EFTA00622924

from establishing a meritorious defense. While he claims to have "many meritorious 
defenses to the Complaint: he only purports to describe one, which constitutes neither 
a factual nor legal defense to any of the counts in the Complaint. 
22. 
The crux of Rothstein's purported defense is that co-Defendant, Bradley 
Edwards (a former RRA attorney), filed lawsuits against Epstein on behalf of his clients 
prior to joining RRA and that these "were and are real cases, with real plaintiffs that 
have real claims against Epstein." See Exhibit D ¶9. Then, without any explanation, 
Rothstein makes the conclusory assertion that these facts "go[j against several counts 
in the Complaint, including, but not limited to, the RICO count." 
23. 
From his affidavit, it appears that Rothstein has still not read the 
Complaint. 
24. 
The Complaint, in no uncertain terms, acknowledges that L.M., E.W and 
Jane Doe are in fact real plaintiffs who have filed real cases. Indeed, the Complaint 
alleges that Rothstein liaised 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." See 
Complaint ¶31.c. So it is unclear what defense Rothstein is attempting to establish by 
asserting that L.M., E.W. and Jane Doe are real plaintiffs with real cases, a fact alleged 
in the Complaint. 
25. 
What is clear Is that Rothstein's affidavit falls woefully short of 
demonstrating a defense, let alone a meritorious one, that would support setting aside 
the default and the Court should therefore deny Rothstein's motion. 
"A factual 
a;legation that does not meet the substance of the allegations against the affiant does 
and cannot state a 'meritorious' defense." See Hill, 872 So. 2d at 921. 
5 
EFTA00622944

Rothstein's Failure to Respond to the 
Complaint Was Not the Result of Excusable Neglect 
26. 
To set aside a default, Rothstein must also demonstrate excusable 
neglect in falling to respond to the complaint. See Hill 872 So. 2d at 921. Rothstein's 
affidavit does not controvert the fact he was personally served and demonstrates that 
he essentially ignored this lawsuit. Such indifference to legal process is inexcusable. 
27. 
In Medcom USA, Inc. v, Ryder Homes & Groves, Co., 847 So. 2d 594, 
596 (Fla. 2d DCA 2003), defendant moved to set aside a clerk's default and filed 
affidavits of its president, vice president and chief counsel, which asserted that 
defendant "had not been served with process; that [defendant's] first knowledge of the 
suit was the receipt of the final judgment ... and that the company had immediately 
retained counsel to take appropriate steps to respond to the action.' The court affirmed 
the trial court's refusal to set aside default under these circumstances because the 
defendant's "bare allegations that [defendant's CEO) had not been served with process 
are not sufficient as a matter of law to impeach the process server's return of service 
and sworn statement that she personally served (defendant's CEO)." Id. See elle 
Marceca v. Southeast Bank, N.A., 521 So. 2d 156, 156 (Fla. 4th DCA 1988) (affirming 
trial court's denial of motion to set aside default where defendant's counsel intentionally 
or through gross neglect ignored the necessity to respond to the complaint and 
summons); The Vanguard Group, Inc. v. Vanguard Security. Inc., 409 So. 2d 1219 (Fla. 
3C DCA 1982) (holding trial court properly denied defendant's motion to set aside 
default where defendant's assertions showed only that defendant ignored the 
complaint). 
6 
EFTA00622945

28. 
Rothstein does not contest the fact that he was properly served with the 
Complaint and Summons. Instead, he asserts that "I do not recall being served with this 
lawsuit" and "[i]f I was properly served with this lawsuit, it has been misplaced within the 
pile of numerous lawsuits and voluminous amount of other legal papers and has not 
been located." See Exhibit D ¶6. That Rothstein is the target of "numerous lawsuits" as 
a result of his fraudulent scheme does not excuse his failure to respond to the instant 
suit. 
29. 
Rothstein also asserts that he "did not have knowledge of [this lawsuit] 
until February, 2010." See Exhibit D ¶2. However, if Rothstein was personally served 
with the Complaint and Summons (which he does not contest), it follows that he must 
have had knowledge of the lawsuit. 
Since Rothstein's affidavit does nothing to 
controvert the verified return of service or affidavit of Carlos Aguirre (Exhibits A and 8, 
respectively), the Court must assume that the Complaint and Summons were properly 
served. See Medcom USA. Inc., 847 So. 2d at 598 (holding that bare allegations that 
defendant had not been served with process are not sufficient as a matter of law to 
impeach the process server's return of service and sworn statement that she personally 
served defendant). 
30. 
Indeed, Rothstein had to be taken from his cell into a separate room to be 
served with the lawsuit, a fact he admits in his affidavit. See Exhibit D ¶4. This is a not 
a situation where, for example, a defendant's counsel's secretary misplaced a complaint 
and forgot to calendar a response deadline. To the contrary, Rothstein was an attorney 
(although disbarred) and former CEO of RRA, a law firm which employed over 70 
lawyers, and was personally served with this lawsuit. Rothstein's affidavit does nothing 
7 
EFTA00622946

to establish that his failure to respond to the Complaint was a result of excusable 
neglect. 
31. 
Rothstein's counsel, Mark Nurik, also asserts that he did not have 
knowledge of the lawsuit until "recently." See Motion to Set Aside Default ¶6 — 7. 
32. 
However, nine separate news articles (attached as composite Exhibit H) 
including The Palm Beach Post (12/08/09), The Sun Sentinel (12/10/09), NBC Miami 
(12/08/09), The ABA Journal (12/09/09), South Florida Lawyers (12/10/09), 
huffingtonpost.com (12/11/09), The AmLaw Daily (12/08/09). Business Insider 
(12/10/09) and Courthouse News (12/16/09), reported Epstein's lawsuit against 
Rothstein. Notably, the articles were published within days of Rothstein being served 
with this lawsuit (December 9, 2009). Thus, Rothstein's and Nurik's assertions that they 
had no knowledge of this case until "recently" are belied by the widespread media 
coverage. 
33. 
Given the foregoing, it can hardly be said that Rothstein ignoring the 
properly served Complaint and Summons constitutes excusable neglect. 
34. 
Unlike Medcom where the defendant asserted he was not served (and in 
which the court nevertheless found said assertion insufficient), Rothstein does not even 
contest the fact he was served; he just does not remember it. How convenient, yet 
insufficient. 
35. 
As his assertions do not come close to rising to the level of excusable 
neglect, the Court should deny Rothstein's Motion to Set Aside Default. 
Rothstein Fails to Establish Due Diligence in Moving to Set Aside the Default 
36. 
Last, Rothstein must establish he acted with due diligence in moving to set 
8 
EFTA00622947

aside the default. a t Hill, 872 So. 2d at 921. 
37. 
Rothstein, in his affidavit, asserts that he learned of the lawsuit and default 
at some unspecified time in February, 2010 and then Immediately contacted [his) 
attorney and advise him of same which prompted the filing of my Motion to Set Aside 
Default and this Affidavit in Support thereof." See Exhibit D ¶8. 
38. 
However, Rothstein fails to explain how he learned of this lawsuit or 
exactly when in February, 2010 he learned of It. 
39. 
Rothstein filed his Motion to Set Aside Default on February 17, 2010. If 
Rothstein learned that a default was entered against him on February 1, 2010, for 
example, but failed to file anything for over three weeks, it can be argued he failed to 
exercise due diligence in moving to set aside the default. 
40. 
But since Rothstein does not articulate how or exactly when he learned of 
the default, it is unclear whether Rothstein acted with due diligence in moving to set 
aside the default entered against him. 
41. 
Accordingly, Rothstein has failed to meet his burden to establish the due 
diligence element. See Zivitz 16 So. 3d at 849 (holding that the party seeking to set 
aside the default has the burden to demonstrate due diligence in seeking relief from 
default, excusable neglect and a meritorious defense). 
Conclusion 
42. 
Since Rothstein has failed to establish a meritorious defense to the 
allegations in the Complaint, excusable neglect in failing to respond to the Complaint 
and due diligence in moving to set aside the default, the Court must deny Rothstein's 
Motion to Set Aside Default. 
EFTA00622948

Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. 
Mail to the following addressees on this 
Gary M. Farmer, Jr., Esq. 
=armar, Jaffe, Weissing, Edwards, Fistos 
& Ishrman, PL 
425 N. Andrews Avenue, Suite 2 
=ort Lauderdale, FL 33301 
- fax 
Attorneys for Defendant, L.M. 
ack Scarola, Esq. 
Seamy 
Denney 
Scarola 
Barnhart 
Sh'pley, P.A 
2139 Palm Beach Lakes Blvd. 
Beach, FL 33409 
F 
Attorneys for Defendant Bradley Edwards 
day of  May  , 2010: 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach FL 33401-5012 
Fax: 
Co-Counsel for Defendant Jeffrey Epstein 
Law Offices of Marc S. Nurik 
& Counsel to Scott Rothstein 
One East Broward Boulevard, Suite 700 
Fort Lauderdale, FL 33301 
BURMAN, CRITTON, LUT nER & COLEMAN, LLP 
303 Banyan Boulevard 
Suite 400 
West Palm Beach, FL 33401 
-ax 
By: 
+)Ift
e D. Critton, Jr. 
lorida Bar #224162 
Michael J. Pike 
Florida Bar #617296 
(Counsel for Defendant Jeffrey Epstein) 
10 
EFTA00622949

VERIFIED RETURPINF SERVICE 
I
IN THE 15Th JUDICIAL CIRCUIT IN AND  OR PALM BEACH COUNTY FLORIDA 
TYPE OF WRIT: AMENDED SpMMONS & COMPLAINT 
. 
CASE NO: 502009CA040800XXXXM8 AG 
•-
PLAINTIFF 
JEFFREY EPSTEIN 
TO: Scott Rothstein. Register 091258-004 
do FCC, Miami 
1. 
Federal Detention Center 
33 NE 4^ Street 
Miami, FL. 33132 
DEFENDANT(8) 
vs. 
SCOTT ROTHSTEIN, individually 
et-el., 
i. 
it 
PURSUANT TO THE REQUEST OF: ROBERT O. CRITITON, JR., ESO.,WHOSE OFFICE IS LOCATED AT: 
303 BANYAN BLVD.. SUITE 400, WEST PALM MACS. FL. 33401 
',CARLOS AGUIRRE C.P.S 0 810 RECEIVED THIS PROCESS ON: 1219/09 0  8:00am 
AND SERVED THE SAME ON: 12/9/09 0  8:45am IN BADE COUNTY FLORIDA. 
( X ) INDIVIDUAL SERVICE: BY SERVING THE PERSN
E
 NAMED HEREIN A COPY OF THE AMENDED 
SUMMONS COMPLAINT, PETITION OR INITIAL PL 
ING. 
COMMENTS: DESCRIPTION OF PERSON SERVED: WHITE MALE, 47 YEARS OLD. ABOUT 6'7 
ABOUT 200Ibs., GREY SHORT HAIR. 
I ACKNOWLEDGE, THAT I AM A CERTIFIED PROCESS SERVER IN THE CIRCUIT IN WHICH THIS 
PROCESS WAS SERVED AND THAT I HAVE NO IN REST IN THIS MATTER. 
UNDER PENALTY OF PERJURY, I DECLARE THAT liREAD THE FOREGOING VERIFIED RETURN OF 
SERVICE AND THE FACTS STATED IN IT ARE TRUE. 
CARLOS AGUIRRE C.P.S III 810 
)1. -ry 
.1/6
EXHIBIT
 
IL 
EFTA00622950

IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN 
AND FOR PALM BEACH COUNTY, 
FLORIDA 
REV PPSTEIN 
Plaintiff, 
v. 
t3CtrT Roil 'STEIN, Individually, 
; IRADLEY O. EDWARDS, individually, 
Individually, 
Defendants. 
 
/ 
Complex Litigation, Pa. R. Civ. Pro.1201 
CASE NO.502009CA040800XXXXMB AG 
n/ n 
\(): 16 
4CPgo 
AMENDED SUMMONS 
(Have not attempted to serve — Amended only as to Place of Service) 
PERSONAL SERVICE ON A NATURAL PERSON 
TC DEFENDANT(S): 
Scott Rothstein, Register #91256.004 
c/o FDC, Miami 
Federal Detention Center 
33 NE 41h Street 
Miami, FL 33132 
IMPORTANT 
A lawsuit has been filed against you. You have 20 calendar days after this 
stir:mons !s served on you to file a written response to the attached complaint/petition 
with the Clerk of this Court. A phone call will not protect you. Your written response, 
!ncluding the case number given above and the names of the parties, must be filed if 
you want the Court to hear your side of this case. If you do not file your response on 
t!me, you may lose the case, and your wages, money, and property may thereafter be 
taken without further warning from the Court. There are other legal requirements. You 
may want to call an attorney right away. if you do not know an attorney, you may call 
an attorney referral service or a legal aid office (listed in the phone book). 
SHARON R. BOCK 
Clerk & Comptroller 
P.O. Box 4667 
West Palm Beach, 
33402-4667 
EFTA00622951

vs. 
Casa No: 
If you choose to file a written response yourself, at the same time you file your 
written response to the Court you must also mail or take a copy of your written response 
to :is `Plaintiff/Plaintiffs Attorney named below. 
10BERT D. CRITTON, JR. 
3URMAN, CRITTON, LUTTIER & COLEMAN 
303 Banyan Boulevard 
Suite 400 
West Palm Beach, FL 33401 
561/842-2820 
7HE STATE OF FLORIDA: 
TC EACH SHERIFF OF THE STATE: 
YOU ARE COMMANDED to serve this 
summons and a copy of the complaint/petition In this action the above-named 
Defendant. 
DATED ON  December 8, 2009 
SHARON R. BOCK 
CLERK OF THE CIRCUIT COURT 
(SEAL) 
EQNA SMITH 
BY: 
DEPUTY CLERK 
(See Reverse Side) 
(Vease al :eves) 
(Voir de L'autre cote de) 
EFTA00622952

VS. 
Case No: 
IMPORTANTE 
Usted ha sido demandado legalmente. Tine 20 Dias, contados a partir del recibo 
de esta notificacior•., para contestar la demanda adjunta, por escrito, y presentada ante 
este tribunal. Una llamada atelefonica no. lo protegera. Si usted desea que el tribunal 
cor.s!clere se defensa, dobe presentar su respuesta por escrito, Incluyendo el numero del 
caso y los nombres de las partes Interesadas. Si usted no contesta la demanda a tiempo, 
pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o privado 
de sus derechos, sin previo aviso del tribunal. Existen ostros requisitos legales. SI lo 
desea, puede usted consultar a un abogado immedlatamente. 
Si no conoce a un 
abogado, puede llamar a una de las oficinas de asistencia legai que aparecen en la gula 
telefonica. 
Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta 
su respuesta ante el tribunal usted enviar por correo o entegar una copla de su respuesta 
a la persona deominada abajo como "Plaintiff/Plaintiffs Attorney" (Demandante o 
Abogado del Demandante). 
1MPORANT 
Dos poursuites judiclares ont ete onterprises contre vous. Vous avez 20 jours 
consecutifs a partir de la date de l'assignation de cette citation pour deposer une reponse 
ecrite a la plainte ci-jointe aupres de ce tribunal. Un simple coupe de telephone est 
insuffisant pour vous proteger. Vous etes oblige de deposer votre reponse ecrite, avec 
mention du numero de dossier ci-dessus et du nom des indios nommees ici, si vous 
souhaitez que le tribunal entende voutre cause. Si vous ne deposez pas votre reponse 
ecrite dans le reta'. requis, vouc risquez de perdre la cause alnsi que votre salaire, votre 
argant, et vos biens peuvent otra salsis par la suite, sans aucun preavis ulterieur du 
tdbunal. 
II y a d'autres obligations juridiques et vous pouvez requerir les services 
irnnediats d'un avocat. SI vous no connaissez pas d'avocat, vous pourriez telephoner a 
ur service de reerence d'avocats ou a un bureau d'assistanco juridique (figurant a 
l'annuaíre de telephones). 
Si vous choisissez de deposer vous-mame une response ecrite, II vous faudra 
egalement, en memo temps que cette formalite, faite parvenir ou expedier une copie de 
votre reponse ecrite au uPlaintiff/Plaintiffs Attorney" (Plaignant ou a son avocat) nomme 
d-dessous. 
EFTA00622953

IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN AND 
Case No. 50 2009CA040800XXXXMB AG 
JEFFREY EPSTEIN 
Plaintiff, 
AFFIDAVIT OF CARLOS AGUIRRE 
STATE OF FLORIDA 
) 
MIAMI-DADE COUNTY 
) 
BEFORE 
ME, 
the 
undersigned 
authority 
personally 
appeared 
having personal knowledge and being duly sworn, deposes and says: 
1. 
I, Carlos Aguirre, am certified by the State of Florida to serve legal 
process, C.P.S. 0810. 
2. 
I was hired by the law firm of Burman. Crittor., Luther & Coleman to serve 
process in this matter on the Defendant, Scott Rothstein. 
3. 
On December 8, 2009, I contacted the Federal Bureau of Prisons via 
facsimile requesting to serve process on Scott Rothstein. 
4. 
On December 9, 2009, I arrived at the Federal Detention Center in Miami, 
Florida and personally served Scott Rothstein with the Complaint and Amended 
Summons at approximately 8:45 a.m. 
5. 
Mr. Rothstein was in a hallway, out of his cell, with other prisoners. A 
EXHIBIT B 
EFTA00622954

guard called Mr. Rothstein's name and he came forward. I personally placed the 
Complaint and Amended Summons in Mr. Rothstein's hands and advised him that he 
was being served with a lawsuit. Mr. Rothstein then turned and walked away with the 
papers I served him. 
FURTHER THE AFFIANT SAYETH NAUGHT. 
Carlos Aguirre 
STATE OF FLORIDA 
MAMI-DADE COUNTY 
I hereby Certify that on this day, before me, an officer duly authorized to 
administer oaths and take acknowledgments, personally appeared Carlos Aguirre 
krown to me to be the person described in and who executed the foregoing Affidavit, 
who acknowledged before me that he/she executed the same, that I relied upon the 
following form(s) of identification of the above named person: [
s/J'
 nd that 
an oath was/wee-fel taken. 
WITNESS my hand and official seal in the County and State last aforesaid this 
gj~j i dav of 
, 2010. 
PR1N 
(SEAL) 
NOTAI&Y PUBLIC/STATE OF FLORIDA 
COMMISSION NO.: 
2 
e
°04. Notary Pubic Slate of Butte 
7: Jason Roberts 
iry lay Con mission DC10193419 
-loge 
Expbes Dint/2014 
EFTA00622955

F 
IN THE 
.C.`1.11T COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH 
COUNTY, FLORIDA 
Case Number: 502009CA040800XXXXMB 
Division: 
AG 
its
 REY EPSTEIN 
Plaintill(s), 
SCOTT ROTHSTEIN, individually, 
BRADLEY S. EDWARDS individually 
and L.M. individually 
Defendant(s), 
DEFAULT 
A default is entered in the above styled cause against: SCOTT RO'FIIS'TEIN, Individually for 
failure to serve a pleading at the time required by law. 
DONE AND ORDERED at the Clerk's Office, City of West Palm Beach, this 21 day of 
JANUARY, 2010. 
Sharon R. Bock 
Clerk & Comptroller 
By: 
KIMBERLY BRADLEY 
Deputy Clerk 
Copies furnished to: 
BURMAN, CRITTON, LOTT= & COLEMAN LLP 303 BANYAN BLVD., STE 400, WEST PALM BEACH, 
FL 33401.4349 
SCOTT ROTHSTEIN, INDIVIDUALLY C/O FDC, MIAMI FEDERAL DETENTION CENTER, 33 NB 4Th
STREET, MIAMI, FL 33132 
GARY FARMER , BSQ , 425 N. ANDREWS AVENUE, SUITE 2, FT. LAUDERDALE, FL 33301 
JOHN SCAROLA , ESQ , 2139 PALM BEACH LAKES BLVD WEST PALM BEACH, FL 33409 
PADULA & GRANT, PLLC 365 B. PALMETTO PARK ROAD, BOCA RATON, FL 33432-S013 
7:1)(H933rr C.{ 
EFTA00622956

IN THE CIRCUIT COURT OF THE FIFTEENTH 
JUDICIAL CIRCUIT IN AND FOR PALM 
BEACH COUNTY, FLORIDA 
CASE NO.: 2009 CA 040800 XXXXMB 
HONORABLE JUDGE DAVID F. CROW 
JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, BRADLEY 
J. EDWARDS, and LM, 
Defendants. 
AFFIDAVIT OF SCOTT W. ROTHSTEIN 
IN SUPPORT OF MOTION TO SET ASIDE DEFAULT 
STATE OF FLORIDA 
) ss.: 
COUNTY OF 
Before me, the undersigned authority, personally appeared, SCOTT W. ROTHSTEIN, 
who after being by me first duly sworn, on oath, deposes and states as follows: 
1. 
I am a Defendant in the above•captioned matter. 
2. 
I did not respond to the Summons and Complaint in this lawsuit because I did not 
have knowledge of its existence until February, 2010. In February 2010, I learned that this 
lawsuit was filed against me and that a default judgment had been entered against me for failure 
to respond. 
3. 
From December 1, 2009 until March I, 2010, I was detained at the Federal 
Detention Center in Miami, Florida'. 
On March I, 2010,1 was transferred to the Pon St. Lucie jail. 
Flt1661522:1 
EXHIBIT. D 
EFTA00622957

4. 
During that time frame I was pulled out of my cell many times by the Bureau of 
Prisons staff to receive service of lawsuits at all hours. 
5. 
Inasmuch as the Bureau of Prisons rules and regulations do not allow a prisoner to 
hand any documents to any visitors, including counsel, upon service of various lawsuits, I simply 
informed my attorney who would then look up the case with the appropriate court and contact 
the attorney for the plaintifffs) in such cases and/or take whatever appropriate action was 
necessary. 
6. 
To the best of my knowledge and belief, I do not recall being served with this 
lawsuit. If I was properly served with this lawsuit, it has been misplaced within the pile of 
numerous lawsuits and voluminous amount of other legal papers and has not been located. Even 
to date, I have not located the Complaint or Plaintiffs Motion for Default.2
7. 
1 state in good faith that if I had actual knowledge of this lawsuit I would have 
advised my attorney as I have done with various other lawsuits currently pending against me. 
8. 
As soon as I learned of the lawsuit, I immediately contacted my attorney and 
advised him of same which prompted the filing of my Motion to Set Aside Default and this 
Affidavit in Support thereof. 
9. 
I have a viable defense to the allegations contained in the Plaintiff, Jeffrey 
Epstein's ("Plaintiff" or "Epstein"), Complaint. Without providing a detailed response to the 
Complaint herein, just one of many meritorious defenses to the Complaint is that at least one, if 
not more, of the lawsuits against Plaintiff which he references as the basis of this instant lawsuit 
(the "Civil Actions"), was filed with the court on behalf of certain clients by a defendant herein, 
Bradley Edwards ("Edwards"), prior to his employment as an attorney at the law firm Rothstein 
Rosenfeldt Adler ("RRA"). The fact that Edwards, prior to his employment with RRA, and prior 
2 Since learning of this lawsuit, my attorney obtained a copy of the Complaint 
2 
EFTA00622958

to our introductions with one another, already had client(s) suing Epstein in Civil Actions, goes 
against several counts in the Complaint, including, but not limited to, the RICO count. In fact, 
the Civil Actions filed by Edwards and/or other attorneys at RRA were and are real cases, with 
real plaintiffs that have real claims against Epstein and, this instant lawsuit is Plaintiff's feeble 
attempt to take advantage of my unfortunate circumstances to disqualify claims by real persons 
that deserve to have their day in court. 
10. 
I respectfully submit that if the Court were to disallow my Motion to Set Aside 
Default, not only would I be extremely prejudiced inasmuch as I have viable defenses to the 
allegations contained in Plaintiffs Complaint, but the plaintiffs in the Civil Actions that Edwards 
and others at RRA filed against Epstein which he references in his Complaint in this matter,
would be prejudiced as well. A default entered against me in this matter would have the same 
effect as my admission to the assertions made by Plaintiff which would, in essence, allow 
Epstein to prevail against the plaintiffs in the Civil Actions on the basis that they are frivolous 
and fraudulent lawsuits, which they arc not. 
Under penalties of perjury, I declare that I have read the foregoing affidavit and the facts 
stated in it are true. 
voranamm• 
3 
EFTA00622959

STATE OF FLORIDA 
Y r k).3c14. C-tmrs.1.0 
)ss.: 
BEFORE ME the undersigned authority, personally appeared SCOTT W. ROTHSTEIN, 
who after being by me first duly sworn on oath deposes and says that he is the Defendant in the 
above-styled cause; that he has read the foregoing Affidavit and the facts contained herein are 
true and correct. 
SWORN TO AND SUBSCRIBED before me this  VS  day of  t nerdn
2010, by SCOTT W. ROTHSTEIN, who is personally known to me or who has produced 
Cix,,,
as identification. 
fRtt.iO 
TARY PUBLIC 
Typed or Printed Nand;
Notary Public 
My commission expires: 
NOTARY KM/Pa P eTiAjt & 
PIAtnDA 
MUM 
O tt 
ISE IM2013 
RONDO MO ATIAVI IC KetIMGCO, see 
4 
EFTA00622960

IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN 
AND FOR PALM BEACH COUNTY, 
FLORIDA 
JE TREY :iPSTEIN 
Complex Litigation, Fla. R. Civ. Pro.1201 
Plaintiff, 
v. 
SCOTT RO'UISTEIN, Individually, 
BRADLEY J. EDWARDS, 
dIvIdually, and L.M., Individually, 
Defendants.. 
Case No. 50 2009CA040800XXXXMB AG 
ORDER ON DEFENDANT SCOTT ROTHSTEIN'S MOTION TO SET ASIDE DEFAULT 
THIS CAUSE came before tho,Court on Defendant Scott Rothstein's Motion to 
Set Aside Default, and the Court having heard argument of counsel and being fully 
advised in these premises, It is hereby 
ORDERED and ADJUDGED that said Defendant's Motion is hereby .grantedt 
_denied-- ,lert.(c4- 
I 6'/ 
009.? cc. kit nsrt 
• 
9 / P. 
/ 1 MY Ove-t) /et 4.e,(61 
///1077cM
DONE AND ORDERED at Palm Beach County-C rthouse, 
ost P=Im Beach, 
Florida, this 
• 
day of  1/412iall-• • 
 , 2010 
i 
David F. Crow 
Circuit Judge 
iNT E 
Copied furnished to: 
ROBERT D. CRITTON, JR., ESQ., Burman, Dillon, Luther & Coleman, 303 Banyan Boulevard, Suite 
400, West Palm Beach, FL 33401, MARC S. NURIK, ESQ., Law Offices of Mark S. Nurik, 
One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301, GARY M. FARMER, 
JR., ESQ., Farmer, Jaffe, Welssing, Edwards, Fistos & Lehrman, PL. 425 N. Andrews Avenue, Suite 2, 
Fort Lauderdale, FL 33301, JACK SCAROLA, ESQ., Searcy Denney Scarola Barnhart & Shipley. PA. 
2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409, and JACK ALAN GOLDBERGER, ESQ., 
Atterbury Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 
33401.5012 
EFTA00622961

IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN 
AND FOR PALM BEACH COUNTY, 
FLORIDA 
.; 
iPSTEIN 
Complex Litigation, Fla. R. Clv. Pro.1201 
Plaintiff, 
V 
SCOTT ROTHSTEN, individually, 
AAOLEY J. EDWARDS, 
!ne!vidualiy, and L.M., individually, 
Case No. 60 2009CA040800XXXXMB AG 
Defendants. 
• 
I 
ORDER ON MOTION TO STRIKE AFFIDAVIT OF SCOTT ROTHSTEIN 
THIS CAUSE came before the Court on Motion to Strike Affidavit of Scott 
Rothstein, and the Court having heard argument of counsel and being fully advised in 
these premises, it is hereby 
ORDERED and ADJUDGED that said Motion is hereby 
ihb-itezAer.,  
Attrn 
wri / 
-42.,  
5 0 do-e3,...s -7‘.) 
4,4 A-f-fr-76 O67‘,,-; eitziortfrey es, 4 It- .1 :erth 
DONE AND ORDERED at Palm Beach C fir Courtho se, 
esLealm-Beach, 
Florida, this faelay  of  ara  20 
CUL 
David F. Crow 
Circuit Judge 
ft "*.larn
.....ikfludJ I 
Copied furnished to: 
ROBERT D. CRITTON, JR., ESQ., Burman, Critton, Luster & Coleman, 303 Banyan Boulevard, Suite 
400, West Palm Beach, FL 33401, MARC S. NURIK, ESQ., Law Offices of Marc S. Nurik, One East 
Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301. GARY M. FARMER. JR., ESQ., Farmer, Jaffe, 
Weissing, Edwards, Fistos & Lehrman, PL. 425 N. Andrews Avenue. Suite 2, Fort Lauderdale, FL 33301, 
JACK SCAROLA, ESQ., Searcy Donney Smola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd., 
West Palm Beach, FL 33409, and JACK ALAN GOLDBERGER, ESQ., Allerbury Goldberger & Weiss, 
PA., 250 Australian Avenue South, Suite 1400, West Palm Beach. FL 33401.5012 
I.
EFTA00622962

South Florida Business Journal: Rothstein sentencing moved to June 9 
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Blog: 
Scott 
Rothstein: 
Picking 
up the Pieces 
Rothstein 
Sentencing 
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Oust is not nemssaely so twining, tut the reasons sewn pretty watt 
Thews • meson flan Rothstein's attorney, Marc Nan. hers unlike Inlyaing Inn soon In a 
ten case recentry. 
Moak clans that ItOttateln's cooperation with loyal &Lifeline, by 
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providing evidlniaa lot alleged walla slangs has Interfered with iturik's 
eliaty to thmawnkete with Mn. 
Recording to federal authorities and numerous media rigor% itOttritthi 
helped eel up Oa Employees of fns Star f mortars Protection IL 
lavestigatke, a local security Rem that had On to the maw, and Roberto 
Settincn. an ahead Sicilian man. Mclennan In Swath Florida. Al throe 
were hit with federal indictments arty Rothstein *leveed, asked them to 
wonder money end destroy evWenat of his Pont; scheme. 
this comes after the first sealed document was thed In Rotinteirts mkrinel 
case, which is a nivel that might moan the lids are leconvninOlnq a lighter sentence 
because of cooperation. 
Ninth MIAthalsbLgthMthal to anent, • smelmscrem of reimewhon so that the pal* and 
arta% alleged criminals wculd tl'ata that Rothlten was flatatim federal paisthcbas bekre 
P. mu evicted. 
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Hues the reevaM text of Nurilfs request for a Wet untenclip date: 
•SeeCtcallYr the defendant is presently in pieta-WO lousing Outside of this district and 
treated aftrenlly than other Imsates. Undersigned es:winters contacts with Ms cant wrest be 
arranged and approved in advance through the gOverimoM, which creates delay. 
'there have teen inalleten *Xenia'''. In the past ren Milan when undersigned counsel has 
been unaware el his client's Ithatim and has been repeatedly out ea OMNI With Ni clent 
substanthil needs of that. Incluang one peeled for over two meas. 
'Given these IngtatUns, In the past five rade, counsel has only been able to meet with his 
client on two occasions. Cuireatiy, there is no Sly 
to mind the dtrendet, had phone 
contact is very kilted. Even the sending and receipt of legal mall Daft kinder than the 
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Rothstein was to be senteraed May 6. The new date Heine 9, at 9:30 ast 
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http://southflorida.bizjournals.com/southflorida/blog/picking_up_the_pieces/2010/04/roths... 4/23/2010 
EFTA00622963