IN THE CIRCUIT COURT OF THE

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 IE., individually, Defendants. EPSTEIN'S MOTION TO POSTPONE THE JUNE 4, 2010 HEARING ON ROTHSTEIN'S MOTION TO SET ASIDE DEFAULT Plaintiff, JEFFREY EPSTEIN ("Epstein"), moves to postpone the June 4, 2010 hearing on Defendant's, SCOTT ROTHSTEIN ("Rothstein"), Motion to Set Aside Default, and states: 1. Epstein filed the instant action against Rothstein and others on December 9, 2009. 2. On December 31, 2009, Epstein filed a Motion for Default due to Rothstein's failure to respond to the Complaint. 3. A default was entered by the Clerk on January 21, 2010. 4. Rothstein filed a Motion to Set Aside Default on February 17, 2010. 5. Several weeks later and on the eve of the hearing on Rothstein's Motion to Set Aside Default, Rothstein filed an affidavit on March 8, 2010in support of his Motion to Set Aside Default. 6. The next day, March 9, 2010, a hearing was held on Rothstein's Motion to EFTA01112644 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 A). 7. On April 5, 2010, counsel for Epstein wrote to counsel for Rothstein to coordinate Rothstein's deposition and indicated that since Rothstein is in jail, the location of his deposition would likely have to be moved. ask 4/5/10 Letter attached as Exhibit B. Counsel for Rothstein never responded to said letter. 8. On April 15, 2010, Epstein filed a Motion to Strike Affidavit of Scott Rothstein because he was unable to depose Rothstein. 9. On April 22, 2010, the Court denied Epstein's Motion to Strike Affidavit of Scott Rothstein and granted an additional thirty (30) days to depose Rothstein (4/22/10 Order attached as Exhibit C). 10. However, 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 D), 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. Mr. Nurik was quoted as follows: a. "(Rothstein) is presently in protective housing outside of this district.... Undersigned counsel's contacts with his client must be arranged and approved in advance through the government, which creates delay." b. "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 client for substantial periods of time, including one period for over two weeks." c. "Given these limitations in the past five weeks, counsel has only been able to meet with his client on two occasions. Currently, there is no ability to e-mail (Rothstein), and phone contact is very limited. Even the sending and receipt of legal mail takes longer than the norm." 2 EFTA01112645 See Exhibit C (emphasis added). 11. Interestingly, counsel for Rothstein had no problem obtaining Rothstein's notarized signature on his affidavit. 12. Due to the additional time given to depose Rothstein, the hearing on Rothstein's Motion to Set Aside Default was rescheduled to June 4, 2010. 13. However, Epstein has been unable to locate, let alone depose, Rothstein and therefore requests the Court postpone the June 4, 2010 hearing on the Motion to Set Aside Default. 14. 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. 15. In addition, news articles have suggested that Rothstein is entering the federal witness protection program due to his involvement In assisting the government 3 EFTA01112646 arrest reputed Gambino mob figure Robert Settinerl: h. tut [Rothstein) may end up spending less time behind bars; the feds plan to put him In prison under the witness protection program for helping sting Settinerl in the FBI undercover operation.' See 3/19/10 Miami Herald Article attached as Exhibit E. I. "Sources tell CBS4 News that because of his cooperation in this case [against Settineri), Rothstein will be entering the federal witness protection program — meaning he will serve his prison time for the Ponzi scheme under a different name and in a prison outside of Florida. See 3/15/10 CBS4 Article attached as Exhibit F. 16. Given the above-described difficulties in locating and deposing Rothstein, Epstein requests the Court postpone the June 4, 2010 hearing on Rothstein's Motion to Set Aside Default and provide an additional thirty (30) days to take Rothstein's deposition. WHEREFORE, Defendant, JEFFREY EPSTEIN, requests the Court postpone the June 4, 2010 hearing on Rothstein's Motion to Set Aside Default and provide an additional thirty (30) days to depose Rothstein and grant any additional relief the Court deems just and proper. 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 2e day of Msy, 2010: Gary M. Farmer, Jr., Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 — fax Attorneys for Defendant,. Jack Scarola, Esq. Seamy Denney Scarola Barnhart Shipley, P.A Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach. FL 33401-5012 Fax: Co-Counsel endant Jeffrey Epstein Law Offices of Marc S. Nurik & Counsel to Scott Rothstein 4 EFTA01112647 2139 Palm Beach Lakes Blvd. One East Broward Boulevard, Suite 700 West Palm Beach, FL 33409 Fort Lauderdale FL 33301 Attorneys for Defendant Bradley Edwards BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Palm Beach, FL 33401 Fax By: (Pi AI- R° .ert D. Craton, Jr. ci Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 5 EFTA01112648 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Clv. Pro.1201 Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. ED/IDS, Individually, and ., Individually, Defendants.. Case No. 50 2009CA040800XXXXMB AG ORDER ON DEFENDANT SCOTT ROTHSTEIN'S MOTION TO SET ASIDE DEFAULT THIS CAUSE came before the,Court on Defendant Scottflothstein'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— yuc e;ettiAji IP/ c-c.4....3 Thad- 7Z.; • 1914Ath et4t, 9 t "7171 /RA ehh.4 i(/#4 °vet in >an cC.7 *ton en DONE AND ORDERED at Palm Beach County-Co rthouse, st P Im Beach, Florida, this s — day of //hilt-- 2010 David F. Crbw Circuit Judge Copied furnished to: ROBERT D. CRITTON, JR., ESQ., Burman, Crilton, Lutlier & 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., Atterbury Goldberger & Weiss, PA., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012 EFTA01112649 YE J. MICHAEL BARMAN. PAP GREGORY W. COLEMAN. PA Matta D. CRITTON. JR.. PA. • BERNARD A. taunters MARK T. Linn. PA MICHAEL J. Pin DAVID A YAREMA IIIPSIDA &onomaim CIVIL TRW LOVER 7ADMITTIO TO PMCTIVI IN aCOADAAND COTORMO BURMAN, CRITTON LUTHER &COLEMAN, LIP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP Sent by Fax. E•Mall and US. Mali Mark Nurik, Esq. Rothstein, Rosenfedlt, Adler, P.A. 401 E. Las Olas Blvd., Suite 1650 Ft. Lauderdale, FL 33301 April 5, 2010 Re: Epstein v. Rothstein. et al, Case No. 50 2009CA040800XXXXMB AG Dear Mr. Nurlk: =MT= CADWELL BOBBIE M. MCKENNA AsHut STOKEN•BARING /Arty STOKES PAMUCAIS RITA H. SuossyK Of COUNSEL EDWARD M. RICCI 07 COUNSEL As you are aware, we have set your client's Motion to Set Aside Default on a special set for 40 minutes on April 30, 2010 at 3:30 p.m. The court indicated we both could take discovery. I am enclosing a Notice for the Deposition of Scott Rothstein at a court reporters office at West Palm Beach. I have set it for April 15, 2010. I am aware that Mr. Rothstein is in jail, and therefore probably cannot attend that deposition at that location. Therefore, I am willing to move the location. The deposition will deal solely with issues associated with his Motion to Set Aside the Default. If that deposition time does not work, please let me know. If it is your intent to file a motion for protective order regarding Mr. Rothstein, please so file. Additionally, I would like an additional date such that I can take Mr. Rothsteln's deposition in the case. Specifically, I would like to cover those Issues that are directed to Mr. Edwards, I have received a Notice from Mr. Edwards' attorney which requires me to do the necessary work and investigation such that I can make certain recommendations to my client. I am aware that Mr. Rothstein prior to his plea, was completely off limits to .a deposition. With his guilty plea, I would anticipate that he now 303 BANYAN BOULEVARD • SUITE 4430. WEST PALM BEACH. a 33401 • PHONE: ■ WINIMBCLCLAWCOlvt EXHIBIT EFTA01112650 Epstein v. Rothstein Page 2 is available to give a deposition. Would you please contact me such that the above discovery can be arranged. Cordially Yours, o D. Critton, Jr. RDC/clz EFTA01112651 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 M., 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 /716141e4 set," Att-rn--, Tivo-Yiefut 02 wi / /2•-d pophrwafi 6, go 614,as 74, alla) %AA-IS-76 66-61-> eixoccnz co -7‘ DONE AND ORDERED at Palm Beach C Florida, this (54 of 41 , 20 David F. Crow Circuit Judge Courtho est each, 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 Mato S. Nurlk, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301, GARY M. FARMER, JR., ESQ., Farmer, Jaffe, Weissing, Edwards, Rstos & Lehrman, PL. 426 N. Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301, JACK SCAR0LA, 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., 260 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401.50 EXHIBIT I 0_ EFTA01112652 KIN Hurtle South Florida Business Journal: Rothstein sentencing moved to June 9 Page 1 of 1 vraaaa: broil Wei risehrwen Mahn ra Ms win taw**. Swan:dos iViliwts Journal • ma zo, 'aria tibultroanakhargasmeusoverniaorldstelaitindai Rt elunfteltagralualorlinsimmewitirdsca_ttrol rida MIS JOURNAL Blog: Scott Rothstein: Picking up the Pieces Rothstein Sentencing Moved To June 9 Thursday, Asti 22.2010. 11Spre EDT I Madded Masan. Ana 22, 2010. lafem A fudge has moved Paul schemer Scott Rolinteln's sentencing back more than a month. that Is not necessarily so unusual, but re reasons seem pretty wad. There's a motion from Rothstein's attorney, Marc Nur*, that's unlike anything I've seen In a court case recently, Paul Eihrdirnann Reporter Nunk claims that ROthittla cooperation with federal authorities by acaciag evidence for alleged mans stings has interfered with NudWs ability to communicate with him, According to federal euthorilleS and numerous media reports, Rothstein helped set up two employees of Me Star executive Protection & Investigation, a local security rims that had ties to the malls, and Roberto Settineri, an alleged SicElan maha connection in South Panda. Ad three were hit with fetters! Indictments atter Rothstein needed'," asked them to launder money and destroy evidence of Ns Pond scheme. This comes after the nest sealed document was few In flothstelreS criminal case, which is a signal that might mean the reds are recommending a eghter sentence because of cooperation. aura( hal etreadv admitted to creating a smokescreen of misdirection so that the public and certain alleged criminals would think that Rothstein was flaunting federal jurisdiction before he was arrested. here's the relevant test of flunk's request for a later sentencing date: the defendant Is presently in protective housing outside of this Strict and treated differently than other inmates. Undersigned counsel's contacts with his clad must Ce arranged and approved in advance though the government, witch creates delay. `There have been numerous occasions n the past few months when understined counsel has been unaware of his client's location and Ms been repeatedly out of contact with Ns client for substantial periods of time, Including one penal for over two weeks. 'Given these limitations, in the past five weeks, counsel haste* been able to meet with his cbent on two occasions. Currently, there is no ably to Amall the defendant, and phrase contact is very limited. even the sending and receipt of legal mail takes longer than the norm." Rothstein was to be sentenced May 6. De new date Is )une 9, at 9:30g. ContoMait.IIHWittu• ratan iherat12# 010$ POOS-SSABSIONO.EVitiliriKPOWSSI Atl conleols of this Site ©American CilyButhiess Journals Inc. AU rights reserved. http://southflorida.bizjournals.com/southflorida/blog/picking_up_the_pieces/... 5/4/2010 EFTA01112653 Scott Rothstein figure accused of making threat - 03/19/2010 - Miamtheral... Page 1 of 3 ZheRliamiHeralb 4.P Posted on Fri, Mar. 19, 2010 Scott Rothstein figure accused of making threat Roberto Settineri, the reputed Sicilian mafioso snagged by Ponzi schemer Scott Rothstein in an FBI sting, had a little brush with the law in January. As he was eating al fresco at Soprano Cafe on Lincoln Road, Settineri opened his leather jacket to flash a handgun at a private security officer, a police report states. "I will put this gun in your f-----g mouth," Settineri told the security officer, the report says. "I know where you live. I'll go to your house and kill you and your family." Miami Beach police eventually caught up with Settineri, who denied threatening the guard with his firearm. The cops arrested Settineri, 41, of Miami, on an aggravated assault charge, a third-degree felony. But that's the least of his problems. Last week, FBI agents arrested Italian-born Settineri, a naturalized U.S. citizen who works as a wine wholesaler, on obstruction of justice and money laundering charges in connection with Rothstein's $1.2 billion investment scam. Federal authorities also accuse him of being connected to the mafia's Colombo and Gambino crime families. At the same time, Italian National Police officers flew to Miami and revealed charges accusing Settineri of belonging to the Sicilian mafia and participating in a slew of violent crimes. Settineri was a regular on Lincoln Road, where he sold wine to resta lining the popular pedestrian way. JANUARY INCIDENT Michael Catalano, Settineri's lawyer, said his client was eating with of other men at Soprano Cafe on Jan. 8 when he had the run-in with the http://wvvw.miamiherald.com/2010/03/19/v-print/1536775/rothstein-figure-... 5/11/2010 EFTA01112654 Scott Rothstein figure accused of making threat - 03/19/2010 - MiamiHeral... Page 2 of 3 security officer, Cesar Mainardi, who was on his patrol bike. He worked for Security Alliance, a company contracted with the city of Miami Beach, Catalano said Mainardi confronted Settineri over a woman they both knew. Mainardi "weaved his way through a tight crowd and intentionally harassed him," Catalano said. Settineri "told the security guard to leave him alone, and he made up these allegations." But Mainardi, in an interview with The Miami Herald, denied the fight was over a woman. In his police statement, Mainardi accused Settineri of threatening him for no reason: "Apparently he did not like the way I looked at him, and I noticed his reaction and wanted to talk to him, but he acted aggressive." 'HEATED ARGUMENT' Mainardi told police that Settineri flashed the semi-automatic weapon, which was in a holster on his belt. But "he never took it out," Mainardi said. Settineri left the restaurant after the confrontation, but Miami Beach police reached him on his cellphone. According to the police report, Settineri admitted having a "heated argument" with the security officer but denied "threatening him with any type of gun." Settineri said he owned four guns, but they were all at his Brickeil Key condo in Miami at the time of the incident. Police found no weapon on him. State records show that Settineri has a concealed-weapons permit. ROTHSTEIN LINK Rothstein, who came to know Settineri through a Broward security company he had hired for protection, allegedly talked Settineri into shredding documents and laundering $79,000 in November from the Fort Lauderdale lawyer's Ponzi scheme, according to an indictment unsealed last week. Rothstein, 47, who pleaded guilty to racketeering and other charges in January, faces up to 100 years in prison at his sentencing in May. But he may end up spending less time behind bars; the feds plan to put him in prison under the witness protection program for helping sting Settineri in the FBI undercover operation. lutp://www.miatniherald.com/2010/03/19/v-print/1536775/rothstein-figure-... 5/11/2010 EFTA01112655 Scott Rothstein figure accused of making threat - 03/19/2010 - MiamiHeral... Page 3 of 3 Italian authorities charged Settineri along with 19 other people allegedly linked to the Sicilian mafia. The charges: extortion, drug trafficking and attempted murder. © 2010 Miami Herald Media Company. All Rights Reserved. http://www.miamiherald.com 5/11/2010 EFTA01112656 I-Team: Rothstein Helps Take Down Alleged Mafia Player - cbs4.com Page 1 of 3 the ClitSI bTeam's Most Popular Mvssfgabons lateolw Descate eels Wade e The Downs Of Satan • dm Sapar. T he Priest and The Mt o AP Travers DirtyUMW Swat • (Moog Any Maim Jobs. Pent E•ma Pita Slums Comments (2) /Or K. 20 tit 4:44 pa US/taseem I-Team: Rothstein Scams Alleged Mafia Player Rothstein Hired Security Firm For SISK/Day 7. Coss TSMe4Mlnw6aants 111 WM (CHU I•TEAM) — In Sough Fiala: where Maslen sal chats we an overplay fad cads. Scott Rothstein may be remembered a vie vestal maw el tam &Lawyer who rose from abeam* to bulk one tithe most pr/ally powered law fins In Pe state, Rothstein new shut comikkal of blUag era and strangers Mkt. TM $1.2 bison Pond schwa he napalm adiestrated la Ow 1519511 to SANS Florida Wan He bed, tricked and deasked nosey everyone he met Md the Jim Deane tinge he caus*Smay Ilieltef be matted. Ems I Out Redislelka amid cm may Kama be the one he hee done on behalf of the fades* government The CBS. I-Team has leaned from muitka sources thst Rothstein was the key Mute In baba; down a aspected Halle tome Moths FBI ha been trying to catch for year,. test week, U.S. Marna Jeffrey Simian announced Me erten ol Oita IMMOusle, Including Roberto Mead, who der prosecutor described se the W ben., tot to OstribM0 other aganttadal is Brooklyn and La C. Hata n Pent. SPcy. Those areas were pen der IOW US sod Haan law enfoicement salon; Stoma sea dudog Wednaday's press conference. AI the same one Seined wes errata by en F81 SWAT Team at Ha home on Warn, Snack Ova staged marks' of to °ambito cane May wens latest In Droner. and minty members of as Siam mW. rereenli•Oen. Santa Mn de Gnu, were aka Into custody Li Palermo. Taken Into custody In Saes Fiala Slav with Set6ned was Dane Dromerhausa A Odd indkidual. Enrique Ros of Pembroke Pints was 'Merged Sol wee out a this country Swot* rata look piece. Seamed, Ofornetheuser as Roe wow Soma with one count of oonairecY lot:Ulna MOW and be counts a WelroMon as snowman Soobstruct federal proceedings. one ccuM of cosailray to launder money sod fivecounts ot substendve money kunailng N corMcard d d dew counts the mon cc'ld oath be Roamed to 110 yeas n prison. of I ow trims Scott Rani& COS Related Slideshowa 2010 KM TowneMOM SetectIon CPS. In We Community CA Chsmdlonsko Day 4 Related SiOria Although Rotelelka name ova appears M M Indiarnent not wee 4 mentioned Outing Wedneridayie pies* conerence el Po U.B. bTearr Rothstein Hired kidney' CISCe,C1384 fan ha leaned OM to man et the watt Of Sts at. Is none oaf then Scott Rothstein. 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Ir the mrq.%tEnn NI wee rot {_+o EXHIBIT • • 5/11/2010 EFTA01112657 I-Team: Rothstein Helps Take Down Alleged Mafia Player - cbs4.com Page 2 of 3 On Neoember 9th. It • more oirstily cgclusse•Md by federal agents. Rothstein Messed up el he Cistutil WO fora meant Tit vØ was men posed by Browsed New Testes. Centes,pap We aende. Pothsloks Not same ay gmeiled en Santee with Chimed 7. Once gain. he 'Mood he kennel cooperating wIth Wet& sulhoniSM Mee yeses ~nine ethers to mete tonne doh. Rothstein was now using Wows Wile on tie turf of the twtewit government Md me kids ay he was ecorewhil, 'AI eiltged In Wei IMIetmerni Steamed. Dromerhautte end Rol were owl of • compact to launder 10 n•lkon tri as funds.' Ginoe Raid Owing isilerinesdayis press cardensnoe. In January, el legend agents In Miami ~Mind to bold a case sgeonst %Me& a htgh lewd mate look pace St II*. Arta and Proffeffagrs Bea Fan and MOOeffs. as wen as Judder Oeparlmentoffioels from Wes/lepton. ers v ecresS He Mang, to net »di fAa Wan counserparle Whin peosecoso ware working on • mashie W•latrrienl egepr Nor*/ suspected ~whets o4 die Pahsrmo.Sseed CM* ongtffeelicn. Semi Mena de Oat Md 41 New York prosecutorsvote beading • seen% case mogul three staged members of the Gandåsto «Wm fans. The Weal au InveivIng Setting:I bed finely eaten them the Mk they had been~ for. nervous agreed trey world goorrantrle Uwlr cuss we mete the easels *Muffs neousty. Reftarge OMIT asks ~or In the Ulan National Pollee. *Mime In South Boas Isetweek with • handful of agent. to monene tel Skinmm operaion, The ~twit Intennedlary In Me US was Robert Seine& • nun frail Palermowho has been Bang In taking foe a tang P'rito; Grassi said. 'He has Impotent bee to the ~aka Ma, Iambi. el ~Oho end Coloenta Throe» Rolutrb &desert, Le Cosa Now. Wes Wag to µan new comedian' In the Us end Ws conneceent would enable the listen organtratan so lone» amen...Made' -Midrib a sery importeM day In the NM against the atmirtet Grp* itz «Ion of La Cosa Noses.' Grant *ski Today• resin. are the Basta very con seceded Invesegellon aided mkt by the lumen State PeSert together *oh tel FBI bows n hay end the Udad Steles" Jun how compile-Wed was the Inveatigsgont Net wrong to reveal Rothstein to» n phi Caw US ~nay Snosten oily catered this cryptic wagons* when asked whit trough. We Wan& end tel Americans together. Wks Sad meal InSmaltS that overlapped w/th no a who; he said. 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CBS Broackcaseug Inks ti Meta Revered.) kang (Been floe Never Been Ealiorl Ooksg Gien To PtgoaTour Horns • EcoZone: Store Seas EPP-RINI* Pan Keys Wonwo Go Hiked rot A Good Cause k Omarks OW: Hew Te Grow Orion Fanlo Weans Parli.ln To Go Green 160 Comment To peel totreente,ww Mod tOg lolly ~dap hem Need e log Wi kr)0101 hero Yew Name Year EaleR L_ -1•ViLlnol be dstffeyed with cornmeal sung.« sox kFk...1-...72 111• eg Murk mwmonrynebew opmi http://cbs4.comAtearn/Scott.Rothstein.Mafia.2.1563707.html 5/11/2010 EFTA01112658 1-Team: Rothstein Helps Take Down Alleged Mafia Player - cbs4.com Page 3 of 3 YourContimenti Post CenMeil CkizMs diansalere in No plebs' Mt keno lo robots vet Mw ISO Show Comments (2) 10210WOCSNI torte rp la *Wilmer* http://cbs4.com/iteam/Scott.Rothstein.Mafia.2.1563707.html 5/11/2010 EFTA01112659 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. ED DS, individually, and individually, Defendants. Case No. 50 2009CA040800XXXXMB AG r F3O7 M° n. nn' :c_ig m -na3 r- EPSTEIN'S RESPONSE IN OPPOSITION TO ROTHSTEIN'S MOTION TO SET ASIDE DEFAULT -rt r rn 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 IEWilbit A and Affidavit of Carlos Aguirre, process server, attached as Exhibit B. 1 EFTA01112660 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 115. 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 l served him." kJ, 8. 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 Sot 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 EFTA01112661 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 voicemalls 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 EFTA01112662 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. Sep Hill v. Murphy, 872 So. 2d 919, 921 (Fla. 2d DCA 2003). 20. In it 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 a[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 FI`UTPA) "[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." it (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 EFTA01112663 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[j 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 M.,M and Jane Doe are in fact real plaintiffs who have filed real cases. Indeed, the Complaint alleges that Rothstein liaised investor money to pay plaintiffs (i.e.,■ and Jane Doe) '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 M., and Jane Doe 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 a;legation 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 EFTA01112664 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 falling 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 elle 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. 3C 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 EFTA01112665 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 8, respectively), the Court must assume that the Complaint and Summons were properly served. See Medcom USA. Inc., 847 So. 2d at 598 (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 EFTA01112666 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 EFTA01112667 aside the default. at 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. EFTA01112668 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. =armar, Jaffe, Weissing, Edwards, Fistos & Ishrrnan, PL 425 N. Andrews Avenue, Suite 2 =ort Lauderdale, FL 33301 - fax Attorneys for Defendant, L.M. ack Scarola, Esq. Seamy Denney Scarola Barnhart Sh'pley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Attorneys for Defendant Bradley Edwards 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 F BURMAN, CRITTON, LUT nER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Palm Beach, FL 33401 Fax By: +)Ifte D. Critton, Jr. lorida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) 10 EFTA01112669 VERIFIED RETURPINF SERVICE IIN THE 15Th JUDICIAL CIRCUIT IN AND OR PALM BEACH COUNTY FLORIDA TYPE OF WRIT: AMENDED SpMMONS & COMPLAINT . CASE NO: 502009CA040800XXXXM8 AG •- PLAINTIFF JEFFREY EPSTEIN TO: Scott Rothstein. Register 091258-004 do FCC, Miami 1. Federal Detention Center 33 NE 4^ Street Miami, FL. 33132 DEFENDANT(8) vs. SCOTT ROTHSTEIN, individually et-el., i. it PURSUANT TO THE REQUEST OF: ROBERT O. CRITITON, JR., ESO.,WHOSE OFFICE IS LOCATED AT: 303 BANYAN BLVD.. SUITE 400, WEST PALM MACS. FL. 33401 ',CARLOS AGUIRRE C.P.S 0 810 RECEIVED THIS PROCESS ON: 1219/09 0 8:00am AND SERVED THE SAME ON: 12/9/09 0 8:45am IN BADE COUNTY FLORIDA. ( X ) INDIVIDUAL SERVICE: BY SERVING THE PERSNE NAMED HEREIN A COPY OF THE AMENDED SUMMONS COMPLAINT, PETITION OR INITIAL PL ING. COMMENTS: DESCRIPTION OF PERSON SERVED: WHITE MALE, 47 YEARS OLD. ABOUT 6'7 ABOUT 200Ibs., GREY SHORT HAIR. I ACKNOWLEDGE, THAT I AM A CERTIFIED PROCESS SERVER IN THE CIRCUIT IN WHICH THIS PROCESS WAS SERVED AND THAT I HAVE NO IN REST IN THIS MATTER. UNDER PENALTY OF PERJURY, I DECLARE THAT liREAD THE FOREGOING VERIFIED RETURN OF SERVICE AND THE FACTS STATED IN IT ARE TRUE. CARLOS AGUIRRE C.P.S III 810 )1. -ry .1/6 EXHIBIT IL EFTA01112670 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA REV PPSTEIN Plaintiff, v. t3CtrT Roil 'STEIN, Individually, ; IRADLEY O. EDWARDS, individually, Individually, Defendants. / Complex Litigation, Pa. R. Civ. Pro.1201 CASE NO.502009CA040800XXXXMB AG n/n \(): 16 4CPgo AMENDED SUMMONS (Have not attempted to serve — Amended only as to Place of Service) PERSONAL SERVICE ON A NATURAL PERSON TC DEFENDANT(S): Scott Rothstein, Register #91256.004 c/o FDC, Miami Federal Detention Center 33 NE 41h Street Miami, FL 33132 IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this stir:mons !s 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, !ncluding 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 t!me, 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 attorney 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 & Comptroller P.O. Box 4667 West Palm Beach, 33402-4667 EFTA01112671 vs. Casa 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 :is `Plaintiff/Plaintiffs Attorney named below. 10BERT D. CRITTON, JR. 3URMAN, CRITTON, LUTTIER & COLEMAN 303 Banyan Boulevard Suite 400 West Palm Beach, FL 33401 "HE STATE OF FLORIDA: TC 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 6. 2009 SHARON R. BOCK CLERK OF THE CIRCUIT COURT (SEAL) EQNA SMITH BY: DEPUTY CLERK (See Reverse Side) (Vease al :eves) (Voir de L'autre cote de) -2- EFTA01112672 VS. Case No: IMPORTANTE Usted ha sido demandado legalmente. Tine 20 Dias, contados a partir del recibo de esta notificacior•., para contestar la demanda adjunta, por escrito, y presentada ante este tribunal. Una llamada atelefonica no. lo protegera. Si usted desea que el tribunal cor.s!clere se defensa, dobe 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 immedlatamente. Si no conoce a un abogado, puede llamar a una de las oficinas de asistencia legai que aparecen en la gula telefonica. Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal usted enviar por correo o entegar una copla de su respuesta a la persona deominada abajo como "Plaintiff/Plaintiffs Attorney" (Demandante o Abogado del Demandante). 1MPORANT Dos poursuites judiclares ont ete onterprises contre vous. Vous avez 20 jours consecutifs a partir de la date de l'assignation de cette citation pour deposer une reponse ecrite a la plainte 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 indios nommees ici, si vous souhaitez que le tribunal entende voutre cause. Si vous ne deposez pas votre reponse ecrite dans le reta'. r