EFTA00596488.txt

"Plaintiff, JEFFREY EPSTEIN, (hereinafter EPSTEIN), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN"

"files this action against Defendants... BRADLEY J. EDWARDS, individually"

"files this action against Defendants... and L.M., individually."

"At all times relevant hereto, ROTHSTEIN was the managing partner and CEO of RRA."

"EDWARDS was an employee, agent, associate, partner, shareholder, and/or other representative of RRA."

"Defendant, ROTHSTEIN and Stuart Rosenfeldt, are and were the principal owners of equity in RRA and each co-founded RRA."

"Defendant, ROTHSTEIN and Stuart Rosenfeldt, are and were the principal owners of equity in RRA and each co-founded RRA."

"L.M. was represented by RRA, ROTHSTEIN and EDWARDS in a civil lawsuit against Epstein"

"Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009... the defendant, SCOTT W. ROTHSTEIN"

"Upon conviction of the offense of RICO Conspiracy set forth in Count 1 of the Information, the defendant, SCOTT W. ROTHSTEIN, shall forfeit"

"Upon conviction of the offense of Money Laundering Conspiracy set forth in Count 2 of the Information, the defendant, SCOTT W. ROTHSTEIN, shall forfei"

"Upon conviction of the offense of Conspiracy to Commit Mail Fraud and Wire Fraud... as set forth in Counts 3, 4, and 5 of the Information, the defenda"

"December 2, 2008 Interstate wire transfer sent from TD Bank to Gibraltar Bank"

"October 16, 2009 Interstate wire transfer sent to TD Bank from JP Morgan Chase"

"Defendant ROTHSTEIN and RRA maintained approximately thirty-eight (38) bank accounts at TD Bank, which were utilized during the course of the Ponzi sc"

"Defendant ROTHSTEIN and RRA maintained at least four (4) bank accounts at Gibraltar Bank, which were utilized during the course of the Ponzi scheme."

"All in violation of Title 18, United States Code, Section 1962(d)."

"COUNT Z (Money Laundering Conspiracy, 18 U.S.C. 1956(h))"

"ROTHSTEIN and EDWARDS engaged in a pattern of racketeering activity through the commission of crimes"

"Defendant Rothstein was the Chief Executive Officer (CEO) and Chairman of Rothstein, Rosenfeldt and Adler, PA."

"ROBERT . CRITTON, JR., ESQ. ... (Attorneys for Plaintiff)"

"Case 0:09-cr-60331-JIC ... UNITED STATES OF AMERICA, Plaintiff; v. SCOTT W. ROTHSTEIN, Defendant."

"Plaintiff EPSTEIN respectfully demands the entry of a judgment for damages against all the named Defendants."

"with EDWARDS and RRA as her attorneys, L.M. did a 180 at her September, 2009 deposition"

"L.M. did a 180 at her September, 2009 deposition in saying: . . . Once they were there, they were scared out of their mind."

"the very existence of RRA was based on the continuation of the massive Ponzi scheme orchestrated by ROTHSTEIN"

"As Magistrate Judge Linnea Johnson wrote in a discovery order dated September 15, 2009 (DE 299 in Federal Case #08-80119)"

"criminal charges have only been brought against ROTHSTEIN"

"After EDWARDS was recruited and joined RRA in the spring of 2009"

"Epstein v. RRA, et al."

"Alan Dershowitz ... one of EPSTEIN'S criminal defense attorneys"

"EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition."

"passenger manifests regarding flights EPSTEIN took with these famous individuals"

"ROTHSTEIN, who owned half of RRA used investors' money from his Ponzi scheme to make up the shortfall"

"RRA and its attorneys including EDWARDS prior to its implosion"

"Epstein v. RRA, et al. Page 7 interests in structured settlements."

"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 cour"

"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"

"William Scherer, on behalf of certain clients, filed a 147 page Complaint against ROTHSTEIN"

"$12 million in the lawyers bank account in Morocco"

"Michael Fisten and Kenneth Jenne (all employees of RRA)"

"After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion"

"ROTHSTEIN... had EDWARDS demand excessive money from EPSTEIN in the Civil Actions."

"RRA and its attorneys in the Civil Actions against EPSTEIN may have compromised their clients' interests... promised a financial interest in the outco"

"Non-Prosecution Agreement (NPA) between Epstein and USAO"

"by September 24, 2009, the date on which L.M. began her deposition in her civil action... L.M.'s new and very different tale about purported sexual mi"

"L.M. was insistent that Jeffrey is an awesome man... However, once in the hands of EDWARDS and RRA, L.M.'s story changed dramatically."

"the defendant, SCOTT W. ROTHSTEIN, shall forfeit... (RP 1 ) 2307 Castilla Isle, Fort Lauderdale, Florida"

"the defendant, SCOTT W. ROTHSTEIN, shall forfeit... (RP2) 2308 Castilla Isle, Fort Lauderdale, Florida"

"Defendant ROTHSTEIN and other co-conspirators also initiated and conducted a scheme to defraud clients of RRA in order to perpetuate the Ponzi scheme."