheme based on promises of financial returns from settlements or outcomes of supposed legal actions including the actions brought against Plaintiff EPSTEIN The RRA dissolution action alleges in part that ROTHSTEIN the managing partner and CEO of the firm RRA has according to assertions of certain investors allegedly orchestrated a substantial misappropriation of funds from investor trust accounts that made use of the law firms name RRA The investment business created and operated by ROTHSTEIN centered around the sale of Epstein RRA et al Page interests in structured settlements See Preliminary Statement of RRA dissolution action Exhibit hereto In furtherance of the scheme RRAs letterhead was used in communications regarding investment opportunities in purported structured settlements RRAs trust account was used to deposit hundreds of millions of dollars or wire transfer of monies from duped investors and other victims RRA personally guaranteed payments Rothsteins scheme went so far as to manufacture false and fraudulent Court opinions/orders including forging the signatures of U.S District Judge Kenneth A Marra and U.S Circuit Court Judge Susan Black 11th Circuit in other cases it is not yet known if he forged similar documents in Esptein related matters See Composite Exhibit hereto The details of this fraudulent scheme are being revealed on a daily basis through various media reports and court documents The most recent estimate of the financial scope of the scheme is that it exceeds billion dollars Relevant to this action EPSTEIN is currently named as a defendant in three civil actions alleging inter alia sexual assault and battery that were handled RRA and its attorneys including EDWARDS prior to its implosion one of which is filed in federal court Jane Doe Epstein Case No U.S.D.C S.D Fla Jane Doe is a named Defendant herein and two of which have been filed in state court in the th Judicial Circuit Court Palm Beach County State of Florida L.M Epstein Case No AB E.W Epstein Case No Epstein RRA et al Page8 AB hereinafter collectively referred to as the Civil Actions and L.M is a named Defendant herein The Civil Actions were all filed in August and September of What is clear is that a fraudulent and improper investment or Ponzi scheme was in fact conducted and operated by RRA and certain of the named Defendants which scheme directly impacted EPSTEIN as a named defendant in the Civil Actions Miami attorney and developer Alan Sakowitz was quoted in a November article as saying that he had met with ROTHSTEIN as a potential investor in August of but became suspicious He stated I was convinced it was all a Ponzi scheme and I notified the FBI in detail how Scotty ROTHSTEIN was hiding behind a legitimate law firm to peddle fake investments Attorney Sakowitz was also quoted as saying ROTHSTEIN had sophisticated eavesdropping equipment and former law enforcement officers who would sift through a potential defendants garbage looking for damaging evidence to use with investors to show how potential defendants could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim Ft Lauderdale attorney William Scherer represents multiple Rothstein related investors He indicated in an article that RRA/Rothstein had used the Epstein Ploy as a showpiece as bait Thats the way he raised all the money He would use cases as bait for luring investors into fictional cases All the cases he allegedly structured were fictional I dont believe there was a real one in there In fact on November William Scherer on behalf of certain clients filed a page Complaint against ROTHSTEIN David Boden Debra Villegas Andrew Barnett TD Bank N.A Frank Epstein RRA et al Page9 Spinosa Jennifer Kerstetter Rosanne Caretsky and Frank Preve asserting various allegations that further prove the massive Ponzi scheme behind the RRA fa ade and as of November a page Amended Complaint naming additional Defendants was filed In addition and upon information and belief ROTHSTEIN David Boden Debbie Villegas Andrew Barnett Michael Fisten and Kenneth Jenne all employees of RRA through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/clients that existed or RRA had against EPSTEIN and the value thereof They would show and share actual case files from the EPSTEIN actions with hedge fund managers Thus the attorneys and clients have waived any attorney-client or work product privileges that otherwise may have existed Because potential investors were given access to some of the actual Civil Action files investor-third parties may have became aware of a name of an existing Plaintiff who had filed anonymously against Epstein and had opposed disclosure of her legal name In all other instances by RRA ROTHSTEIN and EDWARDS claiming the need for anonymity with regard to existing or fabricated clients they were able to effectively use initials Jane Doe or other anonymous designations which was a key element in the fraudulent scheme Fictitious names could be created to make the investors believe many other cases existed against Epstein Epstein RRA et al Page In each of RRAs Civil Actions the Plaintiffs are or were represented by RRA and its attorneys including ROTHSTEIN and EDWARDS In addition investors were told that in addition to the Civil Actions another fifty plus anonymous females were represented by RRA with the potential for hundreds of millions of dollars in settlements and that RRA and its attorneys would sue Epstein unless he paid exorbitant-settlement amounts to protect his high-profile friends Upon information and belief EDWARDS knew or should have known that ROTHSTEIN was utilizing RRA as a front for the massive Ponzi scheme and/or were elling an alleged interest or investment in the Civil Actions and other claims involving Epstein Further evidencing that EDWARDS and possibly other attorneys of RRA knew or should have known and participated in the continuation of the massive Ponzi scheme a front-page Palm Beach Post article dated November reported on the recent filing of an amended forfeiture complaint by prosecutors against dozens of ROTHSTEINs real estate properties foreign cars restaurants and other assets including million in the lawyers bank account in Morocco along with millions more donated to political campaigns and charitable funds The article further reported that Attorney Scott ROTHSTEIN tapped into millions of dollars from his massive investment scam to cover payroll costs at his expanding Fort Lauderdale law firm federal authorities said in court records released Monday ROTHSTEINs law firm RRA generated revenue of million in one recent year yet his 70-lawyer law firm had a payroll of million Epstein RRA et al Page prosecutors said ROTHSTEIN who owned half of RRA used investors money from his Ponzi scheme to make up the shortfall they said Subsequent articles and court filings have reflected ROTHSTEIN received compensation in excess of million in and million in while his partner Rosenfeldt received greater than million in ROTHSTEIN attempted to lure the entity known as D3 Capital Club LLC D3 by offering D3 the opportunity to invest in a pre-suit court settlement against EPSTEIN yet this supposed settlement never existed and was entirely fabricated To augment his concocted sto ROTHSTEIN upon information and belief invited D3 to his office to view thirteen bankers boxes of case files in Jane Doe ne of the Civil Actions in an attempt to substantiate that the claims against EPSTEIN were legitimate and that the evidence obtained against him by RRA ROTHSTEIN and EDWARDS the Litigation Team was real Upon information and belief ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN Fisten a former Dade County police officer with a questionable police record and RRA investigator and Jenne a former attorney Broward County Sheriff and felon assisted ROTHSTEIN in making these offers by providing confidential privileged and work product information to prospective third-party investors It appears that out of the boxes seized by the FBI as part of its investigation at RRA consisted of files relating to the Civil Actions involving EPSTEIN as reported by counsel for the Bankruptcy Trustee Until those boxes can be reviewed as well as other discovery Epstein will not know the depth of the fraud and those involved Epstein RRA et al Page By using the Civil Actions against EPSTEIN as bait and fabricating settlements regarding same ROTHSTEIN and others were able to lure investors into ROTHSTEINS lair and bilked them of millions of dollars which in turn was used to fund the litigation against EPSTEIN for the sole purpose of continuing the massive Ponzi scheme As part of this scheme ROTHSTEIN and the Litigation Team individually and in a concerted effort may have unethically and illegally a Sold allowed to be sold and/or assisted with the sale of an interest in non settled personal injury lawsuits which are non-assignable and non transferable or sold non-existent structured settlements including those cases involving Epstein eached agreements to share attorneys fees with non-lawyers Used investor money to pay plaintiffs i.e L.M E.W and Jane Doe up front money such that plaintiffs would refuse to settle the Civil Actions Conducted searches wiretaps or intercepted conversations in violation of state or federal laws and Bar rules and Utilized the judicial process including but not limited to unreasonable and unnecessary discovery for the sole purpose of furthering the Ponzi scheme Any such actions by ROTHSTEIN and other attorneys including the Litigation Team directly or indirectly would potentially be a violation of various Florida Bar Rules Epstein RRA et al Page including prohibiting the improper sharing of fees or costs and various conflicts of issues rules Evidencing that the Litigation earn knew or should have known of the improper purpose that ROTHSTEIN was pursuing in the continuation of the scheme ROTHSTEIN used RRAs Litigation Team in the EPSTEIN cases to pursue issues and evidence unrelated to and unnecessary to the claims pied in the Civil Actions but significantly beneficial to lure investors into the Ponzi scheme orchestrated by ROTHSTEIN and other co-conspirators Upon information and belief ROTHSTEIN and others claimed their investigators discovered that there were high-profile individuals onboard Epsteins private jet where sexual assaults took place and showed D3 and possibly others copies of a flight log purportedly containing names of celebrities dignitaries and international figures For instance the Litigation Team relentlessly and knowingly pursued flight data and passenger manifests regarding flights EPSTEIN took with these famous individuals knowing full well that no underage women were onboard and no illicit activities took place ROTHSTEIN and the Litigation Team also inappropriately attempted to take the depositions of these celebrities in a calculated effort to bolster the marketing scam that was taking place One of Plaintiffs counsel EDWARDS deposed tpree of EPSTEINS pilots and sought the deposition of a fourth pilot currently servjng in Iraq The pilots were ii deposed by EDWARDS for over twelve hours and EDWARDS never asked one question relating to or about E.W L.M and Jane Doe RRA clients as it related to Epstein RRA et al Page transportation on flights of RRA clients on any of EPSTEINS planes But EDWARDS asked many inflammatory and leading irrelevant questions about the pilots thoughts and beliefs which will never be admissible at trial which could only have been asked for the purposes of pumping the cases and thus by using the depositions to sell the cases or a part of them to third parties Because of these facts ROTHSTEIN claimed that Epstein wanted to make certain none of these individuals would be deposed and therefore he had offered to settle the claims of RRA female clients various potential plaintiffs in actions against EPSTEIN The offer of a million dollar settlement by EPSTEIN was completely fabricated no such offer had ever been made EDWARDS office also notified Defendant that he intended to take the depositions of and was subpoenaing i Donald Trump real-estate magnate and business mogul ii Alan Dershowitz noted Harvard Law professor constitutional attorney and one of EPSTEINS criminal defense attorneys i Bill Clinton Former President of the United States iv Tommy Mottola former President of Sony Record and David Copperfield illusionist The above-named individuals were friends and acquaintances of EPSTEIN with whom he knew through business or philanthropic work over the years None of the above-named individuals had any connection whatsoever with any of the Litigation Teams clients E.W L.M or Jane Doe Epstein RRA et al Page EDWARDS filed amended answers to interrogatories in the state court matters E.W and L.M and listed additional high profile witnesses that would allegedly be called at trial including but not limited to i Bill Richardson Governor of New Mexico formerly U.S Representative and Ambassador to the United Nations and ii Any and all persons having knowledge of EPSTEINS charitable political or other donations The sole purpose of the scheduling of these depositions or listing high profile friends/acquaintances as potential witnesses was again to pump the cases to investors There is no evidence to date that any of these individuals had or have any knowledge regarding RRAs Civil Actions 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 against EPSTEIN a Included claims for damages in Jane Does federal action in excess of rather than simply alleging the jurisdictional limits Organized a Jane Doe TV media interview without any legitimate legal purpose other than to pump the federal case for potential These high-profile celebrity purported witnesses have no personal knowledge regarding the facts on these Three Cases but were being contacted subpoenaed or listed to harass and intimidate them and Epstein and to add star appeal to the marketing effort of the Ponzi scheme Epstein RRA et al Page investors or to prejudice Epsteins right to a fair trial in Palm Beach County EDWARDS Berger and Russell Adler another named partner in RRA all attended EPSTEINs deposition At that time outrageous questions were asked of EPSTEIN which had no bearing on the case but so that the video and questions could be shown to investors Conducted and attempted to conduct completely irrelevant discovery unrelated to the claims in or subject matter of the Civil Actions for the purpose of harassing and embarrassing witnesses and EPSTEIN and causing EPSTEIN to spend tens of thousands of dollars in unnecessary attorneys fees and costs defending what appeared to be discovery related to the Civil Actions but was entirely related to the furtherance of the Ponzi scheme After EDWARDS was recruited and joined RRA in the spring of the tone and tenor of rhetoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing the court on various motions from being substantive on the facts pied to ridiculously inflammatory and sound-bite rich such as the July transcript when EDWARDS stated to the Court in E.W./L.M What the evidence is really going to show is that Mr Epstein at least dating back as Epstein RRA et al Page far as our investigation and resources have permitted back to or has every single day of his life made an attempt to sexually abuse children Were not talking about five were not talking about were not talking about were not talking about which I believe is the number known to law enforcement we are talking about thousands of children and it is through a very intricate and complicated system that he devised where he has as many as people working underneath him that he is paying well to schedule these appointments to locate these girls As an example EDWARDS filed an unsupportable and legally deficient Motion for Injunction Restraining Fraudulent Transfer of Assets Appointment of a Receiver to Take Charge of Property of Epstein and to Post a million Bond to Secure Potential Judgment in Jane Doe Epstein Case No Marra/Johnson The motion was reported in the press as was the ultimate goal i.e to pump the cases for investor following However the Court found Plaintiffs motion entirely devoid of evidence and denied the motion in toto ROTHSTEIN told investors he had another females that he represented and that Epstein had offered million to resolve Epstein RRA et al Page but that he could settle confidently these cases for million separate and apart from his legal fees ROTHSTEIN and the Litigation Team knew or should have known that their three filed cases were weak and had minimal value for the following reasons i ii L.M testified she never had any type of sex with Epstein worked at numerous strip clubs is an admitted prostitute and call girl has a history of illegal drug use pot painkillers Xanax Ecstasy and continually asserted the th Amendment during her depositions in order to avoid answering relevant but problem questions for her E.W testified she worked at eleven separate strip clubs including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest and E.W also worked at Platinum Showgirls in Boynton Beach which was the subject of a recent police raid where dancers were allegedly selling prescription painkillers and drugs to customers and prostituting themselves i Jane Doe federal case seeks million from Epstein She and her attorneys claim severe Epstein RRA et al Page emotional distress as a result of her having voluntarily gone to Epsteins home She testified that there was never oral and or sexual intercourse nor did she ever touch his genitalia Yet Jane Doe suffered extreme emotional distress well prior to meeting Epstein as a result of having witnessed her father murder his girlfriends son She was required to give sworn testimony in that matter and has admitted that she has lied in sworn testimony Jane Doe worked at two different strip clubs including Platinum Showgirls in Boynton Beach i Conducted ridiculous and irrelevant discovery such as subpoenaing records from an alleged sex therapist Dr Leonard Bard in Massachusetts when the alleged police report reflected that EPSTEIN had only seen a chiropractor in Palm Beach named Dr Bard No records relating to EPSTEIN existed for this alleged sex therapist Dr Bard and the alleged subpoena for records was just another mechanism to pump the cases for investor appeal Allowed a Second Amended Complaint to be filed on behalf of L.M alleging that EPSTEIN forced the minor into oral sex yet L.M testified that she never engaged in oral anal or vaginal Epstein RRA et al Page intercourse with EPSTEIN and she had never touched his genitalia Told investors as reported in an Associated Press article that celebrities and other famous people had flown on EPSTEINS plane when assaults took place Therefore even though none zero of RRAs clients claim they flew of EPSTEINS planes the Litigation earn sought pilot and plane logs Why Again to prime the investment pump with new money without any relevance to the existing claims made by the RRA clients I After EDWARDS joined RRA EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non Prosecution Agreement NPA between Epstein and USAO public But RRA EDWARDS and Berger and their three clients already had a copy of the NPA They knew what it said and they knew the civil provisions in the agreement had no impact whatsoever on the three pending Civil Actions The concept behind certain civil provisions in the NPA was to allow an alleged victim to resolve a civil claim with Epstein maintain her complete privacy and anonymity and move on with her life As an assistant United States Attorney stated at a hearing in federal court the NPA was not designed to hand them a jackpot or a key to a bank Epstein RRA et al Page ROTHSTEIN with the intent and improper motive to magnify his financial gain so continue to fund the fraudulent and illegal investment and/or Ponzi scheme had EDWARDS demand excessive money from EPSTEIN in the Civil Actions The actions described in paragraph above herein had no legitimate purpose in pursuing the Civil Actions against EPSTEIN but rather were meant to further the fraudulent scheme and criminal activity of ROTHSTEIN so that he and others could fraudulently overvalue the settlement value of the existing and non-existent claims against EPSTEIN to potential investors As a result of the fraudulent investment or Ponzi scheme RRA and its attorneys in the Civil Actions against EPSTEIN may have compromised their clients interests ROTHSTEIN and the Litigation Team would have been unable to give unbiased legal counsel because outside investor had been promised a financial interest in the outcome of the actions Additionally if a plaintiff received payments from investment monies while her action is pending this clearly could impact the plaintiffs decision of whether or not to settle the current litigation or shade their testimony i.e commit perjury to gain the greatest return on the investment and to further promote the Ponzi Scheme The truthfulness of L.M.s allegations and testimony in L.M.s state civil action have been severely compromised by the need to seek a multi-million dollar payout to help maintain RRAs massive fraud Because fictitious settlements of tens of millions of dollars in cases relating to EPSTEIN were represented to investors in this Ponzi scheme RRA and the attorneys in the Civil Actions needed to create a fiction that Epstein RRA et al Page included extraordinary damages However the actual facts behind her action would never support such extraordinary damages Therefore extraordinary measures were undertaken to create an entirely inflated value of her claims against EPSTEIN a Though she held herself out as a victim of Epstein she admitted to having returned over and over again to him despite her current claim of abuse She has now admitted under oath to being a call girl/escort since the age of in her deposition September Transcript DT She testified Well I lived life as a prostitute see DT and I am a prostitute when I make money see DT L.M admitted her activity with men other than Epstein to making a day from prostitution on maybe more than occasions in one year alone DT L.M admitted under oath to keeping a list of amounts she collected from Johns in two or three lined books including a book of Psalms that she obtained from a religious store DT Under the circumstances her claim for damages against EPSTEIN one of L.M.s many Johns during that same period would be so incredible and certainly not likely to produce the extraordinary settlements promised to RRAs investors In April before she was represented by EDWARDS and RRA L.M gave sworn taped recorded testimony to the agents of the FBI She was represented by a lawyer other than EDWARDS at that statement She spoke of EPSTEIN in a very positive and friendly terms and directly contradicted the central allegations on which L.M.s civil action against Epstein is now based However once in the hands of Epstein RRA et al Page EDWARDS and RRA L.M.s story changed dramatically All of a sudden she wanted to sue EPSTEIN and like other RRA clients sought tens of millions of dollars a For example in her sworn statement to the FBI L.M was insistent that Jeffrey is an awesome man FBI At the conclusion of she stated I hope Jeffrey nothing happens to Jeffrey because hes an awesome man and it really would be a shame Its a shame that he has to go through this because hes an awesome guy and he didnt do nothing wrong nothing pp FBI In fact L.M spoke so highly of EPSTEIN and her interactions with him that the US Attorneys office informed a federal court in July that the US Attorney could not consider L.M a victim Yet by September the date on which L.M began her deposition in her civil action and now represented by RRA and EDWARDS L.M.s new and very different tale about purported sexual misconduct under the supposed influence of EPSTEIN had been thoroughly rehearsed and her role into the ROTHSTEIN scam was complete In her deposition in her civil action L.M declared that I I dont really care about money DT He needs time in jail He doesnt want to be this is not right for him to be on the streets living daily DT Epstein RRA et al Page You dont think my whole life I have lived that shitty life because of Jeffrey Epstein OT In her sworn FBI testimony pre-EDWARDS and RRA L.M was emphatic that her interactions with Epstein involved no inappropriate sexual touching in any way In fact it was exactly the opposite Did he at any point kiss you touch you show any kind of affection towards you A Never never FBI So he never pulled you closer to him in a sexual way A I wish No no never ever ever no never Jeffrey is an awesome man no FBI Yet L.M filed her second amended complaint in April after EDWARDS joined RRA the allegations against EPSTEIN in L.M.s complaint became even more salacious In paragraph of L.M.s Second Amended Complaint L.M alleges among other things that Jeffrey Epstein coerced induced or enticed the then minor Plaintiff to commit various acts of sexual misconduct These acts included but were not limited to fondling and inappropriate and illegal sexual touching of the then minor Plaintiff forcing or inducing the then minor plaintiff into oral sex or other sexual misconduct Epstein RRA et al Page In her sworn FBI statement pre-EDWARDS and RRA L.M testified that Carolyn Andriana the individual who first brought L.M to EPSTEINs home told L.M make sure youre because Jeffrey doesnt want any underage girls FBI Yet at her September deposition now represented by EDWARDS and RRA L.M told a very different story My question was what did Carolyn tell you to tell Mr Epstein about your age A She said it didnt matter Thats your recollection about what she said A Yes she said I remember her saying it doesnt matter Dont worry about it DT Pre-EDWARDS and RRA L.M testified to the FBI I always made sure I had a fake ID anyways saying that I was FBI stated Yet when questioned about her fake ID at her September depo she And did you have a fake ID A No Have you ever had a fake ID Epstein RRA et al Page A No DT In her FBI statement pre-EDWARDS and RRA L.M testified about others L.M brought to the Epstein home L.M testified that women she brought to EPSTEINs home were eager for the opportunity and content with their experiences A None of my girls ever had a problem and theyd call me Theyd beg me you know for us to go to Jeffreys house because they love Jeffrey Jeffrey is a respectful man He really is I mean and he all thought we were of age always This is whats so sad about it FBI Did any of the girls complain about what happened after they left there A No You asked me that question No everybody loved Jeffrey FBI A Every girl that I brought to Jeffrey they said they were fine with it and like for example E.W another of RRAs clients in the Civil Actions a lot of girls begged me to bring them back for the money And as far as I know we all had fun there FBI Epstein RRA et al Page Yet with EDWARDS and RRA as her attorneys L.M did a at her September deposition in saying A Once they were there they were scared out of their mind They did it anyways and some of them walked out and said L.M dont ever do this to me again That was the worst thing that ever happened to me DT A And then a lot of girls werent comfortable DT The above represent only a few of the dramatic changes L.M made in her testimony prior to her representation by EDWARDS/RRA and after she hired ROTHSTEIN EDWARDS and RRA As a result of the fraudulent investment or Ponzi scheme L.M may knowingly have compromised her alleged interests in her Civil Action or committed a fraud on the court RRA and the Litigation Team took an emotionally driven set of facts involving alleged innocent unsuspecting underage females and a Palm Beach Billionaire and sought to turn it into a gold mine Rather than evaluating and resolving the cases based on the merits i.e facts which included knowledgeable voluntary and consensual actions by each of the claimants and substantial pre-Epstein psychological and emotional conditions of each of the claimants and substantial sexual experiences pre Epstein RRA and the 1-itigation earn sought through protective orders and objections to block relevant discovery regarding their claimants They instead forged ahead with discovery the main purpose of which was to pressure Epstein into settling the cases Epstein RRA et al Page Fortunately their tactics have not been successful As Magistrate Judge Linnea Johnson wrote in a discovery order dated September DE in Federal Case in denying Plaintiffs Motion for Protective Order This is his Epsteins right The Record in this case is clear that the childhood of many of the Plaintiffs was marred by instances of abuse and neglect which in turn may have resulted in whole or in part in the damages claimed by the Plaintiffs In addition in an Omnibus Order dated October DE in Federal Case Magistrate Judge Linnea Johnson wrote Here the request at issue goes to the very heart of the Plaintiffs damage claims requesting not only general information relating to Plaintiffs sexual history but inquiring as to specific instances wherein Plaintiff received compensation or consideration for sex acts claim other males sexually assaulted battered or abuses her and/or claim other males committed lewd or lascivious acts on her As a global matter Plaintiffs clearly and unequivocally place their sexual history in issue by their allegations that Epsteins actions in this case has negatively affected their relationships by among other things distrust in men sexual intimacy problems diminished trust social problems problems in personal relationships feeling of stress around men premature teenage pregnancy antisocial behaviors and hyper-sexuality and promiscuity Considering these allegation there simply can be no question that Epstein is entitled to know whether Plaintiffs were molested or the subject of other sexual activity or lewd Epstein RRA et al Page and lascivious conduct in order to determine whether there is an alternative basis for the psychological disorders Plaintiffs claim to have sustained whether Plaintiffs engaged in prostitution or other similar type acts and how certain acts alleged in the Complaint materially affected Plaintiffs relationships with others or how those acts did not have such an affect on those relationships and/or whether Plaintiffs suffered from the alleged emotional and psychological disorders as a result of other sexual acts prior to the acts alleged in the Complaint To deny Epstein thus discovery would be tantamount to barring him from mounting a defense ROTHSTEIN EDWARDS and L.M.s actions constitute a fraud upon EPSTEIN as RRA ROTHSTEIN and the Litigation Team represented themselves to be acting in good faith and with the bests interests of their clients in mind at all times when in reality they were acting in furtherance of the investment or Ponzi scheme described herein EPSTEIN justifiably relied to his detriment on the representations of RRA and Defendants ROTHSTEIN EDWARDS and L.M as to how he conducted and defended the Civil Actions brought against him As a direct and proximate result of the fraudulent and illegal investment or Ponzi scheme orchestrated by ROTHSTEIN and as yet other unknown co-conspirators and as a result of the litigation tactics undertaken by the Litigation Team and L.M as set forth herein Plaintiff EPSTEIN has incurred and continues to incur the monetary damages including but not limited 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 al Page EPSTEIN may have been promised to third party investors incurring significant additional legal fees and costs as result of Defendants refusal to conduct settlement negotiations in a forthright and good faith manner because any monies paid by EPSTEIN is in reality a promised return on an investment and incurred significant attorneys fees and costs in defending the discovery that was not relevant material and/or calculated to lead to the admissibility of evidence but which was done for the sole purpose of pumping the cases to investors EPSTEIN has also been injured in that the scope of the fraudulent and criminal or racketeering activity so permeated the RRA law firm that EPSTEIN has been prevented from fully and fairly defending the civil actions brought against him In essence the very existence of RRA was based on the continuation of the massive Ponzi scheme orchestrated by ROTHSTEIN and other co-conspirators In order to continue to bring in monies from investors ROTHSTEIN and other co-conspirators used the Civil Actions against EPSTEIN along with other manufactured lawsuits as a means of obtaining massive amounts of money ROTHSTEIN EDWARDS and L.M are liable for damages caused to EPSTEIN individually and jointly and severally Count I Violation of et seq Fla Stat Florida Civil Remedies for Criminal Practices Act Against All Defendants Plaintiff realleges and incorporates paragraphs through as if fully set forth herein Epstein RRA et al Page RRA ROTHSTEIN EDWARDS and L.M each and collectively constitute an enterprise pursuant to Fla Stat ROTHSTEIN EDWARDS and L.M engaged in a pattern of criminal activity as defined in and Fla Stat As alleged herein ROTHSTEIN and EDWARDS committed multiple predicate acts in violation of and Fla Stat including violations of Florida Statutes Chapter relating to securities transactions Chapter relating to fraudulent practices false pretenses and fraud generally which includes L.M Chapter relating to forgery relating to extortion which includes L.M and Chapter relating to perju!Y which includes L.M Substantially more than two predicate acts i.e the selling of or participation of the sale of fabricated settlements outlined herein including the Civil Actions involving Epstein as well as the improper litigation tactics outlined above occurred within a five-year time period As a direct and proximate result of ROTHSTEIN EDWARDS and L.M.s violations of Fla Stat EPSTEIN has been injured Pursuant to Fla Stat Plaintiff EPSTEIN is entitled to threefold of his actual damages sustained reasonable attorneys fees and court costs and such other damages as allowed by law WHEREFORE Plaintiff EPSTEIN respectfully demands the entry of a judgment for damages against all the named Defendants Count II Florida RICO Racketeer Influenced and Corrupt Organization Act Pursuant to et seq Fla Stat Against All Defendants Epstein RRA et al Page Plaintiff realleges and incorporates paragraphs through as if fully set forth herein RRA along with ROTHSTEIN EDWARDS and L.M each and collectively constitute an enterprise pursuant to Fla Stat During all times relevant hereto ROTHSTEIN EDWARDS and L.M were and are associated with the enterprise RRA and each other Defendants ROTHSTEIN EDWARDS and L.M as persons associated with the enterprise RRA and each other as an enterprise unlawfully conducted or participated directly or indirectly in such an enterprise through a pattern of racketeerin9 Fla Stat as alleged above herein The breadth and scope of ROTHSTEIN EDWARDS and potentially L.M.s racketeering activity continues to be investigated by the FBI as numerous civil lawsuits against some of the Defendants and others continue to be filed by persons who have been damaged As of the filing of this Complaint criminal charges have only been brought against ROTHSTEIN Substantially more than two predicate acts i.e the selling of fabricated settlements outlined herein including the Civil Actions involving Epstein as well as the improper litigation 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 commission of crimes as defined in a Fla Stat including Chapter relating to securities Chapter relating to fraudulent practices false pretenses and fraud including L.M generally Epstein RRA et al Page Chapter relating to forgery relating to extortion including L.M Chapter relating to perjury including L.M Pursuant to Fla Stat Plaintiff seeks the following relief against Defendants ROTHSTEIN EDWARDS and L.M a Ordering ROTHSTEIN and EDWARDS to divest themselves of any interest in the enterprise RRA Enjoin all Defendants from engaging in the same type of conduct and activities as described herein and Temporarily enjoining ROTHSTEIN EDWARDS and L.M from the continuation of the Civil Actions brought against EPSTEIN until criminal charges have been formally brought against RRA and/or any of the Defendants such that EPSTEIN may be allowed to evaluate whether a stay or dismissal of all Civil Actions against him is merited EPSTEIN further seeks an award of his reasonable attorneys fees and costs and such other relief that this Court deems appropriate WHEREFORE Plaintiff EPSTEIN respectfully demands the entry of a judgment for the relief sought and damages against the named Defendants Count Ill Abuse of Process Against All Defendants Plaintiff realleges and incorporates paragraphs through as if fully set forth herein Epstein RRA et al Page34 After instituting the Civil Actions against EPSTEIN the actions of Defendants ROTHSTEIN EDWARDS and L.M as alleged in paragraphs through herein constitute an illegal improper or perverted use of process ROTHSTEIN EDWARDS and L.M possessed ulterior motives or purposes in exercising such illegal improper or perverted use of process As a result of ROTHSTEIN EDWARDS and L.M.s actions EPSTEIN suffered damages WHEREFORE Plaintiff EPSTEIN respectfully demands the entry of a judgment for damages against all the named Defendants Count IV Fraud Against All Defendants Plaintiff realleges and incorporates paragraphs through as if fully set forth herein ROTHSTEIN by and through Defendant EDWARDS and L.M made false statements of fact to EPSTEIN and his attorneys and agents known to be false at the time made and/or intentionally concealed material information from EPSTEIN and his attorneys and agents for the purpose of inducing EPSTEIN to act in reliance thereon EPSTEIN did so act on the misrepresentation and/or concealment by incurring additional attorneys fees costs and expenses in aggressively defending the civil actions whereas in reality because the Civil Actions against Plaintiff were being exploited and over-valued so as to lure additional investors and to attempt to extort as much money as possible from EPSTEIN so as to continue the massive fraud Epstein RRA et al Page35 WHEREFORE Plaintiff EPSTEIN demands judgment against Defendants for damages incurred and for any other relief to which he is entitled under the law Conspiracy to Commit Fraud Against All Defendants Plaintiff realleges and incorporates paragraphs through and and as if fully set forth herein ROTHSTEIN EDWARDS and L.M conspired to commit a fraud upon EPSTEIN ROTHSTEIN EDWARDS and L.M combined by and through concerted action as detailed herein to accomplish an unlawful purpose or accomplish some purpose by unlawful means The unlawful purpose was among other things the orchestrating and continuation of the massive fraudulent Ponzi scheme and receipt of monies for the continuation of the scheme The unlawful means includes but is not limited to the use of the Civil Actions against EPSTEIN in an unlawful improper and fraudulent manner As a direct and proximate result of ROTHSTEIN EDWARDS and L.M.s conspiracy to defraud EPSTEIN EPSTEIN suffered damages WHEREFORE Plaintiff EPSTEIN demands judgment against Defendants for damages incurred and for any other relief to which he is entitled under the law Jury Trial Plaintiff demands Jury Trial on all issues so triable Epstein RRA et al Page rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Banyan Blvd Suite West Palm Beach FL Fax Attorneys for Plaintiff A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 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