EFTA00596488.pdf

EXHIBIT A EFTA00596488  IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. \MCCOMB v. Plaintiff, 50 2009 CA 0 h 03 SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and COPY L.M., individually, RECEIVED FOR FILING Defendants. oic 0 1Mg EMIVIONIt PUCK COMPLAINT GlAilit QQMPTR9 66011 PINWIT CIVIk,P1\1 1algi Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and professional obligations to the administration of justice, deliberately engaged in a pattern of racketeering that involved a staggering series of gravely serious obstructions of justice, actionable frauds, and the orchestration and conducting of egregious civil litigation abuses that resulted in profoundly serious injury to Jeffrey Epstein one of several targets of their misconduct EFTA00596489 Epstein v. RRA, 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. EFTA00596490 Epstein v. RRA, et al. Page 3 ing and works in Palm Beach 2. Plaintiff, EPSTEIN, is an adult and currently is resid County, Florida. , is an individual residing in 3. Defendant, SCOTT ROTHSTEIN ("ROTHSTEIN") in the State of Florida. In Broward County, Florida, and was licensed to practice law license in the midst of the November 2009, ROTHSTEIN voluntarily relinquished his law A"). He was disbarred by the implosion of Rothstein, Rosenfeldt and Adler, P.A. ("RR mber 1, 2009, ROTHSTEIN Florida Supreme Court on November 20, 2009. On Dece County, Florida. was arrested and arraigned in Federal Court in Broward ging partner and CEO of 4. At all times relevant hereto, ROTHSTEIN was the mana RRA. and were the principal 5. Defendant, ROTHSTEIN and Stuart Rosenfeldt, are owners of equity in RRA and each co-founded RRA. an individual residing in 6. Defendant, BRADLEY J. EDWARDS ("EDWARDS"), is the State of Florida. At all Broward County, Florida and is licensed to practice law in agent, associate, partner, times relevant hereto, EDWARDS was an employee, shareholder, and/or other representative of RRA. Beach County, Florida. 7. Defendant, L.M. ("L.M."), is an individual residing in Palm RRA, ROTHSTEIN and At all times relevant hereto, L.M. was represented by ntial participant in the EDWARDS in a civil lawsuit against Epstein and was an esse lly changing prior sworn scheme referenced infra by, among other things, substantia ulent scheme for the testimony, so as to assist the Defendants in promoting their fraud EFTA00596491 Epstein v. 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 v. 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 EFTA00596492 Epstein v. RRA, et at 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. EFTA00596493 Epstein v. 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 EFTA00596494 Epstein v. 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 settlements. RFtA's trust regarding investment opportunities in purported structured rs or wire transfer of monies account was used to deposit hundreds of millions of dolla guaranteed payments. from duped investors and other victims. RRA personally 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. led on a daily basis through 16. The details of this fraudulent scheme are being revea t estimate of the financial various media reports and court documents. The most recen rs. scope of the scheme is that it exceeds $1.2 billion dolla a defendant in three civil 17. Relevant to this action, EPSTEIN is currently named as handled by RRA and its actions alleging, inter alia, sexual assault and battery that were 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 v. 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 (L.M. v. Epstein, Case No. Judicial Circuit Court, Palm Beach County, State of Florida, 502008CA028058XXXXMB 502008CA028051XXXXMB AB; E.W. v. Epstein, Case No. EFTA00596495 Epstein v. RRA, et al. Page 8 Actions," and L.M is a named AB), (hereinafter collectively referred to as the "Civil st and September of 2008. Defendant herein). The Civil Actions were all filed in Augu investment or Ponzi scheme was 18. What is clear is that a fraudulent and improper in of the named Defendants, which in fact conducted and operated by RRA and certa dant in the Civil Actions. scheme directly impacted EPSTEIN as a named defen quoted in a November 2009 19. Miami attorney and developer, Alan Sakowitz, was a potential investor in August of article as saying that he had met with ROTHSTEIN as it was all a Ponzi scheme 2009, but became suspicious. He stated "I was convinced was hiding behind a legitimate and I notified the FBI in detail how Scotty ROTHSTEIN witz was also quoted as saying law firm to peddle fake investments." Attorney Sako and former law enforcement ROTHSTEIN had sophisticated eavesdropping equipment ' garbage looking for damaging officers who would sift through a potential defendants defendants could be in essence evidence to use with investors to show how potential the value of any legitimate blackmailed into paying settlement that far exceeded damage claim. multiple Rothstein related 20. Ft. Lauderdale attorney William Scherer represents used the "Epstein Ploy ... investors. He indicated in an article that RRA/Rothstein had money. He would use. . .cases as a showpiece as bait. That's the way he raised all the s he allegedly structured as bait for luring investors into fictional cases. All the case ." In fact, on November 20, were fictional. I don't believe there was a real one in there a 147 page Complaint against 2009, William Scherer, on behalf of certain clients, filed Barnett, TD Bank, N.A., Frank ROTHSTEIN, David Boden, Debra Villegas, Andrew EFTA00596496 Epstein v. RRA, et al. Page 9 Preve asserting various Spinosa, Jennifer Kerstetter, Rosanne Caretsky and Frank behind the RRA facade; and allegations that further prove the massive Ponzi scheme Complaint naming additional as of November 25, 2009, a 249 page Amended Defendants was filed. IN, David Boden, Debbie 21. In addition, and upon information and belief, ROTHSTE Jenne (all employees of RRA) Villegas, Andrew Bamett, Michael Fisten and Kenneth ings during which false through brokers or middlemen would stage regular meet nts that existed or RRA had statements were made about the number of cases/clie share actual case files against EPSTEIN and the value thereof. They would show and Thus, the attorneys and clients from the EPSTEIN actions with hedge fund managers. that otherwise may have have waived any attorney-client or work- product privileges 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 sed disclosure of her legal who had filed anonymously against Epstein and had oppo name. ARDS claiming the need 23. In all other instances, by RRA, ROTHSTEIN and EDW able to effectively for anonymity with regard to existing or fabricated clients, they were 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. EFTA00596497 Epstein v. RRA, et al. Page 10 represented by RRA and 24. In each of RRA's Civil Actions, the Plaintiffs are or were its attorneys, including ROTHSTEIN and EDWARDS. Civil Actions another fifty 25. In addition, investors were told that in addition to the , with the potential for hundreds (50) plus anonymous females were represented by RRA attorneys would sue Epstein of millions of dollars in settlements, and that RRA and its high-profile friends. unless he paid exorbitant-settlement amounts to protect his 26. Upon information and belief, EDWARDS knew or should have known that Ponzi scheme and/or were ROTHSTEIN was utilizing RRA as a front for the massive (and other claims) involving selling an alleged interest or investment in the Civil Actions Epstein. attorneys of RRA) knew 27. Further evidencing that EDWARDS (and possibly other on of the massive Ponzi or should have known and participated in the continuati mber 24, 2009, reported on scheme, a front-page Palm Beach Post article, dated Nove cutors against "dozens of the recent filing of an amended forfeiture complaint by prose urants and other assets — ROTHSTEIN's real estate properties, foreign cars, resta cco, along with millions more including $12 million in the lawyers bank account in Moro e further reported that - donated to political campaigns and charitable funds." The articl his massive Attorney Scott ROTHSTEIN tapped into millions of dollars from Fort Lauderdale investment scam to cover payroll costs at his expanding ay. law firm, federal authorities said in court records released Mond n in one ROTHSTEIN's law firm (RRA) generated revenue of $8 millio million, recent year, yet his 70-lawyer law firm had a payroll of $18 EFTA00596498 Epstein v. 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 fabricated. 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. EFTA00596499 Epstein v. RRA, et al. Page 12 and fabricating settlements 30. By using the Civil Actions against EPSTEIN as "bait" able to lure investors into regarding same, ROTHSTEIN and others were which, in turn, was used to fund ROTHSTEIN'S lair and bilked them of millions of dollars continuing the massive Ponzi the litigation against EPSTEIN for the sole purpose of scheme. tion Team, individually and in 31. As part of this scheme, ROTHSTEIN and the Litiga a concerted effort, may have unethically and illegally: sale of an interest In non- a. Sold, allowed to be sold and/or assisted with the able and non- settled personal injury lawsuits (which are non-assign s (including those transferable) or sold non-existent structured settlement cases involving Epstein); non-lawyers; b. Reached agreements to share attorneys fees with Jane Doe) "up c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Civil Actions; front" money such that plaintiffs would refuse to settle the ions in violation of d. Conducted searches, wiretaps or intercepted conversat state or federal laws and Bar rules; and to, unreasonable and e. Utilized the judicial process including, but not limited ring the Ponzi unnecessary discovery, for the sole purpose of furthe scheme. eys, including the Litigation 32. Any such actions by ROTHSTEIN, and other attorn ion of various Florida Bar Rules, Team, directly or indirectly, would potentially be a violat EFTA00596500 Epstein v. RRA, et al. Page 13 various conflicts of issues including prohibiting the improper sharing of fees or costs and rules. have known of the improper 33. Evidencing that the Litigation Team knew or should continuation of the scheme, purpose that ROTHSTEIN was pursuing in the EIN cases to pursue issues and ROTHSTEIN used RRA's Litigation Team in the EPST s pled in the Civil Actions, but evidence unrelated to and unnecessary to the claim i scheme orchestrated by significantly beneficial to lure investors into the Ponz ROTHSTEIN and other co-conspirators. s claimed their investigators 34. Upon information and belief, ROTHSTEIN and other ard Epstein's private jet where discovered that there were high-profile individuals onbo others) copies of a flight log sexual assaults took place and showed D3 (and possibly and international figures. purportedly containing names of celebrities, dignitaries, ingly pursued flight data 35. For instance, the Litigation Team relentlessly and know with these famous individuals and passenger manifests regarding flights EPSTEIN took and no illicit activities took knowing full well that no underage women were onboard ropriately attempted to take the place. ROTHSTEIN and the Litigation Team also inapp bolster the marketing scam that depositions of these celebrities in a calculated effort to was taking place. of EPSTEIN'S pilots, and 36. One of Plaintiffs' counsel, EDWARDS, deposed three in Iraq). The pilots were sought the deposition of a fourth pilot (currently serving EDWARDS never asked one deposed by EDWARDS for over twelve (12) hours, and clients) as it related to question relating to or about E.W., L.M., and Jane Doe (RRA EFTA00596501 Epstein v. RRA, et al. Page 14 EIN'S planes. But EDWARDS transportation on flights of RRA clients on any of EPST tions about the pilots' thoughts asked many inflammatory and leading irrelevant ques could only have been asked and beliefs (which will never be admissible at trial) which by using the depositions to sell the for the purposes of "pumping" the cases and thus cases (or a part of them) to third parties. Epstein wanted to make 37. Because of these facts, ROTHSTEIN claimed that therefore he had offered certain none of these individuals would be deposed and various potential plaintiffs in $200,000,000.00 to settle the claims of RRA female clients r settlement by EPST EIN actions against EPSTEIN. The offer of a $200 million dolla made. was completely fabricated; no such offer had ever been he intended to take the 38. EDWARDS' office also notified Defendant that depositions of and was subpoenaing: l); (i) Donald Trump (real-estate magnate and business mogu nal attorney (ii) Alan Dershowitz (noted Harvard Law professor, constitutio 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 (v) David Copperfield (illusionist). aintances of EPSTEIN with 39. The above-named individuals were friends and acqu the years. None of the whom he knew through business or philanthropic work over er with any of the Litigation above-named individuals had any connection whatsoev Team's clients, E.W., L.M. or Jane Doe. EFTA00596502 Epstein v. RRA, et al. Page 15 40. EDWARDS filed amended answers to interrogatories in the state court matters, E.W. and L.M., and listed additional high profile witnesses that would allegedly be called at trial, including, but not limited to: (1) 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, L.M. in her Civil Action against EPSTEIN: a) Included claims for damages 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. EFTA00596503 Epstein v. RRA, et al. Page 16 in Palm investors or to prejudice Epstein's right to a fair trial Beach County. named partner in c) EDWARDS, Berger and Russell Adler (another RRA) all attended EPSTEIN's deposition. At that time, had no outrageous questions were asked of EPSTEIN which could be bearing on the case, but so that the video and questions shown to investors. irrelevant d) Conducted and attempted to conduct completely Civil discovery unrelated to the claims in or subject matter of the witnesses Actions for the purpose of harassing and embarrassing thousands and EPSTEIN and causing EPSTEIN to spend tens of defending of dollars in unnecessary attorneys' fees and costs was what appeared to be discovery related to the Civil Actions but entirely related to the furtherance of the Ponzi scheme. the spring of e) After EDWARDS was recruited and joined RRA in against 2009, the tone and tenor of rhetoric directed to cases changed EPSTEIN used by Attorney EDWARDS and Berger from dramatically in addressing the court on various motions matory being substantive on the facts pled to ridiculously inflam when and sound-bite rich such as the July 31, 2009, transcript nce EDWARDS stated to the Court in E.W./L.M.: "What the evide as is really going to show is that Mr. Epstein — at least dating back EFTA00596504 Epstein v. RRA, et al. Page 17 itted, back to far as our investigation and resources have perm attempt to 1997 or '98 — has every single day of his life, made an 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 . . and it enforcement, we are talking about thousands of children. ed is through a very intricate and complicated system that he devis h him that where he has as many as 20 people working underneat he is paying well to schedule these appointments, to locate these girls." legally f) As an example, EDWARDS filed an unsupportable and sfer of deficient Motion for Injunction Restraining Fraudulent Tran erty of Assets, Appointment of a Receiver to Take Charge of Prop ntial Epstein, and to Post a $15 million Bond to Secure Pote Judgment, in Jane Doe v. Epstein Case No. 08-CV-80893- the Marra/Johnson. The motion was reported in the press as was ultimate goal (i.e., to "pump" the cases for investor following). of However, the Court found "Plaintiffs motion entirely devoid evidence . . . ", and denied the motion in toto. he g) ROTHSTEIN told investors he had another 52 females that ve, represented, and that Epstein had offered $200 million to resol EFTA00596505 Epstein v. RRA, et al. Page 18 million, but that he could settle, confidently, these cases for $500 separate and apart from his legal fees. known h) ROTHSTEIN and the Litigation Team knew or should have al value that their three (3) filed cases were weak and had minim for the following reasons: (i) L.M. — testified she never had any type of sex with Epstein; worked at numerous strip clubs; is an admitted prostitute and call girl; has a history of illegal drug use (pot, painkillers, Xanax, Ecstasy); and continually asserted the 5th Amendment during her depositions in order to avoid answering relevant but problem questions for her; E.W. — testified she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescription painkillers and drugs to customers and prostituting themselves. Jane Doe (federal case) seeks $50 million from Epstein. She and her attorneys claim severe EFTA00596506 Epstein v. 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 clubs, including Platinum Showgirls in Boynton Beach. ridiculous and irrelevant discovery such as i) Conducted Leonard subpoenaing records from an alleged sex therapist, Dr. ted Bard in Massachusetts, when the alleged police report reflec named that EPSTEIN had only seen a chiropractor in Palm Beach alleged Dr. Bard. No records relating to EPSTEIN existed for this ds was sex therapist, Dr. Bard, and the alleged subpoena for recor tor appeal; just another mechanism to "pump" the cases for inves beha lf of j) Allowed a Second Amended Complaint to be filed on sex," yet L.M. alleging that EPSTEIN forced the minor into 'oral vaginal L.M. testified that she never engaged in oral, anal, or EFTA00596507 Epstein v. RRA, et al. Page 20 intercourse with EPSTEIN and she had never touched his genitalia. k) Told i