EFTA00223265.pdf

Roy BLACK BLACK JESSICA FONSECA-NADER HOWARD M. SREBMCK Scow A. KORNSPAN SREBNICK KATHLEEN P. PHILLIPS AARON ANTHON LARRY A. STUMPF KORNSPAN MARCOS BEATON, JR. MARIA NEYRA MATTHEW P. O'BRIEN JACIUE PERCZEK & STUMPF JENIPER J. SOULII0AS MARK A.J. SHAPIRO =PA.= NOAH Fox JARED E-Mail: December 9, 20O , Esq. Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 RE: Jeffrey Epstein Dear You emailed me a letter on November 2, asking whether Jeffrey Epstein's place of employment remained constant. It has. I reviewed a Google map to confirm that the distance between that place of employment and the location where he was stopped by Palm Beach Police is less than 3 miles (and that the location where he was walking was on a direct mute to his place of work). It has taken us a while to respond to your letter because other matters have consumed our time and effort. Over the past five weeks, the massive billion-dollar conspiracy created and run by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad Edwards, and others with tortuous and fraudulent abuses of process that resulted in serious injury to Mr. Epstein. A copy of the Complaint is enclosed with this letter. As ou know, Rothstein's firm represents and three of the plaintiffs who have brought civil actions against Mr. Epstein. The Rothstein firm was a criminal enterprise that used the litigation against Mr. Epstein to lure investors into its billion-dollar ponzi scheme. We believe that Rothstein and his co-conspirators used the government's criminal investigation as a means to perpetrate and further their fraud. For example: 201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 33131 • Phone: • Fax: • www.RoyBlack.com EFTA00223265  , Esq. December 9, 2009 Page 2 1. The Rothstein lawyers sought disclosure of the NPA to prove who the victims were, and used the NPA to 'corroborate" their false claims. 2. Rothstein and his co-conspirators abused the legal process in other cases. They forged the signature of judges, and even forged an Eleventh Circuit opinion. 3. Rothstein lawyers demanded phony protective orders. 4. In our case, they sought discovery of Epstein's plane logs to fish for celebrities to extort and convince investors that huge amounts of settlement money was available from them. 5. Rothstein lawyers litigated claims using Jane Doe names to make the phony settlements appear plausible to investors, and also to prevent any investigation into the claims by the investors. 6. Rothstein and others told investors that your office directed the women to the Rothstein firm. 7. Rothstein and his co-conspirators gathered information illegally, and shared it with the other plaintiffs' attorneys in this case. 8. Rothstein deceived investors into believing that he had the confidential victim list you prepared, and that he had a copy of the NPA. 9. Rothstein told investors that his investigators had sophisticated electronic bugging equipment to gather evidence against Epstein. 10. Rothstein told investors that Epstein had offered to settle the cases for $200 million, when there have been no such discussions about any settlement at any price. And it does not stop thre. Rabin, latners, and his employees investigated and litigated the , and cases with funds derived from their criminal enterprise and their fraud and misrepresentations to investors. But we have been stymied from debunking fraudulent claims brought by the Rothstein criminal enterprise because you have threatened that such action on Black, Srebnick, Komspan & Stumpf. P.A. EFTA00223266 A. Villafafia, Esq. December 9, 2009 Page 3 our part would constitute a breach of the NPA. So the Rothstein lawyers, once again, are using the power of the federal government to perpetrate and further their fraud. And the expense of litigating these cases has been extreme. For example, Bob Josefsberg, who I do not believe was aware of the Rothstein crimes, is now demanding over $2 million in legal fees. As a lawsuit brought by some of the investors' claims, Rothstein and his partner Edwards used Jeffrey Epstein as bait. The litigation strategy, media pronouncements, and investigatory initiatives of Rothstein and Edwards were calculated to support Rothstein's deceptions rather than to advance the position of his clients. I bring these facts to your attention so that if you had contact with Edwards or those associated with him in the past concerning Mr. Epstein, you consider not continuing communications with any of them in the future. I would like a short conference with you in person to talk about Mr. Epstein's progress through the state criminal justice system, to discuss several outstanding issues that I want to make sure you have accurate information about, and, from my perspective, most importantly, so that I can provide Mr. Epstein with proper counsel going forward. If you email me some dates when you are available this month, we can schedule a short meeting in your office hopefully before the year ends. Roy Black RB/wg Enclosure Black. SrebnIck Komspan & Stumpf, PA EFTA00223267  'THE CIRCUIT COURT QF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA &WHEYSett* Complex Litigation, Fla: k cht Pro. 1201 CASE NO. pn v. Plaintiff; 50 2009CAO' -1Oe)"4B SCOTT ROTHSTEIN, indliricluallYt BRADLEY J. EDWARDS, Individually, and L;,M;,. Individually, COPY RECEIVED FOR FPLING Defendants. DEC Ti itgag orfArt6N M. POCK COMPLAINT 0Ingfil% ciPMPTROIVIR NWT Whig/INN Plaintiff, JEFFREY EPSTEIN, (hereinafter °EPSTEIN", by and through ilia, undersigned attorneys, flies this action against Defendants, SCOTT' ROTHSTEIN, individually, BRADLEY J. EDWARDS, Individually; and-, Individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott ROthateirtalded by.other lawyerS and employees:at the firth of Rothstein, Rosenfeldt, and Adler,.P.A. for personal greed and enrichment, In betrayal of the ethical, legal and fiduciary duties' o their 6wn debts and professional dbligatibna to the administration of justice, deliberately engaged In a pattern of racketeering that Involved a staggering series Of gravely serious obstifictions of Justice, actionable frauds, and the orchestration and conducting of egregious civil litigation abuses that resulted in profoundly serious injury to 4emyy Epstein one of several targets of their misconduct EFTA00223268 Epstein 1 RFtA, et al. Page 2 and others. Rothstein and RRA's fraud had no boundary; Rothstein and his co- conspirators forged Federal court orders and opinions. Amongst the violations of law that are the subject of this lawsuit are the marketing of non-existent Epstein settlements and the sanctioning of a series of depositions that were unrelated to any principled litigation purpose but instead designed to discover extraneous private information about Epstein or his personal and business associates (including well-known public figures) in order to defraud investors and support extortionate demands for payment from Epstein. The misconduct featured the filing of legal motions and the pursuit of a civil litigation strategy that was unrelated to the merits or value of their clients' cases and, instead, had as its improper purpose the furthering of Rothstein's misrepresentations and deceit to third party investors. As a result, Epstein was subject to abusive investigatory tactics, unprincipled media attacks, and unsupportable legal filings. This lawsuit is filed and will be vigorously pursued against all these defendants. The Rothstein racketeering enterprise endeavored to compromise the core values of both state and federal justice systems in South Florida and to vindicate the hardworking and honest lawyers and their clients who were adversely affected by the misconduct that is the subject of this Complaint. Plaintiff reserves the right to add additional defendants — co-conspirators as the facts and evidence is developed. GENERAL ALLEGATONS 1. This is an action for damages in excess of $15,000.00, exclusive costs, interest, and attorneys' fees. EFTA00223269  Epstein'. RRA, et al. Page 3 2. Plaintiff, EPSTEIN, is an adult and currently is residing and works in Palm Beach County, Florida. 3. Defendant, SCOTT ROTHSTEIN ("ROTHSTEIN"), is an individual residing in Broward County, Florida, and was licensed to practice law in the State of Florida. In November 2009, ROTHSTEIN voluntarily relinquished his law license in the midst of the implosion of Rothstein, Rosenfeldt and Adler, P.A. ("RRA"). He was disbarred by the Florida Supreme Court on November 20, 2009. On December 1, 2009, ROTHSTEIN was arrested and arraigned in Federal Court in Broward County, Florida. 4. At all times relevant hereto, ROTHSTEIN was the managing partner and CEO of RRA. 5. Defendant, ROTHSTEIN and Stuart Rosenfeldt, are and were the principal owners of equity in RRA and each co-founded RRA. 6. Defendant, BRADLEY J. EDWARDS ("EDWARDS"), is an individual residing in Broward County, Florida and is licensed to practice law in the State of Florida. At all times relevant hereto, EDWARDS was an employee, agent, associate, partner, shareholder, and/or other representative of RRA. 7. Defendant, ■. (t."), is an individual residing In Palm Beach County, Florida. At all times relevant hereto, was represented by RRA, ROTHSTEIN and EDWARDS in a civil lawsuit against Epstein and was an essential participant in the • scheme referenced infra by, among other things, substantially changing prior sworn testimony, so as to assist the Defendants in promoting their fraudulent scheme for the EFTA00223270 Epstein RRA, et al. Page 4 promise of a multi-million dollar recovery relative to the Civil Actions (defined below) involving Epstein, which was completely out of proportion to her alleged damages. 8. Non-party, RRA is a Florida Professional Service Corporation, with a principal address of 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, FL 33401. In addition to its principal office, RRA also maintained seven offices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to this action, conducted business and filed lawsuits on behalf of clients in Palm Beach County, Florida. (RRA is currently a debtor in bankruptcy. RRA is not named as a Defendant). FACTUAL ALLEGATIONS 9. The United States in United States of America I. Scott W. Rothstein, Case No. 09-60331CR-Cohn, United States District Court, Southern District of Florida, has brought an action for Racketeering Conspiracy, 18 U.S.C. § 1962(d) against Scott W. Rothstein who was the chief executive officer and chairman of RRA. Within the information which was filed, the United States of America has identified the enterprise as being the law firm, RRA, through which Rothstein in conjunction with "his co- conspirators" (not yet Identified by the USA) engaged in the pattern of racketeering through its base of operation at the offices of RRA from sometime in 2005 up through and continuing into November of 2009. Through various criminal activities, including mail fraud, wire fraud and money laundering, the United States of America asserts that EFTA00223271 Epstein 1 RRA, et al. Page 5 Rothstein and his co-conspirators unlawfully obtained approximately $1.2 billion from investors by fraud in connection with a Ponzi scheme. The USA further alleges that "Rothstein and co-conspirators initiated the criminal conduct alleged in the instant Information in order to personally enrich themselves and to supplement the income and sustain the daily operation of RRA." In essence, in the absence of Rothstein and his co- conspirators conducting the Ponzi scheme, the daily operation of RRA, which included payroll '(compensation to lawyers, staff, investigators, etc.), accounts payable including unlimited improper, harassing and potential illegal investigation on cases, including Epstein-related matters, would in all likelihood would not have been sustainable. A copy of the information is attached as Exhibit 1 to this action. 10. As more fully set forth herein, RRA held Itself out as legitimately and properly engaging in the practice of law. In reality, ROTHSTEIN and others in RRA were using RRA to market investments, as described below, so as to bilk investors out of hundreds of millions of dollars. ROTHSTEIN and others in RRA devised an elaborate plan through which were sold purported confidential assignments of a structured pay-out settlements, supposedly reached on behalf of RRA for clients, in exchange for immediate payments to these clients of a discounted lump sum amount. Investors were being promised in excess of a 30% return on their investment which was to be paid out to the investors over time. While some of the cases relied upon to induce investor funding were existing filed cases, it is believed that the confidential, structured pay-out settlements were all fabricated. EFTA00223272 Epstein'. RRA, et al. Page 6 11. Based on media reports, Federal Bureau of Investigation (FBI) press conferences and releases and the Information the massive Ponzi scheme and pattern of criminal activity meant to lure investors began sometime in 2005 and continued through the fall of 2009, when the scheme was uncovered by some of the investors and the FBI. As of November of 2009, civil lawsuits were and continue to be filed against various Defendants as result of their massive fraudulent and criminal scheme. 12. This fraudulent and illegal investment scheme is also evidenced by the filing of Amended Complaint For Dissolution And For Emergency Transfer of Corporate Powers to Stuart A. Rosenfeldt, Or, In The Alternative, For the Appointment of A Custodian or Receiver by ROSENFELDT, and RRA, against ROTHSTEIN, individually. (Case No. 09 059301, In the Circuit Court of the Seventeenth Judicial Circuit, Broward County, Florida, Complex Business Div.), (hereinafter "RRA dissolution action, and attached hereto as Exhibit 2). 13. Plaintiff references the RRA dissolution action for the sole purpose that it acknowledges that RRA and ROTHSTEIN were in fact conducting an illegal and improper investment or Ponzi scheme based on promises of financial returns from settlements or outcomes of supposed legal actions, including the actions brought against Plaintiff EPSTEIN. The RRA dissolution action alleges in part that — "ROTHSTEIN, the managing partner and CEO of the firm (RRA), has, according to assertions of certain investors, allegedly orchestrated a substantial misappropriation of funds from investor trust accounts that made use of the law firm's name (RRA). The investment business created and operated by ROTHSTEIN centered around the sale of EFTA00223273 Epstein'. RRA, et al. Page 7 ment of RRA dissolution interests in structured settlements." See Preliminary State action, Exhibit 2 hereto. used in communications 14. In furtherance of the scheme, RRA's letterhead was ured settlements. RRA's trust regarding investment opportunities in purported struct s or wire transfer of monies account was used to deposit hundreds of millions of dollar nteed payments. from duped investors and other victims. RRA personally guara and fraudulent Court 15. Rothstein's scheme went so far as to manufacture false District Judge, Kenneth A. opinions/orders including forging the signatures of U.S. it in other cases. It is not Marra and U.S. Circuit Court Judge, Susan H. Black, 11th Circu d matters. See Composite yet known if he forged similar documents in Esptein relate Exhibit 3 hereto. on a daily basis through 16. The details of this fraudulent scheme are being revealed recent estimate of the financial various media reports and court documents. The most s. scope of the scheme is that it exceeds $1.2 billion dollar d as a defendant in three civil 17. Relevant to this action, EPSTEIN is currently name were handled by RRA and its actions alleging, inter alia, sexual assault and battery that of which is filed in federal attorneys including EDWARDS prior to its implosion — one .C. S.D. Fla.)(Jane Doe is a court (Jane Doe'. Epstein, Case No. 08-CIV-80893, U.S.D filed in state court in the 15th named Defendant herein), and two of which have been Epstein, Case No. Judicial Circuit Court, Palm Beach County, State of Florida, 502008CA028051XXXXMB AB;..'. Epstein, Case No. 502008CA028058XXXXMB EFTA00223274 Epstein RRA, et al. Page 8 AB), (hereinafter collectively referred to as the "Civil Actions," and ■ is a named Defendant herein). The Civil Actions were all filed in August and September of 2008. 18. What is clear is that a fraudulent and improper investment or Ponzi scheme was in fact conducted and operated by RRA and certain of the named Defendants, which scheme directly impacted EPSTEIN as a named defendant in the Civil Actions. 19. Miami attorney and developer, Alan Sakowitz, was quoted in a November 2009 article as saying that he had met with,ROTHSTEIN as a potential investor in August.of 2009, but became suspicious. He stated "I was convinced it was all a Ponzi scheme and I notified the FBI in detail how SCotty ROTHSTEIN was hiding behind a legitimate law firm to peddle fake investments."- Attorney Sakowitz was also quoted as saying ROTHSTEIN had sophisticated eavesdropping equipment and former law enforcement officers who would sift through a potential defendants' garbage looking for damaging evidence to use with investors to show how potential defendants could be in essence blackmailed into paying settlement that far exceeded the value of any legitimate damage claim. 20. Ft. Lauderdale attorney William Scherer represents multiple Rothstein related investors. He indicated in an article that RRA/Rothstein had used the "Epstein. Ploy ... as a showpiece as bait. That's the way he raised all the money. He would use. . .cases as bait for luring investors into fictional cases. All the cases he allegedly structured were fictional. I don't believe there was a real one in there." In fact, on November 20, 2009, William Scherer, on behalf of certain clients, filed a 147 page Complaint against ROTHSTEIN, David Baden, Debra Villegas, Andrew Barnett, TD Bank, N.A., Frank EFTA00223275 Epstein RRA, et al, Page 9 asserting various Spinosa, Kerstetter, Rosanne Caretsky and Frank Preve e behind the RRA facade; and allegations that further prove the massive Ponzi schem Complaint naming additional as of November 25, 2009, a 249 page Amended Defendants was filed. STEIN, David Baden, Debbie 21. In addition, and upon information and belief, ROTH Jenne (all employees of RRA) Villegas, Andrew Bamett, Michael Fisten and Kenneth meetings during which false through brokers or middlemen would stage regular ts that existed or RRA had statements were made about the number of cases/clien and share actual case files against EPSTEIN and the value thereof. They would show Thus, the attorneys and clients from the EPSTEIN actions with hedge fund managers. ges that otherwise may have have waived any attorney-client or work- product privile existed. of the actual Civil Action 22. Because potential investors were given access to some name of an existing Plaintiff files, investor-third parties may have became aware of a opposed disclosure of her legal who had filed anonymously against Epstein and had name. ARDS claiming the need 23. In all other instances, by RRA, ROTHSTEIN and EDW they were able to effectively for anonymity with regard to existing or fabricated clients, was a key element in the use initials, Jane Doe or other anonymous designations which make the investors believe fraudulent scheme. Fictitious names could be created to many other cases existed against Epstein. EFTA00223276 Epstein 1 RRA, of al. Page 10 24. In each of RRA's Civil Actions, the Plaintiffs are or were represented by RRA and its attorneys, including ROTHSTEIN and EDWARDS. 25. In addition, investors were told that in addition to the Civil Actions another fifty (50) plus anonymous females were represented by RRA, with the potential for hundreds of millions of dollars in settlements, and that RRA and its attorneys would sue Epstein unless he paid exorbitant-settlement amounts to protect his high-profile friends. 26. Upon information and belief, EDWARDS knew or should have known that ROTHSTEIN was utilizing RRA as a front for the massive Ponzi scheme and/or were selling an alleged interest or investment in the Civil Actions (and other claims) involving Epstein. 27. Further evidencing that EDWARDS (and possibly other attorneys of RRA) knew or should have known and participated in the continuation of the massive Ponzi scheme, a front-page Palm Beach Post article, dated November 24, 2009, reported on the recent filing of an amended forfeiture complaint by prosecutors against "dozens of ROTHSTEIN's real estate properties, foreign cars, restaurants and other assets — including $12 million in the lawyer's bank account in Morocco, along with millions more donated to political campaigns and charitable funds." The article further reported that — Attorney Scott ROTHSTEIN tapped into millions of dollars from his massive investment scam to cover payroll costs at his expanding Fort Lauderdale law firm, federal authorities said in court records released Monday. ROTHSTEIN's law firm (RRA) generated revenue of $8 million in one recent year, yet his 70-lawyer law firm had a payroll of $18 million, EFTA00223277 EpsteinI. RRA, et al. Page 11 prosecutors said. ROTHSTEIN, who owned half of RRA used investors' money from his Ponzi scheme to make up the shortfall, they said. Subsequent articles and court filings have reflected ROTHSTEIN received compensation in excess of $35.7 million. in 2008 and $10.5 million in 2009, while his partner Rosenfeldt received greater than $6 million in 2008. 28. ROTHSTEIN attempted to lure the entity known as D3 Capital Club, LLC, ("D3"), by offering D3 "the opportunity" to invest in a pre-suit $30,000,000.00 court settlement against EPSTEIN; yet this supposed settlement never existed and was entirely fabntated. To augment his concocted story, ROTHSTEIN, upon information and belief, invited D3 to his office to view thirteen (13) banker's boxes of case files in Jane Doe (one of the Civil Actions) in an attempt to substantiate that the claims against EPSTEIN were legitimate and that the evidence obtained against him by RRA, ROTHSTEIN, and EDWARDS (the "Litigation Team") was real. 29. Upon information and belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROTHSTEIN in making these offers by providing confidential, privileged and work- product information to prospective third-party investors. It appears that 13 out of the 40 boxes seized by the FBI as part of its investigation at RRA consisted of files relating to the Civil Actions involving EPSTEIN, as reported by counsel for the Bankruptcy Trustee. Until those boxes can be reviewed, as well as other discovery, Epstein will not know the depth of the fraud and those involved. EFTA00223278 Epstein I RRA. et al. Page 12 30. By using the Civil Actions against EPSTEIN as "bait" and fabricating settlements regarding same, ROTHSTEIN and others were able to lure investors into ROTHSTEIN'S lair and bilked them of millions of dollars which, in turn, was used to fund the litigation against EPSTEIN for the sole purpose of continuing the massive Ponzi scheme. 31. As part of this scheme, ROTHSTEIN and the Litigation Team, individually and in a concerted effort, may have unethically and illegally: a. Sold, allowed to be sold and/or assisted with the sale of an interest in non- settled personal injury lawsuits (which are non-assignable arid non- transferable) or sold non-existent structured settlements (including those cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor. money to pay plaintiffs (i.e., 11.111. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conversations in violation of state or federal laws and Bar rules; and e. Utilized the judicial process including, but not limited to, unreasonable and unnecessary discovery, for the sole purpose of furthering the Ponzi scheme. 32. Any such actions by ROTHSTEIN, and other attorneys, including the Litigation Team, directly or indirectly, would potentially be a violation of various Florida Bar Rules, EFTA00223279 Epstein RRA, at al. Page 13 including prohibiting the improper sharing of fees or costs and various conflicts of issues rules. 33. Evidencing that the Litigation Team knew or should have known of the improper purpose that ROTHSTEIN was pursuing in the continuation of the scheme, ROTHSTEIN used RRA's Litigation Team in the EPSTEIN cases to pursue issues and evidence unrelated to and unnecessary to the claims pled in the Civil Actions, but significantly beneficial to lure investors into the Ponzi scheme orchestrated by ROTHSTEIN and other co-conspirators. 34. Upon information and belief, ROTHSTEIN and others claimed their investigators discovered that there were high-profile individuals onboard Epstein's private jet where sexual assaults took place and showed D3 (and possibly others) copies of a flight log purportedly containing names of celebrities, dignitaries, and international figures. 35. For instance, the Litigation Team relentlessly and knowingly pursued flight data and passenger manifests regarding flights EPSTEIN took with these famous individuals knowing full well that no underage women were onboard and no illicit activities took place. ROTHSTEIN and the Litigation Team also inappropriately attempted to take the depositions of these celebrities in a calculated effort to bolster the marketing scam that was taking place. 36. One of Plaintiffs' counsel, EDWARDS, deposed three of EPSTEIN'S pilots, and sought the deposition of a fourth pilot (currently serving in Iraq). The pilots were deposed by EDWARDS for over twelve (12) hours, and EDWARDS never asked one question relating to or about.., and Jane Doe (RRA clients) as it related to EFTA00223280 EpsteinI. RRA, et al. Page 14 transportation on flights of RRA clients on any of EPSTEIN'S planes. But EDWARDS asked many inflammatory and leading irrelevant questions about the pilots' thoughts and beliefs (which will never be admissible at trial) which could only have been asked for the purposes of "pumping" the cases and thus by using the depositions to sell the cases (or a part of them) to third parties. 37. Because of these facts, ROTHSTEIN claimed that Epstein wanted to make certain none of these individuals would be deposed and therefore he had offered $200,000,000.00 to settle the claims of RRA female clients various potential plaintiffs in actions against EPSTEIN. The offer of a $200 million dollar settlement by EPSTEIN was completely fabricated; no such offer had ever been made. 38. EDWARDS' office also notified Defendant that he intended to take the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) Alan Dershowitz (noted Harvard Law professor, constitutional attorney . • and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and 1) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEIN with whom he knew through business or philanthropic work over the years. None of the above-named individuals had any connection whatsoever with any of the Litigation Team's clients, ■. or Jane Doe. EFTA00223281 Epstein 1 RRA, et al. Page 15 40. EDWARDS filed amended answers to interrogatories in the state court matters, I. and IIII, and listed additional high profile witnesses that would allegedly be called at trial, including, but not limited to: (i) Bill Richardson (Governor of New Mexico, formerly U.S. Representative and Ambassador to the United Nations); and (ii) Any and all persons having knowledge of EPSTEIN'S charitable, political or other donations;2 41. The sole purpose of the scheduling of these depositions or listing high profile friends/acquaintances as potential witnesses was, again, to "pump" the cases to investors. There is no evidence to date that any of these individuals had or have any knowledge regarding RRA's Civil Actions. 42. In furtherance of their illegal and fraudulent scheme against EPSTEIN, ROTHSTEIN, EDWARDS (who either know or should have known) and, at times, in her Civil Action against EPSTEIN: a) Included claims for de-triages in Jane Doe's federal action in excess of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Organized a Jane Doe TV media interview without any legitimate legal purpose other than to "pump" the federal case for potential 2 These high-profile celebrity 'purported' witnesses have no personal knowledge regarding the facts on these "Three Cases", but were being contacted, subpoenaed or listed to harass and intimidate them and Epstein, and to add 'star appeal to the marketing effort of the Ponzi scheme. EFTA00223282 Epstein 1RRA, et al. Page S6 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Borger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which had no bearing on the case, but so that the video and questions could be shown to investors. d) Conducted and attempted to conduct completely irrelevant discovery unrelated to the claims in or subject matter of the Civil Actions for the purpose of harassing and embarrassing witnesses and EPSTEIN and causing EPSTEIN to spend tens of thousands of dollars in unnecessary attorneys' fees and costs defending what appeared to be discovery related to the Civil Actions but was entirely related to the furtherance of the Ponzi scheme. e) After EDWARDS was recruited and joined RRA in the spring of 2009, the tone and tenor of rhetoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing the court on various motions from being substantive on the facts pled to ridiculously inflammatory and sound-bite rich such as the July 31, 2009, transcript when EDWARDS stated to the Court in "What the evidence is really going to show is that Mr. Epstein — at least dating back as EFTA00223283 Epstein RRA, et al. Page 17 itted, back to far as our investigation and resources have perm an attempt to 1997 or '98 — has every single day of his life, made we're not sexually abuse children. We're not talking about five, not talking talking about 20, we're not talking about 100, we're n to law about 400, which, I believe, Is the number know en. . . and it enforcement, we are talking about thousands of childr he devised is through a very intricate and complicated system that h him that where he has as many as 20 people working underneat locate these he is paying well to schedule these appointments, to girls." and legally f) As an example, EDWARDS filed an unsupportable fer of deficient Motion for Injunction Restraining Fraudulent Trans rty of Assets, Appointment of a Receiver to Take Charge of Prope Potential Epstein, and to Post a $15 million Bond to Secure Judgment, in Jane Doe Epstein, Case No. 08-CV-80893- was the Marra/Johnson. The motion was reported in the press as ing). ultimate goal (i.e., to "pump" the cases for investor follow id of However, the Court found "Plaintiffs motion entirely devo evidence . . . ", and denied the motion in toto. les that he g) ROTHSTEIN told investors he had another 52 fema ve, represented, and that Epstein had offered $200 million to resol EFTA00223284 Epstein'. RRA, et al. Page 18 million, but that he could settle, confidently, these cases for $500 separate and apart from his legal fees. ld have known h) ROTHSTEIN and the Litigation Team knew or shou minimal value that their three (3) filed cases were weak and had for the following reasons: (i) — testified she never had any type of sex with Epstein; worked at numerous strip clubs; is an admitted prostitute and call girl; has a history of illegal drug use (pot, painkillers, Xanax, Ecstasy); and continually asserted the 5th Amendment during her depositions in order to avoid answering relevant but problem questions for her; (ii) ■- testified she worked at eleven (11) separate strip clubs, Including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and N. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescription painkillers and drugs to customers and prostituting themselves. (iii) Jane Doe (federal case) seeks $50 million from Epstein. She and her attorneys claim severe EFTA00223285 Epstein'. RRA, et al. Page 19 emotional distress as a result of her having voluntarily gone to Epstein's home. She testified that there was never oral, and or sexual intercourse; nor did she ever touch his genitalia. Yet, Jane Doe suffered extreme emotional distress well prior to meeting Epstein as a result of having witnessed her father murder his girlfriend's son. She was required to give sworn testimony in that matter and has admitted that she has lied in sworn • testimony. Jane Doe worked at two different strip dubs, including Platinum Showgirls in Boynton Beach. ridiculous and irrelevant discovery such as i) Conducted ard subpoenaing records from an alleged sex therapist, Dr. Leon ted Bard in Massachusetts, when the alleged police report reflec h named that EPSTEIN had only seen a chiropractor in Palm Beac alleged Dr. Bard. No records relating to EPSTEIN existed for this ds was sex therapist, Dr. Bard, and the alleged subpoena for recor al; just another mechanism to "pump" the cases for investor appe behalf of j) Allowed a Second Amended Complaint to be filed on ■. alleging that EPSTEIN forced the minor Into "oral sex," yet ■. testified that she never engaged in oral, anal, or vaginal EFTA00223286 Epstein RRA. et al. Page 20 intercourse with EPSTEIN and she had never touched his genitalia. k) Told investors, as reported in an Associated Press article, that celebrities and other famous people had flown on EPSTEIN'S plane when assaults took place. Therefore, even though none (zero) of RRA's clients claim they flew of EPSTEIN'S planes, the Litigation Team sought pilot and plane logs. Why? Again, to prime the investment "pump" with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three clients, already had a copy of the NPA. They knew what it said and they knew the civil provisions in the agreement had no impact whatsoever on the three pending Civil Actions. The concept behind certain civil provisions in the NPA was to allow an alleged victim to resolve a civil claim with Epstein, maintain her complete privacy and anonymity and move on with her life. As an assistant United States Attorney stated at a hearing in federal court, the NPA was not designed "to hand them a jackpot or a key to a bank." EFTA00223287 Epstein 1 RRA, et al. Page 21 43. ROTHSTEIN, with the intent and improper motive to magnify his financial gain so continue to fund the fraudulent and illegal investment and/or Ponzi scheme, had EDWARDS demand excessive money from EPSTEIN in the Civil Actions. 44. The actions described in paragraph 42 above herein had no legitimate purpose in pursuing the Civil Actions against EPSTEIN, but rather were meant to further the fraudulent scheme and criminal activity of ROTHSTEIN so that he and others could ,fraudulently overvalue the set