EFTA00724224

STATE OF FLORIDA 
51-Lucto. cout‘le) 
)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 c use; that he has read the foregoing Affidavit and the facts contained herein are 
true and correct. 
SWORN TO AND SUBSCRIBED before me this  ceS  day of  Merl
2010, by SCOTT W. ROTHSTEIN, who is personally known to me or who has produced 
%Lucie Co•ASSX4 7—Qas identification. 
r-"?th,fO 
TARY PUBLIC eir 
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E 1- 20 
Typed or Printed N 
of 
Notary Public 
My commission expires: 
NOTARY PUBLICSTATE OF FLORIDA 
Patrick B. Hogan 
Commission #01)910543 
Expires: 
SEP. 25, 2013 
HOMO Ilato Anditalt IKRIDLNG CO, DC, 
4 
EFTA00724244

IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN 
AND FOR PALM BEACH COUNTY, 
FLORIDA 
JEFFREY EPSTEIN 
Complex Litigation, Fla. R. Civ. Pro.1201 
Plaintiff, 
v. 
SCOTT ROTHSTEIN, individually, 
BRADLEY J. EDVIDS, 
individually, and 
., individually, 
Defendants.. 
Case No. 50 2009CA040800)000(MB AG 
ORDER ON DEFENDANT SCOTT ROTHSTEIN'S MOTION TO SET ASIDE DEFAULT 
THIS CAUSE came before the,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 .grentedt 
_denied— , 
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DONE AND 
.7?"4 
ORDERED at Palm Beach County 
rthouse, 
Im Beach, 
Florida, this 
# 
day of  iga/t-• 
 2010 ( 
David F. Crow 
Circuit Judge 
EXHIBIT E'
Copied furnished to: 
ROBERT D. CRITTON, JR., ESQ., Burman, Critton, Luttier & 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, Weissing, Edwards, Fistos & Lehrman, PL.. 425 N. Andrews Avenue, Suite 2, 
Fort Lauderdale, FL 33301, JACK SCAROLA, ESQ., Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409, and JACK ALAN GOLDBERGER, ESQ., 
Attorbury Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 
33401-5012 
EFTA00724245

IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN 
AND FOR PALM BEACH COUNTY, 
FLORIDA 
JEFFREY EPSTEIN 
Complex Litigation, Fla. R. Civ. Pro.1201 
Plaintiff, 
v. 
SCOTT ROTHSTEIN, individually, 
BRADLEY J. EDWARDS, 
individually, and.., individually, 
Defendants. 
• 
/ 
Case No. 50 2009CA040800XXXXMB AG 
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 
fidlAittAl.v/  
Attin 
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DONE AND ORDERED at Palm Beach C 
Courtho se, 
est 
trn-Beach, 
Florida, this 6 2
  day of 
David F. Crow 
Circuit Judge 
EXHIBIT E 
Copied furnished to: 
ROBERT D. CRITTON, JR., ESQ., Burman, Critton, Luttier & 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 Denney Scarola Barnhart & Shipley, P.A. 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 
L. 
EFTA00724246

South Florida Business Journal: Rothstein sentencing moved to June 9 
Page 1 of 2 
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A Judge has moved Pearl sdieMer Stott Rothstein's sentencing back more than a month. 
That es not necessivey so unusual, but the reasons seem pretty weird. 
There's a motion from ROthstelnl attorney, Marc Plunk, that's unlike anything rye seen In a 
court case recently. 
start mew 
This canes after the first sealed deo-mein was Med In Rothstein's amuse 
case, which is a signal that might moan the feds we recommending s lighter sentence 
because of COMMration. 
Ruck has already admitted to aeatirg a SmokesCreen of misdirection so that the public and 
certain alleged crIrrimals would think mat Rothstein was flaunting federal gurisdlcUon before 
: he was arrested. 
Hunk dans that Ftothstein's cooperation with federel authonties by 
providing evidence for alleged mafla slings has Interfered with Nurik's 
ability to communicate with him. 
According to federal authorities and numerous media reports, Rothstein 
helped set up two enViCireS of Five Star ececuthe Protection & 
Investigation, a local Manny Wm that had ties to the meta, rind Roberto 
Settinen, an alleged SlOkan mare connection In South Florida. MI three 
were hit with redcoat indkunents alter Rothstein allegeely asked them to 
launder money and destroy evidence of his POMi scheme. 
Here's the relevant text of Rurlis recpest for a later sentencing date: 
TSpecifKaY, the defendant is presently in protective housing outside of this district arra 
tinted differently than other inmates undersigned counsel's contacts with his client trust be 
arranged and approved in advance through the government, which creates delay. 
"There have been numerous occasions in the past few months when undersigned counsel has 
been unaware of his client's location and has been repeatedly out of contact with his tient for 
substartral penods of time, incloSing ono period for over two weeks. 
"Given those imitations, in the pest Ave weeks, counsel has only been able to meet with his 
! Sent on two occasions. Currently, there is no ability to e-mad the defendant, aid phone 
i contact is wiry limited. even the senate') and maw of legal mad takes ranger than the 
I norm. 
Rothstein was to be sentenced Hay 6. The new date at hoe 9, at 9:30 
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http://southflorida.bizjoumals.com/southflorida/blog/picicing_up_the_pieces/2010/04/roths... 4/23/2010 
EFTA00724247

South Florida Business Journal: Rothstein sentencing moved to June 9 
Page 2 of 2 
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http://southflotida.bizjounials.coin/southflorida/blog/picldng_up_thcsieces/2010/04/roths... 4/23/2010 
EFTA00724248

Rothstein, Epstein scandals converge with sex offender claiming he was used in swindle 
Page 1 of 2 
The Palm Beach Post 
Print this page 
Close 
Rothstein, Epstein scandals converge with sex 
offender claiming he was used in swindle 
By JANE MUSGRAVE 
Palm Beach Post Staff Writer 
Updated: 7:51 p.m. Tuesday, Dec. 8, 2009 
Posted: 9:27 p.m. Monday, Dec. 7. 2009 
Two of the biggest scandals to rock South Florida in recent years merged today when attorneys 
representing billionaire sex offender Jeffrey Epstein filed a lawsuit claiming the part-lime Palm Beach 
resident is the victim of accused swindler Scott Rothstein. 
Rothstein, who is accused of running a $1.2 billion Ponzi scheme from his Fort Lauderdale-based law 
firm, trumped up civil lawsuits against Epstein, according to the complaint filed in Palm Beach County 
Circuit Court. He then lured investors by telling them Epstein had agreed to settle the lawsuits for as 
much as $200 million and they could get a cut of the cash. 
The problem for investors, according to the lawsuit filed by West Palm Beach attorney Robert Critton, is 
that Epstein never agr
tle the lawsuits filed on behalf of women who are identified only by 
pseudonyms, such as 
"The offer of a $200 million settlement by Epstein was completely fabricated," Critton wrote. "No such 
otter had ever been made." 
Epstein faces roughly two dozens lawsuits filed by women who claim they were teenagers when he lured 
them to his Palm Beach mansion and paid them for massages and sex. The lawsuits started rolling in 
after he pleaded guilty in 2008 to felony solicitation of prostitution and procuring teenagers for 
prostitution. He was released from jail in July after serving 13 months of an 18-month sentence. 
Attorneys who worked for Rothstein, including Bradley Edwards and former Palm Beach County Circuit 
Judge William Berger, handled the three lawsuits the firm filed. But, they said, those represent only a 
fraction of the young women who Epstein molested. 
"What the evidence is really going to show is that Mr. Epstein . .. has every single day of his life made an 
attempt to sexually abuse children," Edwards said at a July court hearing. "We're not talking about five, 
we're not talking about 20, we're not talking about 100, we're not talking about 400 . . . we're talking 
about thousands of children." 
Such talk was part of a carefully orchestrated scheme to convince Investors they stood to make millions 
by investing with Rothstein, Critton said. 
Likewise, Critton said, Edwards has said he intends to depose various luminaries to testify against 
Epstein. Former president Bill Clinton, business mogul Donald Trump, former Sony Record president 
Tommy Mottola and magician David Copperfield have all been identified in court papers as people that 
will be deposed. 
While friends or acquaintances of Epstein, they have no information about the women involved in the 
lawsuits, Critton said, 
"The sole purpose in the scheduling of these depositions or listing high profile friends/acquaintances as 40nrik, 
potential witnesses was, again, to 'pump' the cases to investors," Critton wrote. 
EXHIBIT ft 
http://www.palmbeachpost.cominews/erime/rothstein-epstein-scandals-converge-with-sex-... 3/29/2010 
EFTA00724249

Rothstein, Epstein scandals converge with sex offender claiming he was used in swindle 
Page 2 of 2 
Neither Edwards or Berger responded to phone calls for comment. 
Critton isn't the first to make allegations that Rothstein fabricated cases as a way to lure investors. 
Fort Lauderdale attorney Wiliam Scherer, who has filed a $100 million lawsuit against Rothstein on 
behalf of scores of investors, has made similar claims. In a 147-page lawsuit, Scherer also said Rothstein 
told an investor about the phony $200 million settlement offer from Epstein. 
"He would use . . . cases as bait for luring investors into fictional cases," Scherer was quoted as saying. 
"All of the cases he allegedly structured were fictional. I don't believe there was a real one." 
Rothstein, a potent political fund-raiser who turned a small, unknown law firm into a powerhouse in seven 
short years. has pleaded not guilty to charges of RICO conspiracy, money-laundering conspiracy, mail 
fraud and two counts of wire fraud. His kingdom collapsed in late October when the feds raided his firm, 
Rothstein, Rosenfeldt & Adler. It is now closed. He has been disbarred. 
Find this article at: 
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http://www.palmbeachpost.c,om/newskrime/rothstein-epstein-scandals-converge-with-sex-... 3/29/2010 
EFTA00724250

: Epstein Claims Rothstein Link In Lawsuits - Sun Sentinel 
Page 1 of 2 
Adversiament 
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Epstein Claims Rothstein Link In Lawsuits 
Decanter 10.2009 1 Sy Jane ausgrave The Pan Beach Poet 
Wane the victim. 
We the oldest Ind( in the book when it comes to dodging ailegatonS of sexual abuse, aOCOrang to attorneys 
representing more than a dozen women who are sung Palm Beach billionaire Jeffrey Epstein. claiming he paid them 
le nude massages and sex when they were as young as 14. 
Epstein filed sub Monday in Palm Beach County Circuit Cowl, saying Porai scheme suspect Scott Rothstein trumped 
up lawsuits against him as part of a twisted money-making plan Sul while aimed at the Fort Lauderdale attorney. it Is 
Willing more than an effort to tarnsh the women, their attorneys said Tuesday. 
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'Ws We a SLAPP suit' said attorney Sid Garcia, who is representing a warren who says she was 17 when she was 
molested by the 58-year•Old financier. Epstein pleaded guilty in 2008 to solcitation of prostitution and ardnulMg 
teenagers for prostitution and served IS months of an 18-month sentence. 
An acronym for 'strategic lawsuit against public pantipation; SLAPPs are most correnOnly used by developers to 
silence critics by scaring them with the prospect of huge legal bills. 
'Ws really not directed at Rothstein." Garcia said of the lawsuit -Ws an attempt to make his victims looks bad by 
association.' 
Attorney Spencer Kenn, who won a Confidential senlement from Epstein for one woman and Is representing another 
M a pending lawsuit, agreed. 
In the lawsuit tiled by West Palm Beach attorney Robert Critters Epstein claims Rothstein used the lawsuits to lure 
investors as pan of a 51.2 beon Ponzi scheme. Trumpeting the chance to turn a quid( profit, Rothstein falsely 
reported that Epstein had agreed b settle the lawsuits tor as much as $200 rniffon. By paying a discounted rate up 
front they could ultimately cash in when the settlement was paid In he 
Rothstein, whose law firm collapsed after federal agents raided It In late October. last week pleaded not guilty to 
charges that he made millions running similar schemes shoe 2005. 
Britton claims Rothstein, with the help ce attorney Bradley Edwards, who worked for rim, pumped up investors by 
telling them they weed call such Wineries as loaner President Bill Clinton, business tycoon Donald Trump and 
magician David Coppetteld to testify against Epstein. The message was that Epstein would pay big to protect Ns 
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http://articles.sun-sentinel.com/2009-12-10/news/0912090393_1_ponZt-scheme-lawsuit-cl... 3/29/2010 
EFTA00724251

Epstein Claims Rothstein Link In Lawsuits - Sun Sentinel - Page 2 
Page 1 of 1 
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Epstein Claims Rothstein Link In Lawsuits 
Decanter 10, 2039 I By Jane Mayoral* The Palm Beech Post 
(Par 2 ol 
In the lawsuit, Craton atso goes after one of the three women who were represented by FICAAteisYS bun CI hal 
p6ints up contradictions in sworn statements the woman. dentilied only ass 
made lo FBI agents compared with 
those she node once to lawsuit watt feed 
in an interview with an FBI agent m 2007, ahe deathbed Epatem as -an awesome man• and described herself as a 
prostitute. 
She said none of the gels she took to Epelein ever complained. •Theyd beg me, you know. for us to go to Jeffreys 
house because they love Jeffrey. Jeffrey is a respectful wan," she said. 
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In a Septeritar deposition, nersiory Changed. •Ores they were there they were scared out of their rrthd," the said. 
'They did a any ways and SOTO of them walked Out and said, 1E. cicol ever do this to me again This is the worst 
thing that ever happened to me.'
Cretco said none of the women MIO we suing Epstein for Malone were drugged or coerced. They carnet to nis Palm 
Beach mansion freely. Many came 20.30 or CO times, some well after they turned 18 Further, he said. many either 
were or later became prostLtes or stdpoefs Any psychological problems they had had occurred well before they 
hooked up with Epstein. 
Kevin said such claims miss the point. 
This case is about whether or not a young girl has the capabllty to consent to inappropriate sexual contact: Ha 14-
year-Old asked an adult lo go get drunk, its the adult's responsibility to slap her not to driset her to the oat. he sad 
In these cases, he sad. Epstein solicited underage girls for sex. 
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http://artieles.sun-sentinel.cona/2009-12-10/news/0912090393_1_ponzi-scheme-lawsuit-cl... 3/29/2010 
EFTA00724252

Pervy Billionaire a Rothstein "Victim" I NBC Miami 
Page 1 of 2 
% MIAMI 
Ctea PRINTTH IS 
Powered by el aticabiiity 
Pervy Billionaire a Rothstein "Victim" 
Billionaire sex offender suing alleged Ponzi schemer 
By BRIAN HAMACHER 
Updaled 1:30 PM EDT, Tue, Dec 8.2009 
AP 
Billionaire sex offender Jeffrey Epstein isn't exactly a sympathetic figure, and his alleged weakness for 
underage prostitutes may have made him a target for accused con man Scott Rothstein. 
The Palm Beach mogul is accusing the alleged Fort Lauderdale Ponzi schemer of filing trumped-up 
sexual harassment lawsuits against him to help proliferate his massive $1.2 billion scam, run through his 
Rothstein Rosenfeldt Adler law firm. 
In a lawsuit filed today, Epstein alleges Rothstein told investors they'd get their hands on the nearly $200 
million in settlements that Epstein had worked out with RRA, according to the Palm Beach Post. 
Problem is, Epstein hadn't agreed to pay out. 
"The offer of a $200 million settlement by Epstein was completely fabricated," the suit reads. "No such 
offer had ever been made." 
http://www.printthis.clickability.com/pt/cpetaction-cptatitle=Pervy+Billionaire+a+Rothst... 3/29/2010 
EFTA00724253

Pervy Billionaire a Rothstein "Victim" I NBC Miami 
Page 2 of 2 
To make matters worse, Rothstein's lawyers were planning on calling some of Epstein's high profile 
buddies to testify in the cases, including Bill Clinton, Donald Trump and David Copperfield. 
"The sole purpose in the scheduling of these depositions or listing high profile friends/acquaintances as 
potential witnesses was, again, to 'pump' the cases to investors," the lawsuit reads. 
Rothstein, 47, is currently being held in a Miami federal prison, after he was charged last week with five 
counts related to his scheme, including fraud and racketeering. 
Epstein, 56, is a successful financier who pled guilty to procuring teenagers for prostitution in 2008 and 
did 13 months behind bars. 
First Published: Dec 8, 20091:11 PM EDT 
Find this article at: 
httpAvvew.nbcmiaml.comfnewsnocat-beat/Penry-Billionaire-a-Rothstezn-Victim-78704972 html 
Li Check the box to include the list of inks referenced in the article. 
O NBC Universal. Inc. I All Rights Reserved. 
http://www.printthis.clickability.com/pt/cpt?action=cptattitle—Pervy+Billionaire+a+Rothst... 3/29/2010 
EFTA00724254

Billionaire Sex Offender's Racketeering Suit: Rothstein Lawyers Lied About Me - News -... Page 1 of I 
Tort Law 
Billionaire Sex Offender's Racketeering Suit: Rothstein Lawyers Lied About 
Me 
Posted Dec 9, 2009 6:50 PM CDT 
By Martha Neil 
Just when it might have seemed that alleged wrongdoing related to the spectacular downfall of Rothstein 
Rosenfeldt Adler could not become more bizarre, a billionaire convicted sex offender has filed a civil racketeering 
lawsuit against two onetime partners of the South Florida law firm. 
Contending that they prejudiced his defense of criminal and civil actions related to his alleged sexual activities with 
underage teens by lying about the facts in order to "pump" a $1.2 billion Ponzi scheme that made use of the law 
firm name, Jeffrey Epstein is seeking injunctive relief, unspecified damages in excess of $15,000 and attorney fees. 
Among other allegations, his Palm Beach Circuit Court suit contends that Scott Rothstein, as well as others at the 
firm, falsely claimed to Investors in the Ponzi scheme that Epstein had offered to make a $200 million settlement 
and acted illegally and unethically in civil litigation against him that is still ongoing. 
A copy of the comp sin (PDF), which was filed Monday, is provided by the ekm Law Daily. In addition to criminal 
practices and racketeering counts, it asserts claims for abuse of process, fraud and conspiracy to commit fraud. 
Factually, it alleges that Rothstein and unspecified co-conspirators forged federal court orders and opinions, 
improperly intercepted conversations and pursued a litigation strategy unrelated to the merits of their clients' cases 
and their clients' interests in order to further the claimed Ponzi scheme. Rothstein told investors that he represented 
52 female clients in Epstein-related matters, the suit says, when in fact he had filed only 'weak" cases on behalf of 
exactly three young women. 
As detailed in earlier ABAJournal.com posts, Rothstein, who until recently was the RRA firm's managing partner 
and chief executive officer, is now jailed in a federal fraud case and the dissolving law firm is in receivership, facing 
multiple lawsuits. Rothstein also agreed to give up his Florida law license. 
Attorney Marc Nurik, a former RRA partner who is representing Rothstein in the criminal case, was not immediately 
available for comment, the Am Law Daily states. 
Epstein's suit was filed by attorney Robert Critton Jr. of Burman Critton Luther & Coleman in West Palm Beach. 
Additional coverage: 
ABAJournal.com: "Billionaire's Secret Sex Case Plea Deal Shows What a Good Defense Can Do' 
ABAJournal.com: "Filing: Rothstein Made $35M in 2008; Name Partner: I Wasn't Paid $6M" 
palm Beach Post: "Billionaire sex offender says he's a victim of Scott Rothstein" 
Palm Beach Post: 'Victims' lawyers say sex offender's lawsuit aimed at scaring female victims" 
Copyright 2010 American Bar Association. All rights reserved. 
http://www.abajoumal.com/news/article/billionaire_sex_offenders_racketeer_suit_says_rot... 3/29/2010 
EFTA00724255

South Florida Lawyers: Parsing the Epstein v. Rothstein Suit 
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Parsing the Epstein v. Rothstein Suit 
Palm Beach lawyers Robert Critton and Michael Pike have filed suit on 
behalf of Palm Beach billionaire Jeffrey Epstein against Rothstein and 
former RRA attorney Bradley J. Edwards in Palm Beach state court. 
You can read the complaint here. 
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http://southfloridalawyers.blogspot.com/2009/12/parsing-epstein-v-rothstein-suit.html 
3/29/2010 
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South Florida Lawyers: Parsing the Epstein v. Rothstein Suit 
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Much of the suit is a rehash of the Pont scheme allegations, and how 
Rothstein would talk up all the victims his firm represented that were 
reaching settlements with Epstein, except for some reason Epstein 
always had to pay out over time, even though the victims wanted the 
money right now. 
In actuality, according to the suit, RRA only represented three victims 
in pending litigation 
one in federal court, and two in state court. 
The complaint alleges that Epstein has been harmed in his defense of 
these sults, for a number of reasons. 
In particular, the suit really goes after Edwards, alleging that he knew 
or should have known that Rothstein was using the existing cases for 
purposes of promoting the Ponzl scheme. The complaint alleges that 
the RRA 'Litigation Team' served discovery that was unrelated to the 
three claims they were handling but with the sole purpose 
of 'pumping" the Ponzi Scheme and luring new investors. 
Specifically, the complaint alleges that RRA went after records of 
flights aboard Epstein's private jet where high-profile celebrities were 
allegedly on board when sexual assaults supposedly took place, and 
that the Litigation Team sought the depositions of these celebrities. 
Edwards allegedly took unnecessary depositions of the pilots, and 
asked inflammatory questions allegedly for the purpose of "pumping" 
the attractiveness of the Ponzi scheme. 
The witnesses allegedly on Edwards' deposition list included The 
Donald, Alan Dershowitz, Bill Clinton (of course), Tommy Mottola, and 
illusionist David Copperfield(?). Allegedly Rothstein would then go on 
to tell potential investors that Epstein is settling all these cases in 
order to protect his high-profile friends. 
The complaint goes on to detail other alleged discovery irregularities, 
including a deposition of Epstein (in which Russell Adler was in 
attendance), where lots of inflammatory questions were allegedly 
asked so the video of the deposition could be shown to new investors. 
The complaint also alleges that Edwards went overboard at hearings, 
and wildly overstated the extent of Epstein's alleged crimes again just 
to pump the scheme. Further, the complaint alleges that confidential 
client files of the three existing RRA cases against Epstein were shown 
to potential investors to induce them to invest, and that as a result 
the attorney-client privilege has been waived. 
The claims sound in Florida RICO, fraud, abuse of process etc. 
What to make of all this? 
Since the alleged discovery abuses occurred in the context of pending 
civil wits. Eostein's complaint raises the obvious auestion why the 
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http://southfloridalawyers.blogspot.com/2009/12/parsing-epstein-v-rothstein-suit.html 
3/29/2010 
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South Florida Lawyers: Parsing the Epstein v. Rothstein Suit 
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presiding Judge in those cases should not be dealing with the alleged 
lawyer misconduct? 
Moreover, the allegations against Edwards all involve serving allegedly 
outrageous discovery, making outrageous statements in court 
hearings, or doing outrageous things In pleadings. That places the 
allegations of the complaint at odds with the traditional protections 
afforded attorneys in the performance of their legal duties. 
I have no idea whether the allegations against Edwards are 
meritorious, or perhaps Epstein is trying to leverage the Rothstein 
revelations to assist him in defense of his pending suits. 
Either way the case is likely not going very far, and Epstein probably 
will have to seek his remedies if any in the pending cases where the 
alleged discovery misconduct took place. 
The more interesting jurisprudential question is what remedy, if any, 
could Investors (as opposed to Epstein) have if they were Induced to 
invest as a result of the lawyer activities detailed in the complaint? 
When you step back, the entire Rothstein saga, with Its many sad and 
pathetic twists, should cause the courts and policymakers to define a 
bit more clearly the extent to which lawyers should be afforded 
protection when they practice law •• which in the normal 
circumstance certainly makes sense -• as opposed to allegedly 
misusing and abusing the law and a Bar license in order to execute an 
incomprehensibly massive (not to mention illegal) moneymaking 
fraud. 
Labels: Bradley J. Edwards, Michael J. Pike Robert D. Crltton Jr. 
Russell S. Adler. Scott Rothstein 
8 comments: 
detention center junkie said... 
Epstein's suit Is a crock KIDDZZZ,leave the lawyers alone LOVE 
YA!! 
December 10. 2009 2:40 PM 
Anonymous said... 
Where did SFL find the Robert Critton wall sticker set? 
December 10, 2009 3:01 PM 
Anonymous said... 
The complaint talks about Judge Berger too. 
lkcember 10, 20O9 4:15 PM 
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http://southfloridalawyers.blogspot.com/2009/12/parsing-epstein-v-rothstein-suit.html 
3/29/2010 
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Jeffrey Epstein Sues Accused Ponzi Schemer Scott Rothstein For Misusing His Name 
Page 1 of 1 
March 29, 2010 
This is the print preview: Back to normal view 
Jeffrey Epstein Sues Accused Ponzi Schemer 
Scott Rothstein For Misusing His Name 
First Posted: 12-11-09 11:17 AM I Updated: 12-11-09 12:27 PM 
It's hard to know who to root for when two disgraced 
Florida financiers duke it out in court. 
CityFile reports that billionaire money manager Jeffrey 
pstein, who served 13 months in jail for soliciting a 
eenage girl for prostitution, is taking aim at accused Ponzi 
hemer Scott Rothstein. 
Earlier this year, state authorities charged Rothstein, a 
rominent Florida lawyer and powerful political fundraiser, 
with running a $1.2 billion Ponzi scheme. 
According the suit, Rothstein and his law firm's partners used Epstein's name to lure investors 
into his alleged scheme. Essentially, the suit says, Rothstein's firm claimed to have secured a $200 
million settlement with Epstein, and used that amount to 'pump" a fraudulent investment scheme. 
The suit also argues that Rothstein's firm claimed to represent 52 women who claimed to have 
been sexually abused by Epstein. In fact, Rothstein's firm only represented three such women in 
cases the suit describes as 'weak." 
Is Epstein, he of the allegedly egg-shaped penis, just piling on Rothstein's misfortunes? Read 
the complaint for yourself (hat tip to ABA Journal). 
Story continues below 
rothstein-complaint-1. 
http://www.huffingtonpost.com/2009/12/11/jeffrey-epstein-sues-accu_n_388787.html?vie... 
3/29/2010 
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Billionaire Slaps Scott Rothstein With Suit 
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Billionaire Slaps Scott Rothstein With Suit 
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December 8,2009 7:50 PM 
Billionaire Slaps Scott Rothstein With Suit 
Posted by Brian Baxter 
The almost daily developments in the bizarre saga of disbarred Fort Lauderdale lawyer Scott Rothstein seem almost too outlandish to be true. Here's the latest 
On Monday, sibling publication the Daily Business Review reported that the federal government will have first dibs on Rothstein's seized property if he is 
convicted, noting that the fraud allegations against Rothstein have hit the $1.6 billion mark. 
Now, another notorious Floridian has entered the Pierre. 
Billionaire money manager and convicted sex offender Jeffrey Epstein has filed suit against Rothstein, claiming that the disbarred lawyer touted a fictitious $200 
million sexual harassment settlement that Epstein was willing to pay as a guise to lure investors into his Pont' scheme. Epstein, represented by Robert Critton, 
Jr. of West Palm Beach's Burman Critter,. linnet & Coleman  filed his civil suit in Palm Beach County Circuit Court late Monday.
http://arnlawdaily.typepad.com/amlawdaily/2009/12/rothsteinsuit.html 
12/9/2009 
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Billionaire Slaps Scott Rothstein With Suit 
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According to the 36-case comolaim  Epstein accuses Rothstein of 'engaging in a pattern of racketeering that involved a staggering series of gravely serious 
obstructions of justice, actionable frauds, and 
egregious civil litigation abuses' that damaged Epstein and others. The complaint also accuses Rothstein of 
forging federal corn orders and opinions. 
In an interview with The Am Law Daily, Critton lashed out at Rothstein for fraudulently claiming that his client had agreed to pay $200 million to settle civil 
sexual harassment charges filed against Epstein by several women after the scandalous allegations against him first came to light in 2005. (In lune 2008 
Epstein's all-star lesal team negotiated a plea to two prostitution charges that infuriated Palm Beach's poke chief, who had already written a lever criticizing 
Bate prosecutors: Epstein was released this July after serving almost a year in prison.) 
Thee of the sexual harassment suits were filed by lawyers working for Rothstein. Critton says those same lawyers falsely claimed to represent many more 
women with potential claims against Epstein. The additional women never actually existed, Critton says, adding that they were merely introduced to entice 
investors to fund litigation against his client. 
As a result, Critton says Epstein had to spend more money on his defense in those criminal ones, and his lawyers wound up engaging in frivolous dissevery and 
depositions. The additional cost was between 5100,000 to $200,000, Critton says, adding that the whole matter has only complicated efforts to resolve current 
cases pending against the billionaire. 
'Instead of a defendant having a legitimate discussion with a plaintiff to resolve a case, [Rothstein's] out there pitching millions in dollars from these other cases 
he claims to have, he says. Critton adds that Rothstein's "abusive litigation tactics' included trying to depose 'extraneous individuals' that would embarrass 
Epstein 
Those individuals include Bill Clinton, David Copperfield, and Donald Trump--all close friends of Epstein who traveled with the money manager on his private 
plane. (Rothstein sought access to flight records and other information that be could show to potential investors to boost his claim to a nine-figure settlement) 
Critton declined to comment on the damages Fresein is seeking from Rothstein over the alleged settlement claims, though he hinted that the amount vnll be at 
least SI00,000 and more than that if damages are trebled. Critton has yet to hear from lawyers for Rothstein on the civil suit and says ho hasn't yet decided 
whether claims wall be brought against other members of Rot stem's defunct (Inn, Rothstein Rosenfeld* Adler. 
'Pm taking baby steps on this; says Critton BP stranger to high-orothe sex suits. 
Rothstein's criminal lawyer, Marc Hunk, a former partner at RRA, was not immediately available for comment 
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