IN THE CIRCUIT COURT OF THE FIFTEENTH

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50 2009CA040800XXXXMB AG JEFFREY EPSTEIN Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. ED DS, individually, and individually, Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO ROTHSTEIN'S MOTION TO SET ASIDE DEFAULT Plaintiff, JEFFREY EPSTEIN, submits his response in opposition to Defendant, SCOTT ROTHSTEIN'S ("Rothstein") Motion to Set Aside Default, and states: Background and Procedural Posture 1. Epstein filed the instant action against Rothstein and others on December 9, 2009. 2. Rothstein was the former Chairman and CEO of the now defunct law firm, Rothstein, Rosenfeldt & Adler, P.A. ("RRA"). Rothstein was a licensed, bona fide litigator, not a lay person unfamiliar with lawsuits and legal process. 3. Rothstein was indicted and pled guilty to five counts including racketeering, money laundering and fraud related to a massive Ponzi scheme he conducted through RRA. His sentencing is scheduled for June 9, 2010. 4. On December 09, 2009, Rothstein was personally served with the summons and Complaint in this action. See Verified Return of Service attached as Exhibit A and Affidavit of Carlos Aguirre, process server, attached as Exhibit B. EFTA00724224 5. As set forth in Mr. Aguirre's affidavit, Rothstein was in a hallway, out of his cell, with other prisoners, when a guard called his name and he came forward. See Exhibit B ¶5. Mr. Aguirre then "personally placed the Complaint and Amended Summons in Mr. Rothstein's hands and advised him that he was being served with a lawsuit. Mr. Rothstein turned and walked away with the papers I served him." Id. 6. On December 31, 2009, Epstein filed a Motion for Default due to Rothstein's failure to respond to the Complaint. 7. A default (attached as Exhibit C) was entered by the Clerk on January 21, 2010. 8. Over two months after being served with the Complaint, Rothstein filed a Motion to Set Aside Default on February 17, 2010. 9. Several weeks later and on the eve of the hearing on the Motion to Set Aside Default, Rothstein filed an affidavit on March 8, 2010 in support of his Motion to Set Aside Default (attached as Exhibit D). 10. The next day, March 9, 2010, a hearing was conducted on Rothstein's Motion to Set Aside Default and the Court deferred ruling so the parties could conduct discovery related to the motion (3/9/10 Order attached as Exhibit E). 11. On April 15, 2010, Epstein filed a Motion to Strike Affidavit of Scott Rothstein because Epstein was unable to depose Rothstein. 12. On April 23, 2010, the Court denied Epstein's Motion to Strike Affidavit of Scott Rothstein and granted an additional thirty (30) days to depose Rothstein (4/23/10 Order attached as Exhibit F). 13. However, Epstein has been unable to locate, let alone depose, Rothstein. 2 EFTA00724225 14. Indeed, Rothstein's own counsel has had considerable difficulty locating and communicating with his client. In an April 22, 2010 article in the South Florida Business Journal (attached as Exhibit G), it was reported that Rothstein's counsel, Mark Nurik, Esq., was unaware of his client's location for substantial periods of time and has only had limited contact with Rothstein. 15. Moreover, Epstein's counsel has made the numerous efforts to locate and depose Rothstein, to no avail: a. Telephone conference with Lisa Kaye, Case Management Coordinator/Legal Liaison at the Federal Detention Center in Miami — was advised they do not have custody of Rothstein, have no information on his whereabouts and could not assist in coordinating his deposition; b. Telephone conference with U.S. Marshal's office — was advised they are not responsible for coordinating depositions and would not give provide any information regarding Rothstein. c. Telephone conference Bureau of Prisons Inmate Locator in Washington D.C. — was advised they have no record of Scott Rothstein; d. Telephone conference with Port St. Lucie Jail — was advised they had custody of Rothstein for brief period, but had no information on his whereabouts; e. Two voicemails for Bureau of Prisons — never returned a call; f. Two letters and two voicemails for United States Attorney Paul Schwartz — never returned a call or responded to letters; and g. Voicemail for United States Attorney Jeff Kaplan — never returned call. Legal Standard - Setting Aside Default 16. It is axiomatic that a party moving to set aside a default must establish (1) due diligence in moving to set aside the default; (2) excusable neglect in failing to respond to the complaint; and (3) a meritorious defense to the allegations of the 3 EFTA00724226 complaint. See Hill v. Murphy, 872 So. 2d 919, 921 (Fla. 2d DCA 2003). 17. The party seeking to set aside the default bears the burden of demonstrating excusable neglect, a meritorious defense and due diligence. See Zivitz v. Zivitz, 16 So. 3d 841,849 (Fla. 2d DCA 2009) 18. The standard of review for an order denying a motion to vacate a default is whether the trial court abused its discretion. See Szucs v. Qualico Development, Inc., 893 So. 2d 708, 710 (Fla. 2d DCA 2005). Rothstein's Affidavit Does Nothing to Establish a Meritorious Defense 19. Courts have repeatedly held that to establish a meritorious defense, the defendant must tender either a defensive pleading showing the defense or a sworn motion or affidavit stating the facts supporting the meritorious defense. See Hill v. Murphy, 872 So. 2d 919, 921 (Fla. 2d DCA 2003). 20. In Hill, the defendant filed an affidavit in support of a motion to set aside a default in which he asserted that he did not enter into an agreement with plaintiffs. See Hill, 872 So. 2d at 921. The court found that "[w]hile this assertion does constitute a factual allegation in an affidavit, it does not establish a meritorious defense" because the causes of action against the defendant (negligent supervision, civil conspiracy and FDUTPA) "[do not] depend on the existence of a contract between [the parties]." Id. The court went on to note that "[a] factual allegation that does not meet the substance of the allegations against the affiant does and cannot state a 'meritorious' defense." Id. (Emphasis added). Accordingly, the court concluded that the trial court did not abuse its discretion in refusing to set aside the clerk's default. Id. 21. Rothstein did not tender a defensive pleading and his affidavit is a far cry 4 EFTA00724227 from establishing a meritorious defense. While he claims to have "many meritorious defenses to the Complaint," he only purports to describe one, which constitutes neither a factual nor legal defense to any of the counts in the Complaint. 22. The crux of Rothstein's purported defense is that co-Defendant, Bradley Edwards (a former RRA attorney), filed lawsuits against Epstein on behalf of his clients prior to joining RRA and that these "were and are real cases, with real plaintiffs that have real claims against Epstein." See Exhibit D ¶9. Then, without any explanation, Rothstein makes the conclusory assertion that these facts "go[] against several counts in the Complaint, including, but not limited to, the RICO count." 23. From his affidavit, it appears that Rothstein has still not read the Complaint. 24. The Complaint, in no uncertain terms, acknowledges that and ea are in fact real plaintiffs who have filed real cases. Indeed, the Complaint alleges that Rothstein "[u]sed investor money to pay plaintiffs (i.e., and MI III 'up front' money such that plaintiffs would refuse to settle the Civil Actions." See Complaint ¶31.c. So it is unclear what defense Rothstein is attempting to establish by asserting that and are real plaintiffs with real cases, a fact alleged in the Complaint. 25. What is clear is that Rothstein's affidavit falls woefully short of demonstrating a defense, let alone a meritorious one, that would support setting aside the default and the Court should therefore deny Rothstein's motion. "A factual allegation that does not meet the substance of the allegations against the affiant does and cannot state a 'meritorious' defense." See Hill, 872 So. 2d at 921. 5 EFTA00724228 Rothstein's Failure to Respond to the Complaint Was Not the Result of Excusable Neglect 26. To set aside a default, Rothstein must also demonstrate excusable neglect in failing to respond to the complaint. See Hill 872 So. 2d at 921. Rothstein's affidavit does not controvert the fact he was personally served and demonstrates that he essentially ignored this lawsuit. Such indifference to legal process is inexcusable. 27. In Medcom USA, Inc. v. Ryder Homes & Groves, Co. 847 So. 2d 594, 596 (Fla. 2d DCA 2003), defendant moved to set aside a clerk's default and filed affidavits of its president, vice president and chief counsel, which asserted that defendant "had not been served with process; that [defendant's] first knowledge of the suit was the receipt of the final judgment ... and that the company had immediately retained counsel to take appropriate steps to respond to the action." The court affirmed the trial court's refusal to set aside default under these circumstances because the defendant's "bare allegations that [defendant's CEO] had not been served with process are not sufficient as a matter of law to impeach the process server's return of service and sworn statement that she personally served [defendant's CEO]." Id. See also Marceca v. Southeast Bank, N.A., 521 So. 2d 156, 156 (Fla. 4th DCA 1988) (affirming trial court's denial of motion to set aside default where defendant's counsel intentionally or through gross neglect ignored the necessity to respond to the complaint and summons) . The Vanguard Group, Inc. v. Vanguard Security, Inc., 409 So. 2d 1219 (Fla. 3d DCA 1982) (holding trial court properly denied defendant's motion to set aside default where defendant's assertions showed only that defendant ignored the complaint). 6 EFTA00724229 28. Rothstein does not contest the fact that he was properly served with the Complaint and Summons. Instead, he asserts that "I do not recall being served with this lawsuit" and "[i]f I was properly served with this lawsuit, it has been misplaced within the pile of numerous lawsuits and voluminous amount of other legal papers and has not been located." See Exhibit D ¶6. That Rothstein is the target of "numerous lawsuits" as a result of his fraudulent scheme does not excuse his failure to respond to the instant suit. 29. Rothstein also asserts that he "did not have knowledge of [this lawsuit] until February, 2010." See Exhibit D ¶2. However, if Rothstein was personally served with the Complaint and Summons (which he does not contest), it follows that he must have had knowledge of the lawsuit. Since Rothstein's affidavit does nothing to controvert the verified return of service or affidavit of Carlos Aguirre (Exhibits A and B, respectively), the Court must assume that the Complaint and Summons were properly served. See Medcom USA, Inc., 847 So. 2d at 596 (holding that bare allegations that defendant had not been served with process are not sufficient as a matter of law to impeach the process server's return of service and sworn statement that she personally served defendant). 30. Indeed, Rothstein had to be taken from his cell into a separate room to be served with the lawsuit, a fact he admits in his affidavit. See Exhibit D ¶4. This is a not a situation where, for example, a defendant's counsel's secretary misplaced a complaint and forgot to calendar a response deadline. To the contrary, Rothstein was an attorney (although disbarred) and former CEO of RRA, a law firm which employed over 70 lawyers, and was personally served with this lawsuit. Rothstein's affidavit does nothing 7 EFTA00724230 to establish that his failure to respond to the Complaint was a result of excusable neglect. 31. Rothstein's counsel, Mark Nurik, also asserts that he did not have knowledge of the lawsuit until "recently." See Motion to Set Aside Default ¶6 — 7. 32. However, nine separate news articles (attached as composite Exhibit H) including The Palm Beach Post (12/08/09), The Sun Sentinel (12/10/09), NBC Miami (12/08/09), The ABA Journal (12/09/09), South Florida Lawyers (12/10/09), huffingtonpost.com (12/11/09), The AmLaw Daily (12/08/09), Business Insider (12/10/09) and Courthouse News (12/16/09), reported Epstein's lawsuit against Rothstein. Notably, the articles were published within days of Rothstein being served with this lawsuit (December 9, 2009). Thus, Rothstein's and Nurik's assertions that they had no knowledge of this case until "recently" are belied by the widespread media coverage. 33. Given the foregoing, it can hardly be said that Rothstein ignoring the properly served Complaint and Summons constitutes excusable neglect. 34. Unlike Medcom, where the defendant asserted he was not served (and in which the court nevertheless found said assertion insufficient), Rothstein does not even contest the fact he was served; he just does not remember it. How convenient, yet insufficient. 35. As his assertions do not come close to rising to the level of excusable neglect, the Court should deny Rothstein's Motion to Set Aside Default. Rothstein Fails to Establish Due Diligence in Moving to Set Aside the Default 36. Last, Rothstein must establish he acted with due diligence in moving to set 8 EFTA00724231 aside the default. See Hill, 872 So. 2d at 921. 37. Rothstein, in his affidavit, asserts that he learned of the lawsuit and default at some unspecified time in February, 2010 and then "immediately contacted [his] attorney and advise him of same which prompted the filing of my Motion to Set Aside Default and this Affidavit in Support thereof." See Exhibit D ¶8. 38. However, Rothstein fails to explain how he learned of this lawsuit or exactly when in February, 2010 he learned of it. 39. Rothstein filed his Motion to Set Aside Default on February 17, 2010. If Rothstein learned that a default was entered against him on February 1, 2010, for example, but failed to file anything for over three weeks, it can be argued he failed to exercise due diligence in moving to set aside the default. 40. But since Rothstein does not articulate how or exactly when he learned of the default, it is unclear whether Rothstein acted with due diligence in moving to set aside the default entered against him. 41. Accordingly, Rothstein has failed to meet his burden to establish the due diligence element. See Zivitz 16 So. 3d at 849 (holding that the party seeking to set aside the default has the burden to demonstrate due diligence in seeking relief from default, excusable neglect and a meritorious defense). Conclusion 42. Since Rothstein has failed to establish a meritorious defense to the allegations in the Complaint, excusable neglect in failing to respond to the Complaint and due diligence in moving to set aside the default, the Court must deny Rothstein's Motion to Set Aside Default. 9 EFTA00724232 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this Gary M. Farmer, Jr., Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 le, FL 33301 Jack Scarola, Esq. Searcy Denney Scarola Barnhart Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach. FL 33409 day of May 2010: Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Fax: Co-Counsel for Defendant Jeffrey Epstein Law Offices of Marc S. Nurik & Counsel to Scott Rothstein One East Broward Boulevard, Suite 700 Fort Lauderdale, FL 33301 "SF orneys for Defendant Bradley Edwards BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Palm Beach. FL 33401 Fax e D. Critton, Jr. .Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 10 EFTA00724233 ;I VERIFIED RETURNOF SERVICE 11 IN THE 15TH JUDICIAL CIRCUIT IN AND!OR PALM BEACH COUNTY FLORIDA TYPE OF WRIT: AMENDED PLAINTIFF JEFFREY EPSTEIN TO: Scott Rothstein. Register #91256-004 clo FDC, Miami Federal Detention Center 33 NE 4I" Street Miami, FL. 33132 vsk. MMONS & COMPLAINT CASE NO: 502009CA040800XXXXMB AG DEFENDANTS) SCOTT ROTHSTEIN, individually et-al.. PURSUANT TO THE REQUEST OF: ROBERT D. CRI ON. JR., ESQ.,WHOSE OFFICE IS LOCATED AT: 303 BANYAN BLVD., SUITE 400. WEST PALM BEAC FL 33401 ICARLOS AGUIRRE C.P.S # 810 RECEIVED THIS PROCESS ON: 1219109 O 8:00am AND SERVED THE SAME ON: 12/9/09 O 8:45am IN RfADE COUNTY FLORIDA. ( X ) INDIVIDUAL SERVICE. BY SERVING THE PERS N NAMED HEREIN A COPY OF THE AMENDED SUMMONS COMPLAINT, PETITION OR INITIAL PLE ING. COMMENTS: DESCRIPTION OF PERSON SERVED: WHITE MALE, 47 YEARS OLD, ABOUT 5'7 ABOUT 2001bs., GREY SHORT HAIR. I ACKNOWLEDGE, THAT I AM A CERTIFIED PROCESS SERVER IN THE CIRCUIT IN WHICH THIS PROCESS WAS SERVED AND THAT I RAVE NO IN REST IN THIS MATTER. UNDER PENALTY OF PERJURY. I DECLARE THAT littEAD THE FOREGOING VERIFIED RETURN OF SERVICE AND THE FACTS STATED IN IT ARE TRUR CARLOS AGUIRRE C.P.S # 810 EXHIBIT tr EFTA00724234 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Plaintiff, v. SCOTT ROTHSTEIN, Individually, BRADLEY J. EDWARDS, Individually, S., individually, Defendants. Complex Litigation, Fla. R. Civ. Pro.1201 CASE NO.502009CA040800X)00(MB AG AMENDED SUMMONS (Have not attempted to serve — Amended only as to Place of Service) PERSONAL SERVICE ON A NATURAL PERSON TO DEFENDANT(S): Scott Rothstein, Register #91256-004 do FDC, Miami Federal Detention Center 33 NE 4th Street Miami, FL 33132 IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the Clerk of this Court. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of this case. If you do not file your response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attomey right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book). SHARON R. BOCK Clerk & Comptroliei P.O. Box 4667 West Palm Beach, Florida 33402-4667 EFTA00724235 vs. Case No: If you choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the "Plaintiff/Plaintiff's Attorney" named below. ROBERT D. CRITTON, JR. BURMAN, CRITTON, LUTTIER & COLEMAN 303 Banyan Boulevard Suite 400 West Palm Beach, FL 33401 561/842-2820 THE STATE OF FLORIDA: TO EACH SHERIFF OF THE STATE: YOU ARE COMMANDED to serve this summons and a copy of the complaint/petition in this action the above-named Defendant. DATED ON December 8.2009 SHARON R. BOCK CLERK OF THE CIRCUIT COURT (SEAL) BY: (See Reverse Side) (Vease al reves) (Voir de L'autre cote de) EpNA SMITH DEPUTY CLERK EFTA00724236 vs. Case No: IMPORTANTE Usted ha sido demandado legalmente. Tine 20 Dias, contados a partir del recibo de esta notificacion, para contestar la demanda adjunta, por escrito, y presentarla ante este tribunal. Una llamada atelefonica na lo protegera. Si usted desea que el tribunal considere su defensa, debe presentar su respuesta por escrito, incluyendo el numero del caso y los nombres de las partes interesadas. Si usted no contesta la demanda a tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existen ostros requisitos legales. Si lo desea, puede usted consultar a un abogado immediatamente. Si no conoce a un abogado, puede llamar a una de las oficinas de asistencia legal que aparecen en la guia telefonica. Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal usted anviar por correo o entegar una copia de su respuesta a la persona deominada abajo como "Plaintiff/Plaintiff's Attomey" (Demandante o Abogado del Demandante). IMPORANT Des poursuites judiciares ont eta enterprises contra vous. Vous avez 20 jours consecutifs a partir de la date de l'assignation de cette citation pour deposer une reponse ecrite a la plaínte ci-jointe aupres de ce tribunal. Un simple coupe de telephone est insuffisant pour vous proteger. Vous etes oblige de deposer votre reponse ecrite, avec mention du numero de dossier ci-dessus et du nom des parties nommees ici, si vous souhaitez que le tribunal entende voutre cause. Si vous ne deposez pas votre reponse ecrite dans le relai requis, vouc risquez de perdre la cause ainsi que votre salaire, votre argent, et vos biens peuvent etre saisis par la suite, sans aucun preavis ulterieur du tribunal. II y a d'autres obligations juridiques et vous pouvez requerir les services immediats d'un avocat. Si vous ne connaissez pas d'avocat, vous pourriez telephoner a un service de reerence d'avocats ou a un bureau d'assistance juridique (figurant a l'annuaíre de telephones). Si vous choisissez de deposer vous-meme une response ecrite, il vous faudra egalement, en meme temps que cette formalite, faire parvenir ou expedier une copie de votre reponse ecrite au ”Plaintiff/Plaintiffs Attomey" (Plaignant ou a son avocat) nomme ci-dessous. EFTA00724237 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND Case No. 50 2009CA040800XXXXMB AG JEFFREY EPSTEIN Plaintiff, AFFIDAVIT OF CARLOS AGUIRRE STATE OF FLORIDA ) MIAMI-DADE COUNTY ) BEFORE ME, the undersigned authority personally appeared having personal knowledge and being duly sworn, deposes and says: 1. I, Carlos Aguirre, am certified by the State of Florida to serve legal process, C.P.S. #810. 2. I was hired by the law firm of Burman, Critton, Luther & Coleman to serve process in this matter on the Defendant, Scott Rothstein. 3. On December 8, 2009, I contacted the Federal Bureau of Prisons via facsimile requesting to serve process on Scott Rothstein. 4. On December 9, 2009, I arrived at the Federal Detention Center in Miami, Florida and personally served Scott Rothstein with the Complaint and Amended Summons at approximately 8:45 a.m. 5. Mr. Rothstein was in a hallway, out of his cell, with other prisoners. A EXHIBITS_ EFTA00724238 guard called Mr. Rothstein's name and he came forward. I personally placed the Complaint and Amended Summons in Mr. Rothstein's hands and advised him that he was being served with a lawsuit. Mr. Rothstein then turned and walked away with the papers I served him. FURTHER THE AFFIANT SAYETH NAUGHT. Carlos Aguirre STATE OF FLORIDA MIAMI-DADE COUNTY I hereby Certify that on this day, before me, an officer duly authorized to administer oaths and take acknowledgments, personally appeared Carlos Aguirre known to me to be the person described in and who executed the foregoing Affidavit, who acknowledged before me that he/she executed the same, that I relied /upon the ( 9 following form(s) of identification of the above named person: arn ajdn., and that an oath was/war/et taken. WITNESS my hand and official seal in the Count and State last aforesaid this of 'day , 2010. PRIN N (SEAL) NOTA PUBLIC/STATE OF FLORIDA COMMISSION NO.: 2 Forifrocf, Nolery Public Stole of Florida Jaso My ilRoberta Cotiflncn 00949740 to, Expires 01/21/2014 EFTA00724239 F IN THE C_ _MIT COURT OF THE 1 12 IEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case Number: 502009CA040800XXXXMB Division: AO JEFFREY EPSTEIN Plaintiff(s), -vs- SCOTT ROTHSTEIN, individually, BRAIIEY J. EDWARDS individually and individually Defendant(s), DEFAULT A default is entered in the above styled cause against: SCOTT ROTHSTEIN, individually for failure to serve a pleading at the time required by law. DONE AND ORDERED at the Clerk's Office, City of West Palm Beach, this 21 day of JANUARY, 2010. Sharon R. Bock Clerk & Comptroller t..42By: KIMBERLY BRADLEY Deputy Clerk Copies furnished to: BURMAN, CRITTON, LUTTIER & COLEMAN LLP 303 BANYAN BLVD., STE 400, WEST PALM BEACH, FL 33401-4349 SCOTT ROTHSTEIN, INDIVIDUALLY CJO FDC, MIAMI FEDERAL DETENTION CENTER, 33 NE of STREET, MIAMI, FL 33132 GARY FARMER , BSQ , 425 N. ANDREWS AVENUE, SUITE 2, FT. LAUDERDALE, FL 33301 JOHN SCAROLA , ESQ , 2139 PALM BEACH LAKES BLVD WEST PALM BEACH, FL 33409 PADULA & GRANT, PLLC 365 E. PALMETTO PARK ROAD, BOCA RATON, FL 33432-5015 EXHIBIT e/ EFTA00724240 PP* IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 2009 CA 040800 XXXXMB HONORABLE JUDGE DAVID F. CROW JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN BRADLEY J. EDWARDS, and Defendants. AFFIDAVIT OF SCOTT W. ROTHSTEIN IN SUPPORT OF MOTION TO SET ASIDE DEFAULT STATE OF FLORIDA 55.: COUNTY OF Before me, the undersigned authority, personally appeared, SCOTT W. ROTHSTEIN, who after being by me first duly sworn, on oath, deposes and states as follows: 1. I am a Defendant in the above-captioned matter. 2. I did not respond to the Summons and Complaint in this lawsuit because I did not have knowledge of its existence until February, 2010. In February 2010, I learned that this lawsuit was filed against me and that a default judgment had been entered against me for failure to respond. 3. From December 1, 2009 until March 1, 2010, I was detained at the Federal Detention Center in Miami, Florida. On March 1, 2010,1 was transferred to the Port St. Lucie jail. FTL:1661522:1 EXHIBIT D EFTA00724241 4. During that time frame I was pulled out of my cell many times by the Bureau of Prisons staff to receive service of lawsuits at all hours. 5. Inasmuch as the Bureau of Prisons rules and regulations do not allow a prisoner to hand any documents to any visitors, including counsel, upon service of various lawsuits, I simply informed my attorney who would then look up the case with the appropriate court and contact the attorney for the plaintiffs) in such cases and/or take whatever appropriate action was necessary. 6. To the best of my knowledge and belief, I do not recall being served with this lawsuit. If I was properly served with this lawsuit, it has been misplaced within the pile of numerous lawsuits and voluminous amount of other legal papers and has not been located. Even to date, I have not located the Complaint or Plaintiff's Motion for Default.2 7. 1 state in good faith that if I had actual knowledge of this lawsuit I would have advised my attorney as I have done with various other lawsuits currently pending against me. 8. As soon as I learned of the lawsuit, I immediately contacted my attorney and advised him of same which prompted the filing of my Motion to Set Aside Default and this Affidavit in Support thereof. 9. I have a viable defense to the allegations contained in the Plaintiff, Jeffrey Epstein's ("Plaintiff" or "Epstein"), Complaint. Without providing a detailed response to the Complaint herein, just one of many meritorious defenses to the Complaint is that at least one, if not more, of the lawsuits against Plaintiff which he references as the basis of this instant lawsuit (the "Civil Actions"), was filed with the court on behalf of certain clients by a defendant herein, Bradley Edwards ("Edwards"), prior to his employment as an attorney at the law firm Rothstein Rosenfeldt Adler ("RRA"). The fact that Edwards, prior to his employment with RRA, and prior 2 Since learning of this lawsuit, my attorney obtained a copy of the Complaint. 2 EFTA00724242 to our introductions with one another, already had client(s) suing Epstein in Civil Actions, goes against several counts in the Complaint, including, but not limited to, the RICO count. In fact, the Civil Actions filed by Edwards and/or other attorneys at RRA were and are real cases, with real plaintiffs that have real claims against Epstein and, this instant lawsuit is Plaintiffs feeble attempt to take advantage of my unfortunate circumstances to disqualify claims by real persons that deserve to have their day in court. 10. I respectfully submit that if the Court were to disallow my Motion to Set Aside Default, not only would I be extremely prejudiced inasmuch as I have viable defenses to the allegations contained in Plaintiffs Complaint, but the plaintiffs in the Civil Actions that Edwards and others at RRA filed against Epstein which he references in his Complaint in this matter would be prejudiced as well. A default entered against me in this matter would have the same effect as my admission to the assertions made by Plaintiff which would, in essence, allow Epstein to prevail against the plaintiffs in the Civil Actions on the basis that they are frivolous and fraudulent lawsuits, which they are not. Under penalties of perjury, I declare that I have read the foregoing affidavit and the facts stated in it are true. 3 EFTA00724243 STATE OF FLORIDA 51-Lucto. cout‘le) )ss.: BEFORE ME the undersigned authority, personally appeared SCOTT W. ROTHSTEIN, who after being by me first duly sworn on oath deposes and says that he is the Defendant in the above-styled c use; that he has read the foregoing Affidavit and the facts contained herein are true and correct. SWORN TO AND SUBSCRIBED before me this ceS day of Merl 2010, by SCOTT W. ROTHSTEIN, who is personally known to me or who has produced %Lucie Co•ASSX4 7—Qas identification. r-"?th,fO TARY PUBLIC eir Al ' E 1-20 Typed or Printed N of Notary Public My commission expires: NOTARY PUBLICSTATE OF FLORIDA Patrick B. Hogan Commission #01)910543 Expires: SEP. 25, 2013 HOMO Ilato Anditalt IKRIDLNG CO, DC, 4 EFTA00724244 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDVIDS, individually, and ., individually, Defendants.. Case No. 50 2009CA040800)000(MB AG ORDER ON DEFENDANT SCOTT ROTHSTEIN'S MOTION TO SET ASIDE DEFAULT THIS CAUSE came before the,Court on Defendant Scott Rothstein's Motion to Set Aside Default, and the Court having heard argument of counsel and being fully advised in these premises, it is hereby ORDERED and ADJUDGED that said Defendant's Motion is hereby .grentedt _denied— , /2A-t cA.-/ dint)) tx. --V- 1.);1-± /C#0(244-42 -7t) Le- • &AV., astt, (i(ite., (21./r. 410,4 ( /f1-. e yin d_.-71,J2_. ,l/t<:)77 0'7 DONE AND .7?"4 ORDERED at Palm Beach County rthouse, Im Beach, Florida, this # day of iga/t-• 2010 ( David F. Crow Circuit Judge EXHIBIT E' Copied furnished to: ROBERT D. CRITTON, JR., ESQ., Burman, Critton, Luttier & Coleman, 303 Banyan Boulevard, Suite 400, West Palm Beach, FL 33401, MARC S. NURIK, ESQ., Law Offices of Mark S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301, GARY M. FARMER, JR., ESQ., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL.. 425 N. Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301, JACK SCAROLA, ESQ., Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409, and JACK ALAN GOLDBERGER, ESQ., Attorbury Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012 EFTA00724245 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and.., individually, Defendants. • / Case No. 50 2009CA040800XXXXMB AG ORDER ON MOTION TO STRIKE AFFIDAVIT OF SCOTT ROTHSTEIN THIS CAUSE came before the Court on Motion to Strike Affidavit of Scott Rothstein, and the Court having heard argument of counsel and being fully advised in these premises, it is hereby ORDERED and ADJUDGED that said Motion is hereby fidlAittAl.v / Attin --an-L‘r,--e 12 vvie/ 61-4.--c-,s 7{7 aget-J /4,474 ---, 76 O 4-6,--1 ettoCez: O;1 4 46S-. DONE AND ORDERED at Palm Beach C Courtho se, est trn-Beach, Florida, this 62 day of David F. Crow Circuit Judge EXHIBIT E Copied furnished to: ROBERT D. CRITTON, JR., ESQ., Burman, Critton, Luttier & Coleman, 303 Banyan Boulevard, Suite 400, West Palm Beach, FL 33401, MARC S. NURIK, ESQ., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301, GARY M. FARMER, JR., ESQ., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL. 425 N. Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301, JACK SCAROLA ESQ., Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409, and JACK ALAN GOLDBERGER, ESQ., Atterbury Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012 L. EFTA00724246 South Florida Business Journal: Rothstein sentencing moved to June 9 Page 1 of 2 Nein**1 Leal Na MOntererfr She,* Then "Mom alfiarehtR ..:.-ntOC•011ruCre: 4.tta ;:ospwar err_ Tito Short Answer: Get advice. ennui with ours aa weeds al vet Roil autism* OM. Cueseenlis Bank of Ample° cc4;'. hum Fibrins JOURNAL ..... ..... . Okiesedater at Bath Honda • sue 1 Nara 1 MN@ I J:CR 76M at I a S1. HOME Neva eadau.lilialt418 SALDISILMKTO REAL ESTATE MIRO MCVAY Gaga& TRAM MOPO MRCS MEbusiness news *et Tarr Bit Gears • Ossified& Emal Neils Baled Uses Steepen-a Freeissues ere weeder. ieces• sow *Phalli% Piet tee ill PtMa Etle'eAti sF100•01•0,01•••14)01.8d h JO. ... . .... Blog: Scott Rothstein: Picking i SEARCH MORE Scoff Rassfein• Preldry Up The Races up the Pieces arin Rothstein Sentencing Moved le ar.d Er Reponse To June 9 renew, %aerie , . Moab* Ape 73.101¢. ttreph EDT I Medea Dusty, Apt 22, Xi10, I sown RIM alp Res FM state canawrn A Judge has moved Pearl sdieMer Stott Rothstein's sentencing back more than a month. That es not necessivey so unusual, but the reasons seem pretty weird. There's a motion from ROthstelnl attorney, Marc Plunk, that's unlike anything rye seen In a court case recently. start mew This canes after the first sealed deo-mein was Med In Rothstein's amuse case, which is a signal that might moan the feds we recommending s lighter sentence because of COMMration. Ruck has already admitted to aeatirg a SmokesCreen of misdirection so that the public and certain alleged crIrrimals would think mat Rothstein was flaunting federal gurisdlcUon before : he was arrested. Hunk dans that Ftothstein's cooperation with federel authonties by providing evidence for alleged mafla slings has Interfered with Nurik's ability to communicate with him. According to federal authorities and numerous media reports, Rothstein helped set up two enViCireS of Five Star ececuthe Protection & Investigation, a local Manny Wm that had ties to the meta, rind Roberto Settinen, an alleged SlOkan mare connection In South Florida. MI three were hit with redcoat indkunents alter Rothstein allegeely asked them to launder money and destroy evidence of his POMi scheme. Here's the relevant text of Rurlis recpest for a later sentencing date: TSpecifKaY, the defendant is presently in protective housing outside of this district arra tinted differently than other inmates undersigned counsel's contacts with his client trust be arranged and approved in advance through the government, which creates delay. "There have been numerous occasions in the past few months when undersigned counsel has been unaware of his client's location and has been repeatedly out of contact with his tient for substartral penods of time, incloSing ono period for over two weeks. "Given those imitations, in the pest Ave weeks, counsel has only been able to meet with his ! Sent on two occasions. Currently, there is no ability to e-mad the defendant, aid phone i contact is wiry limited. even the senate') and maw of legal mad takes ranger than the I norm. Rothstein was to be sentenced Hay 6. The new date at hoe 9, at 9:30 Osherow led seision, &mu a as romoinuo fuonAtt.•rt 4.04800A Poe 1 *a' Ew] , g aintnia,mpeGse clonmoitepseol, 1 anew Picking up the Scott Rothstein Pieces Archive Fall 2010g11 kixuare 701O (sick neer mow Mao r211 Yash "MOM darmer1010111 MorealtSr 20cn a) EtalaiSUSISISI2arbin • Coin Cormorant anorrosert fa22. TWA as Aucciate". 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RAS • glalltaraliallthlamai , • Baliblaillealthila • aOIBredarlltd i • IIIIIISWitintattleit earon.seaun4Vvaticiul wee EXHIBIT G' http://southflorida.bizjoumals.com/southflorida/blog/picicing_up_the_pieces/2010/04/roths... 4/23/2010 EFTA00724247 South Florida Business Journal: Rothstein sentencing moved to June 9 Page 2 of 2 SM AL NitilITION Start yc.xs %vitt: 3 FREE vret*Ze nto., Ix. cat a Rastratca 00. ft she onoile,acceptinol 0110% O nintenint sad ;Vox% Potty ONLINE: braiNrins, ess4 I =n ib= I sel &MO/MI -all:WS* ;tarate reicarsiaaaigladaussaulait vnmr 52425ag I Mat I biar" n4aci'wq traLttil Vat dreAl vita imigsmatutass 'nmet ;Mk com AffLIATEI eat, igtpot095.41100JcanY I SCalseuanmPtth I Snort,- ,fewt I U*V. Fran TiChi ICOFI3Sh 01010 Ainc,c4n Ca Bonny Ammo% n:. int m format Al Witt re.4:400 maktiOce Dc the reaynoltninmescol 6sifitqica. Vonsnoti. acted r ',Woe* uwa.onegt.iin re toot non poinutlan 0 Iv:Woman, http://southflotida.bizjounials.coin/southflorida/blog/picldng_up_thcsieces/2010/04/roths... 4/23/2010 EFTA00724248 Rothstein, Epstein scandals converge with sex offender claiming he was used in swindle Page 1 of 2 The Palm Beach Post Print this page Close Rothstein, Epstein scandals converge with sex offender claiming he was used in swindle By JANE MUSGRAVE Palm Beach Post Staff Writer Updated: 7:51 p.m. Tuesday, Dec. 8, 2009 Posted: 9:27 p.m. Monday, Dec. 7. 2009 Two of the biggest scandals to rock South Florida in recent years merged today when attorneys representing billionaire sex offender Jeffrey Epstein filed a lawsuit claiming the part-lime Palm Beach resident is the victim of accused swindler Scott Rothstein. Rothstein, who is accused of running a $1.2 billion Ponzi scheme from his Fort Lauderdale -based law firm, trumped up civil lawsuits against Epstein, according to the complaint filed in Palm Beach County Circuit Court. He then lured investors by telling them Epstein had agreed to settle the lawsuits for as much as $200 million and they could get a cut of the cash. The problem for investors, according to the lawsuit filed by West Palm Beach attorney Robert Critton, is that Epstein never agr tle the lawsuits filed on behalf of women who are identified only by pseudonyms, such as "The offer of a $200 million settlement by Epstein was completely fabricated," Critton wrote. "No such otter had ever been made." Epstein faces roughly two dozens lawsuits filed by women who claim they were teenagers when he lured them to his Palm Beach mansion and paid them for massages and sex. The lawsuits started rolling in after he pleaded guilty in 2008 to felony solicitation of prostitution and procuring teenagers for prostitution. He was released from jail in July after serving 13 months of an 18-month sentence. Attorneys who worked for Rothstein, including Bradley Edwards and former Palm Beach County Circuit Judge William Berger, handled the three lawsuits the firm filed. But, they said, those represent only a fraction of the young women who Epstein molested. "What the evidence is really going to show is that Mr. Epstein . .. has every single day of his life made an attempt to sexually abuse children," Edwards said at a July court hearing. "We're not talking about five, we're not talking about 20, we're not talking about 100, we're not talking about 400 .. . we're talking about thousands of children." Such talk was part of a carefully orchestrated scheme to convince Investors they stood to make millions by investing with Rothstein, Critton said. Likewise, Critton said, Edwards has said he intends to depose various luminaries to testify against Epstein. Former president Bill Clinton, business mogul Donald Trump, former Sony Record president Tommy Mottola and magician David Copperfield have all been identified in court papers as people that will be deposed. While friends or acquaintances of Epstein, they have no information about the women involved in the lawsuits, Critton said, "The sole purpose in the scheduling of these depositions or listing high profile friends/acquaintances as 40nrik, potential witnesses was, again, to 'pump' the cases to investors," Critton wrote. EXHIBIT ft http://www.palmbeachpost.cominews/erime/rothstein-epstein-scandals-converge-with-sex-... 3/29/2010 EFTA00724249 Rothstein, Epstein scandals converge with sex offender claiming he was used in swindle Page 2 of 2 Neither Edwards or Berger responded to phone calls for comment. Critton isn't the first to make allegations that Rothstein fabricated cases as a way to lure investors. Fort Lauderdale attorney Wiliam Scherer, who has filed a $100 million lawsuit against Rothstein on behalf of scores of investors, has made similar claims. In a 147-page lawsuit, Scherer also said Rothstein told an investor about the phony $200 million settlement offer from Epstein. "He would use .. . cases as bait for luring investors into fictional cases," Scherer was quoted as saying. "All of the cases he allegedly structured were fictional. I don't believe there was a real one." Rothstein, a potent political fund-raiser who turned a small, unknown law firm into a powerhouse in seven short years. has pleaded not guilty to charges of RICO conspiracy, money-laundering conspiracy, mail fraud and two counts of wire fraud. His kingdom collapsed in late October when the feds raided his firm, Rothstein, Rosenfeldt & Adler. It is now closed. He has been disbarred. Find this article at: Print this page Close 1arn Your ithitbetoe0 75tilittomINE in aS link as 1C NV:laths* studytuatCo days, nighis, or wcakendi. Whenever and wherever you choose. 144\ Tialnaltal http://www.palmbeachpost.c,om/newskrime/rothstein-epstein-scandals-converge-with-sex-... 3/29/2010 EFTA00724250 : Epstein Claims Rothstein Link In Lawsuits - Sun Sentinel Page 1 of 2 Adversiament You are Wire SunSentinet corn > Colledens Laksui Ms by Geo?* Find a Lawyer Free Find the Riots Lawyer in Your Area Save Time • Describe Your Case Nast Web 14.0 id With CO, Yawnin Intim Lawson% Heart attack, stroke, organ rimy. ether nap inures Free cane. wen nnorv.t Whin Abram HeloLine Help's; Injured %halms For 25 yrs. Gel a Free Local Consultation Nowl owe epee...Woe Mom& co &tint of Neolinencet Find CellYou Have a Case. No Legal Fees Unless You Succeed. Falea.lnievaancorr. Free Case Evaluation Fast moonier about your case Severe Florida sense 1970 yaw( tem* toe ccIn FIND MORE STORIES ABOuT • LEW3Ull • Ponti scheme FEATURED ARTICLES See The bide, Pam awn Se, Calendar Jenny Epstein Swam*. 17. Underage sin sand to sue betionee ' meaner s 1719 Federal arms gain fort Lauderdale lawyer Scow.. Neynnue 0 400 Epstein Claims Rothstein Link In Lawsuits Decanter 10.2009 1 Sy Jane ausgrave The Pan Beach Poet Wane the victim. We the oldest Ind( in the book when it comes to dodging ailegatonS of sexual abuse, aOCOrang to attorneys representing more than a dozen women who are sung Palm Beach billionaire Jeffrey Epstein. claiming he paid them le nude massages and sex when they were as young as 14. Epstein filed sub Monday in Palm Beach County Circuit Cowl, saying Porai scheme suspect Scott Rothstein trumped up lawsuits against him as part of a twisted money-making plan Sul while aimed at the Fort Lauderdale attorney. it Is Willing more than an effort to tarnsh the women, their attorneys said Tuesday. Ads try doe*, Denture Cream Lawsuit Side Effects After Denture Cream Use? Get Help Now. Free Case Review www.ForThePeople.com Advertisement 1 Tip (la Ott Beilye: Ott dawn. 3 lbe• your belly, awry. teed by, using- du; / weird tip. "--> 'Ws We a SLAPP suit' said attorney Sid Garcia, who is representing a warren who says she was 17 when she was molested by the 58-year•Old financier. Epstein pleaded guilty in 2008 to solcitation of prostitution and ardnulMg teenagers for prostitution and served IS months of an 18-month sentence. An acronym for 'strategic lawsuit against public pantipation; SLAPPs are most correnOnly used by developers to silence critics by scaring them with the prospect of huge legal bills. 'Ws really not directed at Rothstein." Garcia said of the lawsuit -Ws an attempt to make his victims looks bad by association.' Attorney Spencer Kenn, who won a Confidential senlement from Epstein for one woman and Is representing another M a pending lawsuit, agreed. In the lawsuit tiled by West Palm Beach attorney Robert Critters Epstein claims Rothstein used the lawsuits to lure investors as pan of a 51.2 beon Ponzi scheme. Trumpeting the chance to turn a quid( profit, Rothstein falsely reported that Epstein had agreed b settle the lawsuits tor as much as $200 rniffon. By paying a discounted rate up front they could ultimately cash in when the settlement was paid In he Rothstein, whose law firm collapsed after federal agents raided It In late October. last week pleaded not guilty to charges that he made millions running similar schemes shoe 2005. Britton claims Rothstein, with the help ce attorney Bradley Edwards, who worked for rim, pumped up investors by telling them they weed call such Wineries as loaner President Bill Clinton, business tycoon Donald Trump and magician David Coppetteld to testify against Epstein. The message was that Epstein would pay big to protect Ns celebrity friends. Ads ar 00000 Insurance claim? Not getting what you deserve? Free consultation with attorneys www.stabineki-Nnt.com http://articles.sun-sentinel.com/2009-12-10/news/0912090393_1_ponZt-scheme-lawsuit-cl... 3/29/2010 EFTA00724251 Epstein Claims Rothstein Link In Lawsuits - Sun Sentinel - Page 2 Page 1 of 1 &lyeAMAMI RENT IT 7 WHILE IT'S STILL A NEW RELEASE You ale Mm. SunSenthetcom > Cabochons s Lawsuit Ads by Goosle HELP A CHILI) LIKE. DAWN: Sc.stisc,i a child.M.need for less than 51 a day and give her the bask necessities. FIND MORE STORIES ABCS., I • laweire • Pomp Scheme FEATURED ARTCLaS See The Video: Pen Seth Set Offender „matey Ecoein sorymele. 17, NM underage eel second to we biemnake uricasiss rt MIS Federal eget. lea Fort lairderdete lawyer Sca.. nkreenter I AM :1171.-f41111741 Epstein Claims Rothstein Link In Lawsuits Decanter 10, 2039 I By Jane Mayoral* The Palm Beech Post (Par 2 ol In the lawsuit, Craton atso goes after one of the three women who were represented by FICAAteisYS bun CI hal p6ints up contradictions in sworn statements the woman. dentilied only ass made lo FBI agents compared with those she node once to lawsuit watt feed in an interview with an FBI agent m 2007, ahe deathbed Epatem as -an awesome man• and described herself as a prostitute. She said none of the gels she took to Epelein ever complained. •Theyd beg me, you know. for us to go to Jeffreys house because they love Jeffrey. Jeffrey is a respectful wan," she said. Ad. by Go., . Yaz Lawsuit Experienced Attomeys Fighting For Your Rights. Call Morgan & Morgan. wsPAY ForThePeople com THE .04IND SIDE stargwr,Butuck I half RENT IT WHILE IT'S STILL A UV! RELEASE:. In a Septeritar deposition, nersiory Changed. •Ores they were there they were scared out of their rrthd," the said. 'They did a any ways and SOTO of them walked Out and said, 1E. cicol ever do this to me again This is the worst thing that ever happened to me.' Cretco said none of the women MIO we suing Epstein for Malone were drugged or coerced. They carnet to nis Palm Beach mansion freely. Many came 20.30 or CO times, some well after they turned 18 Further, he said. many either were or later became prostLtes or stdpoefs Any psychological problems they had had occurred well before they hooked up with Epstein. Kevin said such claims miss the point. This case is about whether or not a young girl has the capabllty to consent to inappropriate sexual contact: Ha 14- year-Old asked an adult lo go get drunk, its the adult's responsibility to slap her not to driset her to the oat. he sad In these cases, he sad. Epstein solicited underage girls for sex. Ads by Couple Yaz Birth Control Lawsuit Legal Settlements for Victims Of Birth Control - Free Legal Consult. www.YnAttomey.net Pie 1112 Index by Keno:alp/4ex by Dale 1 Pansy Potcy i Terms of Serve http://artieles.sun-sentinel.cona/2009-12-10/news/0912090393_1_ponzi-scheme-lawsuit-cl... 3/29/2010 EFTA00724252 Pervy Billionaire a Rothstein "Victim" I NBC Miami Page 1 of 2 % MIAMI Ctea PRINTTH IS Powered by el aticabiiity Pervy Billionaire a Rothstein "Victim" Billionaire se