Draft: efta02762305

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA¶

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

PART 6¶

v.¶

SCOTT ROTHSTEIN individually, and J. , individually,¶

Defendants/Counter-Plaintiff.¶

PLAINTIFF/COUNTER-DEFENDANT JEFF DOCUMENTS IN SUPPORT OF II1S REVI EIN'S APPENDIX OF BUS MOTION IN LIMINE¶

Plaintifl7Counter-Defendant Jeffrey E in support of his revised Omnibus Motiop4 : tein") files this Appendix of Documents¶

Co s¶

No.	Date	Document
1	1/5/11	Epstein's Motion to Amend Complaint (D.E. 195)
2	4/9/09	Plaintiff's Motion to Strike References to Non-Prosecution Agreement or, in the Alternative, to Lift Protective Order Barring Jane Doe's Attorneys from Revealing Provisions in the Agreement (D.E. 32); <i>Jane Doe v. Jeffrey Epstein</i> ; S.D. Fla. Case No. 9:08-cv-80893-KAM
3	4/17/09	Plaintiff's First Amended Complaint (D.E. 38) <i>Jane Doe v. Jeffrey Epstein</i> ; S.D. Fla. Case No. 9:08-cv-80893-KAM
4	4/30/09	Jeffrey Epstein's Deposition Transcript Excerpts (pp. 148, 151-152); <i>E.W. v. Jeffrey Epstein</i> ; 15 ^th Judicial Circuit Case No. 50-2008-CA-028058-XXXX-MB

No.	Date	Document
5	6/19/09	Plaintiff's Motion for Injunction Restraining Fraudulent Transfer of Asserts, Appointment of a Receiver to Take Charge of Property of Epstein, and to Post a $15 Million Bond to Secure Potential Judgment (D.E. 165); <i>Jane Doe 2 v. Jeffrey Epstein</i> ; S.D. Fla. Case No. 08-cv-80119-MARRA/ [REDACTED]
6	11/5/09	Order Denying Plaintiff's Motion for Injunction, etc. (D.E. 400) <i>Jane Doe 2 v. Jeffrey Epstein</i> ; S.D. Fla. Case No. 08-cv-80119-MARRA/ [REDACTED]
7	7/22/09	Letters from [REDACTED] re depositions
8	7/27/09	Complaint (D.E. 1) <i>L.M. v. Jeffrey Epstein</i> ; S.D. Fla. Case No. 9:08-cv-81092-KAM
9	N/A	Court Docket <i>L.M. v. Jeffrey Epstein</i> ; S.D. Fla. Case No. 9:08-cv-81092-KAM
10	8/11/09 8/24/09	Re-Notices of Taking Videotaped Deposition of Donald Trump <i>Jane Doe v. Jeffrey Epstein</i> ; S.D. Fla. Case No. 9:08-cv-80893-KAM
11	8/10/09	Plaintiff's Request for Entry Upon Land (D.E. 143) <i>E.W. v. Jeffrey Epstein</i> ; 15 ^th Judicial Circuit Case No. 50-2008-CA-028058-XXXX-MB
12	8/24/09	Epstein's Motion for Protective Order Regarding Depositions of Lawrence Visoski and David Hart Rogers (D.E. 159) <i>L.M. v. Jeffrey Epstein</i> ; 15 ^th Judicial Circuit Case No. 50-2008-CA-028051-XXXX-MB
13	11/3/09	Article: <u>South Florida Sun-Sentinel</u> - <i>Scott Rothstein's investment deals seemed too good to be true</i>
14	11/6/09	Article: <u>New Times Broward-Palm Beach</u> - <i>Scott Rothstein: The Jeffrey Epstein and Bill Clinton Ploy</i>
15	11/9/09	Verified Complaint for Forfeiture <i>In Rem</i> (D.E. 1) <i>United States of America v. Scott W. Rothstein</i> (Forfeiture Action); S.D. Fla. Case No. 0:09-CV-61780-WJZ
16	11/12/09	Article: <u>South Florida Sun-Sentinel</u> - <i>FBI doubts Rothstein ran a Ponzi scheme alone</i>

No.	Date	Document
17	11/20/09	<b>Complaint (without exhibits)</b> (D.E. 3) <i>Razorback Funding, LLC v. Rothstein</i> 17th Jud. Cir. Case No. 062009CA062943AXXXCE
18	11/23/09	<b>Amended Verified Complaint for Forfeiture <i>In Rem</i></b> (D.E. 14) <i>United States of America v. Scott W. Rothstein</i> (Forfeiture Action); S.D. Fla. Case No. 0:09-CV-61780-WJZ
19	11/23/09	<b>Article: <u>South Florida Sun-Sentinel – You're in a town full of thieves</u></b>
20	11/24/09	<b>Article: <u>The Miami Herald – Feds: Scott Rothstein Ponzi scheme paid salaries at law firm</u></b>
21	11/25/09	<b>Amended Complaint (without exhibits)</b> (D.E. 12) <i>Razorback Funding, LLC v. Rothstein</i> 17th Jud. Cir. Case No. 062009CA062943AXXXCE
22	12/1/09	<b>Information</b> (D.E. 1) <i>United States v. Rothstein</i> ; S.D. Fla. Case No. 0:09-cr-60331-JIC
23	12/7/09	<b>Complaint (without exhibits)</b> (D.E. 5)
24	6/30/17	<b>Affidavit of Jeffrey Ep [REDACTED]</b> (D.E. 931)
25	11/10/17	<b>Bradley J. Edwards' Deposition Transcript Excerpts</b> (pp. 163-164, 166, 227-229, 259-260, 276-278, 321-322, 338-339)
26	3/23/10	<b>Bradley J. [REDACTED]' Deposition Transcript Excerpts</b> (pp. 112, 116-117, 123-125, 230-231)
27	10/10/13	<b>[REDACTED] J. [REDACTED]' Deposition Transcript Excerpts</b> (pp. 205)
28	7/26/09 8/13/09 10/23/09	<b>Email from Pricilla Nascimento to Scott Rothstein</b> <b>Email from [REDACTED] J. [REDACTED] to Priscilla Nascimento</b> <b>Email from Ken Jenne to Scott Rothstein</b>
29	6/14/12	<b>Scott Rothstein's Deposition Transcript Excerpts</b> (pp. 23-26, 52-53)

No.	Date	Document
30	12/12/11	Scott Rothstein's Deposition Transcript Excerpts (pp. 59-62);
31	12/21/11	Scott Rothstein's Deposition Transcript Excerpts (p. 2278)
		Razorback Funding. LLC v. Rothstein; 17th Jud. Cir. Case No.
32	3/17/10	Jeffrey Epstein's Deposition Transcript Excerpts (pp 1 14, 19-
		20, 23, 25-26, 28-34, 36-39, 48-55, 57, 59-60, 62-69, 6-80,
33	11/9/17	Amended Exhibit List (D.E. 10
34	11/15/17	Epstein's Objections to A e ed Exhibit List
35	11/9/17	Seventh Amended emental Witness List
36	1/25/12	Jeffrey Epstein's Depv n Transcript Excerpts (pp. 19-21)

CERTIFICATE OF SERVICE¶

I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on November 21, 2017, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b)(1).¶

LINK & ROCKENBACH, PA
1555 Palm Beach Lakes Boulevard, Suite 301
West Palm Beach, Florida 33401
(561) 727-3600; (561) 727-3601 [fax]¶

By: /s/ Scott J. Link
Scott J. Link (FBN 602991)
Kara Berard Rockenbach (FBN 44903)
Angela M. Many (FBN 26680)
Primary: Scott@linkrocklaw.com
Primary: Kara@linkrocklaw.com
Primary: Angela@linkrocklaw.com
Secondary: Tina@linkrocklaw.com
Secondary: Troy@linkrocklaw.com
Secondary: Tanya@linkrocklaw.com
Secondary: Eservice@linkrocklaw.com ¶

Trial Counsel for Plaintiff/Counter-Defendant
Jeffrey Epstein¶

SERVICE LIST¶

Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 <u>mep@searcylaw.com</u> <u>jsx@searcylaw.com</u> <u>scarolateam@searcylaw.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> J. [REDACTED]	Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 <u>njs@FLAppellateLaw.com</u> <u>kbt@FLAppellateLaw.com</u> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> J. [REDACTED]
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------	-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

<p><b>J. [REDACTED]</b> <b>Pottinger LLC</b> 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <a href="mailto:brad@epllc.com">brad@epllc.com</a> <a href="mailto:staff.efile@pathtojustice.com">staff.efile@pathtojustice.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <b>J. [REDACTED]</b></p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <a href="mailto:marc@nuriklaw.com">marc@nuriklaw.com</a> <i>Counsel for Defendant Scott Rothstein</i></p>
<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:jgoldberger@agwpa.com">jgoldberger@agwpa.com</a> <a href="mailto:smahoney@agwpa.com">smahoney@agwpa.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>

NOT A CERTIFIED COPY¶

APP. 23¶

NOT A CERTIFIED COPY¶

A:•No.¶

(DT 30b:5-8)r¶

e. tn her FBI statement (pre-EDWARDS and 'IRRA), L.M. lestlfied about otlieis L.M. brought to the Epstein hoMe..L.Mi testified that women she brought to home were eagerbrihe 0pp:wit/nit, andtentent with their experiences:¶

A: None of my girls ever had a problem and they'd call me. They'd beg me, you know, for 40 to go to Jeffb30 house because they IS Jeffrey. Jeffrey le nian. 'Ho really Is. mean, and he all thought we were of ego always. This fe whars sesad about. (p 30-Fg N87
¶

CI: any dYthe girls complain about What happened after they left there¶

No. You asked methat question. No, everybody loved Jeffrey. ' fp. 44 - FBI)

A: Every girl that I brought to Jeffrey, they said they were fine with It. and Ilke for example [E.W. — another of RRA's clients In the CM 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. (p.'45 - FBI) •¶

7¶

Yet, with and RRA as her attorneys,' L.M. did a 180' et her September; 2009 deposition in saying: .¶

A: . . . Once they were there, they were scared ou oftheir*Ind. They did It Ynyways and some .of them walked an aid LM. t\ fre don't ever do this to me again. That:wee the-worst thing that ever happened to die. (DT 170:8-11)
¶

... A: And then, a tot of girls weren't comfortable. (DT 17t13)¶

f. The above represent only a few of the dramatic changes L.M. made In her testimony prior to her representation by RRA and after she hired ROTHSTEIN, and RM.¶

As a result of the fraudulent Investment or (Renzi) 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 Litigation Team 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. . .

Fortunately, their ladles have not been successful. As Magistrate Judge Linnea valet° in a discovery order dated•September 15, 2009 (DE 299 in Federtil Case #08480119)harlenyIng Plaintiffs' Motion-fOr Protective Order¶

"This IS his [Epstein's! right. The Record in this case Is clear that•the childhood of manta the Piatnfiffs was marred by instances of abuse and neglect, which In tam may have 'resulted, In whole or id part, in the damages claimed by the Pffgritiffs,°*¶

addition, In :an Omnibus Order dated Oc!ober, 28, 2009 (DE 377 In Federal Case uosascillo) Iviaglitrate'Judge Linnea Johnsonwrote:¶

• "Here the request atastie goesto the very heart of the Plaintiff's damage claims, requesting riot only general Information relating lo Plaintiffs.sexual history, but Inquiring as to Specific indtandes wherein Plaintiff received compensation or consideration for sex acts, claim other mates sexually assaulted, battered, or abtites her, ahri/ortraim 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 Epstein's actions in this case• has negatively affected their relationships by, among other things, "distrust in men," 'sexual timacy 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 whetherPleintlffs were molested or the subject of other "sexual activity' or "lewd¶

•¶

.4¶

and lascivious .conduct" In order to .determine whether there is an .alternative basis Eifthe psychokigleal disorders Plaintiffs claim to have sustained, whether Plaintiffs engaged In prostitution or other similar type acts .and.hew certain•acts alleged bi ins Goi ttaint materially affected Plaintiffs' reiatlettahips.wlth.others or how those acts didnot hew) such an affect on those relationships:and/or whether Plaintiffs Suffered from.the alleged emotional and psychological dlsorders'as a result of other sexual acts prior to the acts a• lleged in. the Complaint To deny 'Epstein thus discovery, would be tantamount to barring' him from mounting a •ciefenseik''¶

.50. ROTHSTEIN, an Ul.'s actions constitute a fraud upon EPSTEIN Eli PIRA, ROTHSTEIN and the beam represented.themselves to be acting In • good faith and with the.beets Inters of their clients in mind at all times wherrin reality, they were..acting In -furtherance of the Investment or Ponzl scheme described herein. EPSTEIN justifiably. relied to his detriment on the representations of RRA, and pefendants, ROTHSTEIN, EDWARDS and L.M. as to how he conducted aniidetended ' the 014Actions brought against him.¶

feitct dfre and proximate result of the fraudulent and illegal Investment or Ponzl ordhestrated by.ROTHSTEIN and as yet other unknown co-conspirators and as .a Jesuit 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 volt* as a result of them refusing to settle In that a percentage of any payment by

Epstein v. RRA, et al.
Page 30¶

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 ROTH [REDACTED] 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, [REDACTED] and L.M. are liable for damages caused to EPSTEIN - individually, and jointly and severally.

County - Violation of §§ 772.104, et as cf., Fla. Stat. - Florida Civil Remedies for Criminal Practices Act - Against All Defendants¶

Plaintiff realleges and incorporates paragraphs 1 through 53 as if fully set forth herein.

Epstein v. RRA, et al.
Page 31¶

RRA, ROTHSTEIN, [REDACTED] and L.M. each and collectively constitute an enterprise pursuant to §772.102(3), Fla. Stat. (2009).
ROTHSTEIN, [REDACTED] and L.M. engaged in a pattern of criminal activity as defined in §772.102(3) and (4), Fla. Stat. (2009).
As alleged herein, [REDACTED] and [REDACTED] committed multiple predicate acts in violation of §772.103(1), (2), (3) and (4), Fla. Stat., including violations of Florida Statutes - Chapter 517, relating to securities transactions; Chapter 817, relating to fraudulent practices, false pretenses, and fraud generally (which includes L.M.); Chapter 831, relating to forgery; §836.05, relating to extortion (which includes L.M.); and Chapter 837, relating to perjury (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 §772.103, Fla. Stat., EPSTEIN has been injured.
Pursuant to §772.104(1), Fla. Stat., Plaintiff EPSTEIN is entitled to threefold of his actual damages sustained, reasonable attorney's 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
"Ricketeer Influenced and Corrupt Organization Act"
Pursuant to §§895.01, et seq., Fla. Stat. (2009).
Against All Defendants¶

k¶

)¶

Plaintiff realleges and incorporates paragraphs 1 through 53 as if ftilly t forth .herein.

SI. RRA, along with ROTHSTEIN, and L.M., each actively, conetifute einanterpdse pigeoaritto.§.805.02(a),.Fla. Stat. (2009).,_¶

During all .times- relevant. hereto( ROTHSTEIN, MCItl •L.M. were and are aisoclatert with the enterprise, RRA, and eachalher.
Defendants, ROTHSTEIN, and LM., as persons associated with the enterprise, RRA and-each other (as an ante e), unlawfully conducted or participated, directly or fndirect1y; in such an ente laugh a pattern of racketeering, § B95.43(3), Fla. Stet, as alleged above-herein.
The -breadth. and scope of ROTHSTEIN, and; colonially, 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 flung Of this Complaint, criminal charges have only been • brought against ROTHSTEIN.

. 65: Substantially more than two predicate acts. (i.e., the selling of fabricated sottlementsautlined herein, including-the Civil Adkins involving Epstein as well as the Improper litigation Waits outlined above) occurred-within a five year time period.¶

• 66. Pursuant to §895.02, Fla. Stat., ROTHSTEIN and engaged in a pattern of 'racketeering activity' through the commission of crimes as defined In § 895.02(1)(a)-(b), Fla.'Stat, Including Chapter 617, relating to securities; Chapter 817, relating to fraudulent practices, false pretenses, and fraud (including L.M.) generally;¶

Epstein v. RRA, et al.
Page.33¶

Chapter 813, relating to forgery; §836.05, relating to extortion (including L.M.); Chapter 837, relating to perjury (including L.M.).¶

Pursuant to §895.05, Fla. Stat., Plaintiff seeks the following relief against Defendants, ROTHSTEIN, [REDACTED] and L.M.:
a) Ordering ROTHSTEIN and [REDACTED] to divest themselves of any interest in the enterprise, RRA;
b) Enjoin all Defendants from engaging in the same type of conduct and activities as described herein; and
c) 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 attorney's 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 III - Abuse of Process -
Against All Defendants¶

Plaintiff realleges and incorporates paragraphs 1 through 53 as if fully set forth herein.

• • I.¶

After Instituting the Civil Actions against EPSTEIN, the actions of Defendants, ROTHSTEIN, and LM. as alleged in paragraphs 9 through 58 :herein, constitute an illegal, Improper or perverted use of process.

ROTFISTEIN, -.and L.M. possessed utterior.rnotives or purpo.ses in exercising such illegal, improper, or perverted use of placebo,¶

As a result -of ROTHSTEIN,. and LM.'s a STEIN suffered" • damages:

WHEREFORE, Plaintiff EPSTEIN respectfully demands the entry of a Judgment.for ,dariaieges against all this named' Defendants¶

trd Ants* All t7standants¶

Plaintiff realleges and Incorporates paragraphs through-63 as if•fully set forth. herein.

64<) \ 74. ROTHST.EIN,. b and through Defendant and. LM. made false 'statements of fad to EPSTEIN and his attorneys and agents, -known-to-13018'5e at the time made, and/or Intentionally concealed material information from EPSTEIN' and his attorneys and agents, for the purpose of Inducing.EPSTEN toadtin reliance 'Monson.¶

EPSTEIN did so act on the misrepresentation• and/or concealment by incurring additional attorney's fees, costs, and expenses in aggressively defending the chill actions whereas In realitt, because the Civil Actions against Plaintiff were being exploited and overkalued•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 v. RRA, et al.¶

Page 35¶

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 1 through 53, and 74 and 75 as if fully set forth herein.
ROTHSTEIN, [REDACTED] and L.M. conspired to commit a fraud upon EPSTEIN.
ROTHSTEIN, [REDACTED] 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, [REDACTED] 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 v. RRA, et al.
Page 38¶

rcrit@bclclaw.com
MICHAEL J. PIKE, ESQ.
Florida Bar #617298
mpike@bclclaw.com ¶

BURMAN, CRITTON, LUTTIER & COLEMAN
303 Banyan Blvd., Suite 400
West Palm Beach, FL 33401
561-842-2820
Fax 561-253-0164
(Attorneys for Plaintiff)¶

NOT A CERTIFIED COPY¶

APP. 24¶

NOT A CERTIFIED COPY¶

IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA¶

JEFFREY EPSTEIN.¶

Plaintiff/Counter-Defendant.¶

Case No. 50 2009 CA 040800XXXXMBAG¶

vs.¶

SCOTT ROTHSTEIN, individually,
[REDACTED] J. EDWARDS, individually.¶

Defendant/Counter-Plaintiff.¶

AFFIDAVIT OF JEFFREY EPSTEIN¶

The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby deposes and says:¶

1. I am over eighteen, (18) years old and have personal knowledge of the facts stated herein,
1. I am the Counter-Defendant in the above captioned action (the "Action") and submit this Affidavit in support of my Motion for Summary Judgment (the "Summary Judgment Motion") with respect to the Fourth Amended Counterclaim (the "Counterclaim") of Counter-Plaintiff Bradley Edwards ([REDACTED]).
1. In his Counterclaim, [REDACTED] has a sole, unsupported claim against me for Malicious Prosecution.
1. As more fully described below, at the time that I commenced the Action against [REDACTED] Scott Rothstein ("Rothstein") in December 2009, I had a good faith basis for filing the same, based on the facts that existed at the time I filed suit, as set forth below and more fully in my Summary Judgment Motion.
I filed the Action against Rothstein and [REDACTED] because, based on the facts described below and in the Summary Judgment Motion, I believed at the time of filing my original Complaint that these two individuals, and other unknown partners of theirs at Rothstein, Rosenfeldt, Adler ("RRA"), engaged in serious misconduct involving a widely publicized illegal Ponzi scheme operated through their law firm (the "Ponzi Scheme") that featured the very civil cases litigated against me by Edwards, which were being used to defraud potential investors in the Ponzi Scheme.
In early November 2009, stories in the press, on the news, and on the internet were legion about the implosion of RRA, the Ponzi Scheme perpetrated at that firm, and the misuse in the Ponzi Scheme of certain civil cases then being litigated against me by RRA partner, Edwards. The cases Edwards was litigating against me, which are described in the Summary Judgment Motion (the "Epstein Cases"), were being used to defraud investors out of millions of dollars and to fund the RRA Ponzi Scheme.
In November 2009, I also became aware of news stories that as a result of the Ponzi scheme at RRA, the Florida Bar had commenced investigations into over one-half of the attorneys employed by RRA.
At or about the same time in November 2009, I also became aware that the law firm of Conrad Scherer filed a Complaint against Scott Rothstein and others, Razorback Funding, LLC; et al. v. Scott W. Rothstein; et al., Case No. 09-062943(19) (hereinafter referenced as the "Razorback Complaint"), on behalf of some of the Ponzi Scheme investors.
Upon reviewing the Razorback Complaint, I learned that the Razorback Complaint detailed the use of the Epstein Cases (i.e., the cases being litigated against me

by [REDACTED] to defraud investors in the Ponzi Scheme; including, but not limited to, improper discovery practices and other methods to bolster the cases.¶

Prior to my filing the initial Complaint in the Action, I also became aware that the Federal government filed an Information against Scott Rothstein, which included allegations of RRA as an "Enterprise" in which Rothstein and his yet unidentified co-conspirators engaged in a racketeering conspiracy, money laundering conspiracy, mail and wire fraud, conspiracy, and wire fraud, and specifically alleged that (a) potential investors were defrauded by Rothstein and other co-conspirators who falsely advised that confidential settlement agreements were available for purchase, when the settlement agreements offered were fabricated; (b) the fabricated settlements agreements were allegedly available in amounts ranging from hundreds of thousands of dollars to millions of dollars and could be purchased at a discount and repaid to the investors at face value over time; (c) Rothstein and other co-conspirators utilized the offices of RRA and the offices of other co-conspirators to convince potential investors of the legitimacy of the and success of the law firm, which enhanced the eredibility of the purported investment opportunity in these fictitious settlements; (d) Rothstein and other co-conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA, to expand RRA by the hiring of additional attorneys and support staff, to fund salaries and bonuses, and to acquire larger and more elaborate office space and equipment in order to enrich the personal wealth of persons employed by and associated with the RRA Enterprise.
Prior to filing the initial Complaint in the Action, consistent with the allegations made by the press, in the Razorback Complaint, and in the Rothstein.

federal compliant againsbne on prosecuting a ease against against . e . 12. Equally consistent with the allegations p d in the Razorback Complaint that the Epstein.Cases were being.deli for purposes unrelated to the litigation in order to lure investors ititri4\ 53 Schenie is the fact tharon July 24. 2009. filed a. two hundred I ' rt 4) page, one. fitly-six 1156). count • laintifiel.M. for whom was already court involving the same matters alleged in the federal complaint:. The, t was filed in federal court. but was never served on me or prosecuted. lead 0 conclude that the only reason it was filed was to enhance the case files offices of RRA to potential investora in the Pond Scheme..¶

Information, it was clear that the activity in the Epstein Cases being litigated:by intensified substantially during Rte.short six (6) months during which was a parniet at RRA from April 2009 through.the end of October 2009. Furthermore, during that six (6)-month period. questionable discovery like that detailed in the Razorback Complaint had taken phice.in the Epstein Cases being litigated against me by Ed including noticing the depositions of famous dignitaries and celebriti Bill Clinton and. David Coppertield. However. the plaintiffs in thelEps made no allegations of improper conduct against them.implicatin rides oi• dignikarles.¶

• so while .4 partner. at RRA. • filed a motion in Federal court in nested that the court order me. Ripest a fittemmillion dollar bond in the Jane wise. Thisease. nceording lo the Razorback Complaint, was being loafed at that same titntto•investors'.in the P.otizi Scheme,. In conneotion. With that motion, filed papers discussing my net worth and filed supplemental papers purporting to list in great detail my vehicles, planes and other items of substantial value, all at a time when. according to the¶

accounts in the press. the Informatiouand the Razorback Complaint. the Ponzi Scheme was unraveling and the need for new Investors In the Ponzi Scheme was becoming urgent. The court rejected the Motion, calling it "devoid of evidence¶

The facts set forth above and in the.SumntarY Judgnient Motion were the facts upon which I relied in (a) determining that I had incurred damages, such attorneys fees and disbursements paid to defend against abusive litigation practic • eh appehred to be Unrelated to the underlying litigation against me. and (blasseLn causes of action against Edwards and Rothstein in the Action.

FURTHER AFFIANT SA Y ITH NAUGHT.¶

STATE OF NEW YORK COUNTY OF NEW YOR¶

Sworn and subscribt .9An this June,...: t-J.1 . N IL before me, the undersigned authority, by Jeffrey Epstein,¶

r ice\¶

pkt.)¶

coliaRVbPUBL N A I 404 1 1del/¶

HAMM AVOW NOTARY PUELIC•STATE OF NEW YORK No, 01AV6313116 Qualified In Richmond Counly My Commission Expkos October 14, 2016¶

APP. 25¶

NOT A CERTIFIED COPY¶

IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN
AND FOR PALM BEACH COUNTY, FLORIDA¶

Case No. 502009CA040800XXXXMB¶

JEFFREY EPSTEIN,¶

Plaintiff,¶

vs.¶

SCOTT ROTHSTEIN, individually;
[REDACTED], individually,¶

Defendants/Counter-Plaintiffs.¶

VOLUME I¶

VIDEOTAPED DEPOSITION¶

OF¶

(BRADLEY) (EDWARDS)¶

Taken on Behalf of Plaintiff¶

Friday, November 10th (2017)¶

10:02 a.m. - 6:16 p.m.¶

2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409¶

Examination of the witness taken before¶

Sonja D. [REDACTED]¶

Palm Beach Reporting Service, Inc.
1665 Palm Beach Lakes Boulevard, Suite 1001
West Palm Beach, FL 33401
(561) 471-2995¶

1 "discovered that there were high-profile witnesses
2 onboard Epstein's private jet where some of the
3 alleged sexual assaults took place, and showed D3" --
4 the potential investors -- "copies of a flight log
5 --" Right?¶

6 A Yeah.¶

7 Q -- "purportedly containing names of
8 celebrities, dignitaries and international figures."¶

9 A Right.¶

10 Q Did the flight log in fact contain names of
11 celebrities?¶

12 A Epstein's flight log does contain names of
13 celebrities. Those are the people he hung out with.¶

14 Q And dignitaries?¶

15 A What's the definition of dignitary? I think
16 so.¶

17 Q Good enough for me.
18 And international figures.¶

19 A Yes.¶

20 Q (SO (there (is (some (truth (that (Rothstein (is
(21) (weaving (in) (based (on (documents) (the (flight (log (that
(22) (was (obtained (by (you (as (the (lead (trial (lawyer (in (the
(23) (pending (lawsuits?)¶

(24) (A) (There (is (some (truth (in (the (pending (lawsuits?)¶

(25) (Q) (NO. (I'm (saying (that (what (Rothstein (was¶

1 (doing) (--) (we) (all) (--)¶

2 (A) (He) (used) (actual) (evidence) (to) (support) (a)¶

3 (fabricated) (story).¶

4 (Q) (And) (the) (actual) (evidence) (that) (was) (referred)¶

5 (to) (here) (are) (these) (flight) (logs) (that) (you) (as) (the) (lead)¶

6 (lawyer) (obtained) (and) (brought) (back) (to) (the) (Rothstein)¶

7 (firm), (right)?¶

8 (A) (I) (maintain) (the) (evidence) (for) (all) (of) (my) (cases)¶

9 (at) (the) (Rothstein) (firm) (where) (I) (worked), (yes).¶

10 (Q) (That's) (all) (I) (was) (confirming).¶

11 (A) (Does) (it) (appear) (that) (Rothstein) (gained) (access)¶

12 (to) (it) (and) (used) (it) (to) (support) (his) (fairytale)? (It) (does).¶

13 (Q) (It) (does), (right)? (And) (you) (agree) (with) (that).¶

14 (A) (Yes).¶

15 Q So paragraph 41.¶

16 A Yes.¶

17 Q In this case, Razorback -- this is not¶

18 Mr. Epstein's suit, right? This is Bill Scherer¶

19 representing the Razorback client that he represented¶

20 suing Rothstein is making these allegations?¶

21 A Yes.¶

22 Q Right? Okay.¶

23 So Mr. Scherer -- do you know Mr. Scherer?¶

24 A I know him now better than I did then. I¶

25 didn't know him at all then.¶

1 underaged women were onboard." There were underage
2 women onboard. Epstein knew that. So he knows this to
3 be false. "And no elicit activities took place."
4 Epstein knows elicit activities took place on his
5 airplane, so he knows that to be false.¶

6 He can't just adopt what Bill Scherer says
7 and say, █, that forms the basis of something I
8 believe. It can't possibly form the basis of what
9 he believes, because he knows it to be false.¶

10 Q (Okay.) (So (did (any) (of (the (three (clients (that
(11) (you (represented (while (you (were (at (Mr. Rothstein's
(12) (testified (that (they (went (on (Mr. Epstein's (plane?)¶

(13) (A) (They (were (not (three (of (-- (they (were (not (on
(14) (Mr. Epstein's (plane.) (They (were (not (the (victims (on (the
(15) (plane.)¶

(16) (Q) (So (the (clients (that (you (represented (-- (you
(17) (individually (while (at (the (Rothstein (firm (-- (your
(18) (three (clients (testified (or (admitted (that (they (never
(19) (traveled (on (Mr. Epstein's (plane, (correct?)¶

(20) (A) (If (they (testified (truthfully, (they (would (say
(21) (that.) (I (just (don't (remember (if (they (were (asked (that
(22) (question.)¶

23 Q But you know the question is --¶

24 A I do know the answer to that question for
25 sure.¶

1 the many topics that, amongst plaintiffs'
2 counsel, we discussed as the way in which
3 Epstein intended to ultimately defeat these
4 cases, which would ultimately prove his
5 serial sexual molestation of minors.¶

6 BY MR. LINK:¶

7 Q So is your concern something that's
8 evidence?¶

9 A And we had a source telling us our concern
10 was true.¶

11 Q I understand.¶

12 A Okay, so --¶

13 Q (I) (have) (heard) (about) (the) (source.) (I) (am) (asking)
14 (you) (about) (evidence.) (You) (told) (me) (you) (had) (concerns.)
15 (Okay,) (I) (don't) (know) (that) (a) (federal) (judge) (cares) (about)
16 (your) (personal) (concerns.) (I) (doubt) (that) (a) (federal) (judge)
17 (cares) (that) (you) (have) (a) (source) (who) (won't) (get) (on) (the)
18 (stand.)¶

19 (So) (whenever) (I) (have) (filed) (a) (motion) (for)
20 (in) (junction,) (I) (intend) (to) (put) (evidence) (on) (in) (front) (of)
21 (the) (court.) (And) (I'm) (asking) (you,) (sir,) (what) (evidence)
22 (did) (you) (have) (in) (this) (federal) (proceeding) (to) (prove)
23 (your) (statement) (that) (Mr.) (Epstein) (was) (fraudulently)
24 (transferring) (his) (assets) (overseas?)¶

25 (MR.) (SCAROLA): (Excuse) (me.) (I'm) (going) (to)¶

1(object) to (Counsel's) speech about (Counsel's)¶

2(experience.) Move that it be stricken.¶

3(And the question as to what evidence)¶

4(did Mr. [REDACTED] have [REDACTED])¶

5(MR. LINK:) Yes.¶

6(MR. SCAROLA:) [REDACTED] is a question that has¶

7been asked and answered repeatedly.¶

8(BY MR. LINK:)¶

9(Q) (So would you agree you had no admissible¶

10(evidence) at the time that you filed this pleading?)¶

11(A) (Hold on one second.) (So [REDACTED])¶

12(Q) (Yes,) (Sir.)¶

13(A) [REDACTED] this is evidence.¶

14(Q) (What is it?)¶

15(A) (In request for admission [REDACTED] asked)¶

16(Mr. Epstein [REDACTED])¶

17(Q) (Yes.)¶

18(A) [REDACTED] admit you are moving (financial) assets¶

19(overseas) outside of the direct territorial reach of the¶

20(US and Florida courts.)¶

21(Question 22) you were making asset¶

22(transfers) with the intent to defeat any judgment¶

23(that might) be entered against you in this case or¶

24(similar cases.)¶

25(Twenty-three,) do you currently have the¶

1 (ability to post @ $15 million bond to satisfy @
2 (judgment in this case without financial or other
3 difficulty?)¶

4 (Q Uh-huh.)¶

5 (A If he told the truth, he would have said yes.)¶

6 And that is what the adverse inference requirement¶

7 allows for us to draw when he says in response to those¶

8 direct requests for admissions that he's invoking his¶

9 Fifth Amendment right against self-incrimination, which¶

10 is tantamount to an admission. So that is evidence.¶

11 (Q Okay. So you think that the adverse¶

12 inference --¶

13 (A That's going to happen in this case, too.)¶

14 Q Hang on. Let me just make sure I
15 understand.¶

16 You thought when you filed this that
17 having an adverse inference to a question --
18 whatever question you asked -- because he raised the
19 Fifth, makes it an admission? That's your
20 understanding of an adverse inference in federal
21 court?¶

22 A I had an admission by Mr. Epstein in response
23 to his question.¶

24 Q That was it? You told me he pled the Fifth
25 and didn't answer. All I'm asking is, was it your¶

2 BY MR. LINK:¶

4 Q And this is a memo from him to you copying Marc Nurik. firm? Marc Nurik was a lawyer at Rothstein's¶

6 A One of the criminal defense lawyers.¶

8 Q And it's references Mr. Epstein's non-prosecution agreement?¶

9 A That's what it looks like.¶

10 11 12 13 14 15 16 Q And it looks like it's Mr. Adler to you. Says, "Brad age from Black and i just had a great conversati w Marc Nurik about the non-prosecution agr apt, and I need you to please get in contac it arc and meet with him to discuss the poss Bring with you a copy of the agreement.¶

17 18 19 20 ext sentence says, "We also discussed the assets itu ion and there are some major ies that need to be explored with Marc and le¶

21 "Get on it" exclamation point.¶

22 (Were)@MI (reportInq)(C) tr= (Karen in 01-0-70¶

219 (represent) (the)(three)Prolerstelr,(clients (the)Prim)¶

Q3) ardrel)(=CI(lrelq (C) 1prosecute)cam(Eps emn WatreTI?)¶

Q.0 • a e (tin) (Eigil)C) (data (AW11. (8th) 0195) C)¶

for identification.)¶

1 (I) had (just) started at the firm. (I) had (just) got there.¶

2 (Russ Adler was one of the only lawyers¶

3 (that) (I) had known for years before (I) got to the firm.¶

4 (And) Russ Adler handled sexual abuse cases. (So,)¶

5 (especially) in the beginning, (I) talked to Russ about¶

6 how to kind of navigate through the complications¶

7 with Jeffrey Epstein and with the type of defense¶

8 that was going on. (So this (just) appears that wayne¶

9 Black and Russ Adler -- wayne was the¶

10 (investigator) -- that they were talking also about¶

11 how to -- what we needed to do in the investigation.¶

12 (Yeah,) Russ was definitely involved then.¶

13 (He didn't do much in the day-to-day,) so (I) don't want¶

14 to say anything to that.¶

15 (Q) (I) understand. But (I'm talking about) on¶

16 April 8th, 2009, (it looks) to me (like) he's giving you¶

17 instructions on what to do. Do you agree?¶

18 (A) Not giving me instructions on what to do. (I)¶

19 mean, he's telling me bring Marc Nurik the¶

20 non-prosecution agreement, is the instruction.¶

21 (If) anything, we are working together with¶

22 the common goal.¶

23 Q The get on it, exclamation point --¶

24 A We're buddies. Then we were just friends.¶

25 Get on it is let's do this.¶

1 2 3 4 5 6 7 8 A was on the airplane with Jeffrey Epstein and an underaged girl. Jeffrey Epstein makes the allegation in the complaint that the proof that Brad was pumping a Ponzi scheme is that he sought flight logs, despite knowing that there were no underaged girls on the airplane. Jeffrey Epstei new that to be false, because there were indeed g ag d girls on the airplane.¶

9 10 11 12 13 14 0 To the extent that Jeffrey Ep tei himself won't say that I knowingly filed t. alse allegation, could know that Jeffrey Epstein knew that t s a false I ACdit 6 AShIr allegation, because I t s nthe airplane and so S was this underaged g' , c d he knew that.¶

15 16 17 18 19 So at e t e that he filed this complaint, he new at it was false, the allegatio that he was making, which allegedly forme thesis of his assertion that I was in ve n a Ponzi scheme.¶

20 Okay.¶

21 You lost me, but I'm not going --¶

22 A Read it back. I think it makes sense.¶

23 Q I'm not going to try to figure that out.¶

24 (DB)(you) (have (anyone)(th-Et) can (CeTta f)ratreat)¶

GLD what (was) it4E (vs-t-Eiro-g) mind ani in (December (2OC19) at¶

1 (the time that the lawsuit was filed about why he
2 (filed it?)¶

3 (A) MR. EPSTEIN testified to that.¶

4 (Q) (Other than MR. EPSTEIN,) do you have any
5 witnesses that are going to testify about the reasons
6 why MR. EPSTEIN made the decision to file the
7 lawsuit?¶

8 (A) NO. (It's very obvious why he filed the
9 lawsuit.)¶

10 (Q) You have no other witnesses other than
11 MR. EPSTEIN, correct?¶

12 (A) We have attempted to take his attorneys'
13 depositions and they have all rejected that
14 opportunity. So he has no witnesses that can testify
15 as to what was in his mind at that time.¶

16 (Q) You are the plaintiff in the counterclaim,
17 right?¶

18 (A) We will see how this unfolds, right?¶

19 (Q) Let me just wrap this up, because you have
20 given me a lot of information to which I think are
21 simple questions. Do you have a witness that will
22 testify, other than MR. EPSTEIN, about what was in
23 his mind in December 2009 about why he brought the
24 lawsuit?¶

25 MR. SCAROLA: Direct evidence or¶

1(circumstantial) evidence or both?2(THE WITNESS:) (Let) me (think) about (that)3(question.) (About) (why) (he) (brought) (the) (lawsuit.)4(Specifically) (that.)5(MR.) (LINK:) (Can) (you) (read) (back) (the)6(question) (for) (him), (please?)7(I) (won't) (take) (that) (as) (coaching) (at) (all.)8(In) (any) (event,) (well) (done.) (But) (I) (don't) (think)9(you) (heard) (my) (question.)10(Can) (you) (read) (it) (back?)11((Thereupon,) (the) (requested) (portion) (of) (the)12(record) (was) (read) (back) (by) (the) (reporter) (as)13(above) (duly) (recorded.))14(THE WITNESS:) (A) (witness) (other) (than)15(MR.) (Epstein,) (no.)16BY MR. LINK:17Q Thank you.18Why was Bill Berger added to the witness19list last night?20A You will have to ask somebody other than21myself.22Q Do you know what Mr. Berger -- why he's23listed as an expert in this case?24A Again, that's a question for the lawyers.25Q Do you know when Mr. Berger agreed to1 federal action have anything to do with any factor,
2 other than those that you have just described, the
3 potential expiration of the statute of limitations
4 and your desire to take advantage of the provisions
5 of the non-prosecution agreement as a potential
6 alternative to the state court claim?¶

7 A That is the only reason that we filed it at
8 that time.¶

9 Q Did Scott Rothstein have any role
10 whatsoever in that decision-making process?¶

11 A He never had any role in any decision-making
12 process with anything to do with any of these cases, so
13 no.¶

14 Q (Did you become aware of the fact that your
15 Epstein-related files at some point in time had been
16 requested by Scott Rothstein?)¶

17 (A) Yes.¶

18 (Q) How did you become aware of that?¶

19 (A) I think Mike told me -- Fisten.¶

20 Q was there any explanation offered as to why¶

21 (Scott Rothstein wanted to see the Epstein-related
22 files?)¶

23 (A) That if these cases went to trial, he wanted
24 to try the cases with me.¶

25 (Q) He who?¶

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3 Q And was there anything suspicious about the
4 head partner in the firm telling you that in this
5 high-profile case he wanted to be part of the
6 prosecution team?¶

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1 I was told that he was going to try the
2 case with me. Period. Not more than, not less than
3 that. That's just it. Not be the lead, not be the
4 second, not be the third.¶

5 Q Just try the case with you?¶

6 A That's what I was told.¶

7 Q And that was okay because he was head of
8 the firm and he owned the files, right?¶

9 A Correct.¶

10 Q (You were an employee, in your mind, and he
(1) was the lawyer ultimately at the firm responsible for
(2) the three clients, true?)¶

(3) (A) (There's seventy lawyers at the firm. They
(4) all work for him. Hundreds of files. He's still the
(5) equity partner of the firm, so they are the firm's
(6) files. They are not -¶

17 Q (I understand. You told me earlier. And (I
(8) didn't realize that, that the interest that ( )
(9) Edwards, PA had in three files, you gave up to
(20) Mr. Rothstein and became a salary employee,
(21) essentially.¶

22 A (Gave up to RRA.)¶

23 Q Mr. Rothstein's firm, correct?¶

24 A Right. We've established this.¶

25 Q And so that Mr. Rothstein was the lawyer at¶

1 (that) (firm) (as) (the) (--) (one) (of) (two) (equity) (shareholders)
2 (who) (was) (ultimately) (responsible) (for) (the) (three) (Epstein)
3 (matters?)¶

4 (A) (For) (every) (case) (in) (the) (entire) (firm,) (including)
5 (those) (--)¶

6 Q (Including) (the) (three) (Epstein) (matters?)¶

7 A (Every) (case,) (yeah.)¶

8 MR. LINK: I have no further questions.¶

9 MR. SCAROLA: I have nothing further.¶

10 We will read.¶

11 THE VIDEOGRAPHER: The time is 6:16
12 p.m., and that concludes this deposition.¶

13 - - -¶

14 (The deposition was concluded
15 at 6:16 p.m.)¶

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PART 6¶

PLAINTIFF/COUNTER-DEFENDANT JEFF DOCUMENTS IN SUPPORT OF II1S REVI EIN'S APPENDIX OF BUS MOTION IN LIMINE¶

trd Ants* All t7standants¶