EFTA00622924

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. EDWARDS, 
individually, and L.M., 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 
EFTA00622924

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 
EFTA00622925

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 
EFTA00622926

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, L.M. 
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- 
unse 
efendant Jeffrey Epstein 
Law Offices of Marc S. Nurik 
& Counsel to Scott Rothstein 
4 
EFTA00622927

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: 
Ro .ert D. Craton, Jr. 
ci Florida Bar #224162 
Michael J. Pike 
Florida Bar #617296 
(Counsel for Defendant Jeffrey Epstein) 
5 
EFTA00622928

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. EDWARDS, 
Individually, and L.M., 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 
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/RA ehh.4 z ur °vet in Ad 5O:4 ce-- -767- *ton en 
DONE AND ORDERED at Palm Beach County-Co rthouse, 
st P Im Beach, 
Florida, this 
? - 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 
EFTA00622929

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 
SNONDA Kum) merino CIVIL ma 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 
Stay 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. FL 33401 • PHONE: S61.842-2820 •' 
WWW.BCLCLAW.COlvt 
EXHIBIT 
EFTA00622930

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 
EFTA00622931

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 L.M., individually, 
Defendants. 
Case No. BO 2009CA0401300XXXXMB 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 
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%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_ 
EFTA00622932

KIN Nuke 
South Florida Business Journal: Rothstein sentencing moved to June 9 
Page 1 of 1 
Womboa:Ligil i Net asehrimit Rimier rre in ion myna 
Sate, /swim Mira :Weal • ma zt, otto 
theatrullahridairgasmeuseverMeorldstralwitindai 
nt  eltragiteltaktiasulorlsodeameantirdsed_ttrol 
rida 
MIS JOURNAL 
Blog: Scott Rothstein: Picking 
up the Pieces 
Rothstein Sentencing Moved 
To June 9 
thwiesy. An 22.2010. 1.2Sem EDT I Mailed Trmsder. Apra 22, 2010.1:40pm 
A fudge has moved Pond 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 Eirinkrnann 
Reporter 
Runk claims that ROthstein's cooperation with federal authorities by provIdkig evidence for alleged mana 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 CrecuUve 
Protection & liwestkration, a local security film that had ties to the mall., and Roberto Settineri, an alleged Sid:lan maha 
connection In South Panda. Ad three were hit with federal Indictments after Rothstein aregeoly asked them to launder 
money and destroy evidence of Ns Pond scheme. 
This comes after the Rest sealed document was feed in flothsteireS criminal case, which is a Ronal that might mean the reds 
are recommending a lighter sentence because of cooperation. 
Mask nal etreadv admitted to creating a smokescreen of misdirection so that the public end certain alleged criminals would 
think that Rothstein was flaunting federal jurisdiction before he was arrested. 
here's the relevant teat of flunk's request for a later sentencing date: 
- SeedflallY, the defendant Is presently in protective housing outside of thls Strict and treated differently than other inmates. Undersigned 
counsel's contacts with his clad must te arranged and approved in advance through the government, witch creates delay. 
- There have been numerous occasions in the past few months when understined counsel has been unaware of his client's location and has been 
repeatedly out of contact with Ns client for substantial periods of time, Including one period for over two weeks. 
'Given these limitations, in the past five weeks, counsel has only been able to meet with his caent on two occasions. Currently, there is no 
Mary t0 Amall the defendant, and phone contact is very coated. 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 9:30 e.m. 
telegeMESSIIIIServito. Coati ihe fatli#010$ 
POOS.SSABSIONO. IWctlurR.Ro0ma9sir.d 
AO conlenls of this Site ID American CilyButhiess Journals Inc. AU rights reserved. 
http://southflorida.bizjournals.com/southflorida/blog/picking_up_the_pieces/... 5/4/2010 
EFTA00622933

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 
By JAY WEAVER 
tweavernMiamIHerald.com 
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 
EFTA00622934

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 
EFTA00622935

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 
hup://www.miamiherald.com/2010/03/19/v-print/1536775/rothstcin-figure-... 5/11/2010 
EFTA00622936

I-Team: Rothstein Helps Take Down Alleged Mafia Player - cbs4.com 
Page 1 of 3 
the ClitSI bTeam's Most Popular Mvssfgabons 
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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 
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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. 
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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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(3/17.2010) 
lawn Rogssimit returned from lairoCcocelNomMbae 3, he inmeceately began cafferating Sit prosecutor's 
Hunkered don In a bola monk barna of Sorel agents quad:ad ROthsteln Mays about everyone he has wet done business win. One name, Moser, 
ROW; stood out - Roberto Satinet 
01014Crukrie de IOW OfOrnithiltier and Roses `OSIOCIftlele OIS•tanell They 09110100 a Ware away rim Wed Me Mar exeCuirre PielOCIOn a Invesbeacer 
Atoning to et temmoy kr Oromorboosot For Star Old extensive work for Rothstein. prosaic Sassily for Rea:Rase tat end Ns businesses. They were kit 
hired by Rotoion ward yam ago to pro✓de walk for Can Camaro - Ow (nowt Venue µmelon - ellar pothatern bcoghl Da plop.ly. 
John Gala. the special yea la Wage of the Ma Miami NW Circe, saki Seined Is .0010:00 the las have been lament' n for ware. 
'Are operators owe wool Pawn Met Wain In NM whin Oven Nitional Pike provided the (8! web bttomoban *bout Seamed' Gana said 
tlN is ad Mae yen, caw MI had boon unstio a bold any net el aintinal case saint Stirred. Tut Is, tone Ratistain tame Oang. 
Based on 104aC61 amber with the nW ugadrt es wet as alas cootelesed In V. Marano on Nowa. 0, fow dale eRr resmH9 from Saw% Ronieln 
ABS (reeled by federal agents to contact Sated and the cetera. He pretended he need the rum to tap Wen doittoy kakWalakw financial records before redentil 
Spent! mad OM beam. 
He no allagedy asked mem to help move some of ken Pond schwa money to al Omni bsro accouals. 
Rodulank bonnie, was gal pegs noes and toper* wont theses sottnIng M was tenanting wait FBI. 
$0 in Older ID rake the udeseranainweadOn work. ROtherern had lo PORN 
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pereLp v...1). the FBI. 
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EXHIBIT 
• 
 • 
5/11/2010 
EFTA00622937

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. 
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http://cbs4.comAtearn/Scott.Rothstein.Mafia.2.1563707.html 
5/11/2010 
EFTA00622938

1-Team: Rothstein Helps Take Down Alleged Mafia Player - cbs4.com 
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http://cbs4.com/iteam/Scott.Rothstein.Mafia.2.1563707.html 
5/11/2010 
EFTA00622939

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, and L.M., individually, 
Defendants. 
Case No. 50 2009CA040800XXXXMB AG 
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EPSTEIN'S RESPONSE IN OPPOSITION TO 
ROTHSTEIN'S MOTION TO SET ASIDE DEFAULT 
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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. 
EFTA00622940

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 
EFTA00622941

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 
EFTA00622942

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 
EFTA00622943