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Electronically Filed I 0/02/2013 11 :28:04 AM ET 
Spstelnv. RRA.etaf. 
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Vet. wfth EDWA'RDS and RRA as her attorneys,· L:M. did a •1w at her 
SeptemberA 2009 <teposltion in saying. 
A:. .••. Once they were there, toey wete seared out of"fh.e!r mind. 
·-····-- - • 
They did· H ·anyways and same=~of ·them· walked out and said L.M. 
~on't -~r ;do -this :to me ~- That =WU'the·woM ting tbat ever 
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happ8fled to me. (OT 170:8-11) 
... -A: And then, B ·101 of glrla we:ren1t ccmfortable. (DT 171 :13) 
f. 
The sbove. represent only a fevn~f the-dramatic changes ·L.M. made 
~ heJ' te~ony :prior to her 1epresamaUba• by- ~DWARDS/RRA and after she 
hired ROTHSTEtN, EDWARDS antt,RRA. 
48. As a result of the fraudulent Investment er '(Ponzi) s~eme, LM. may :knowingly 
h~ compromised her· a1leged Interests th her CMt Actlon, or oo~mltted a fraud on the 
court. 
4J). RRA snd the Litigation Team bok :an ertlQtionally driven s~t of facts ·1nvolvlng 
~leged Jnnooent, \msospectlng, underage females ahd-a Palm 8each BIDlomilts Bild 
sought to tum It Into a gold mine. Rather Ulan evaluating and re·~Mng the cases ,based 
'Qn- the merits (I.a. facts) which Included knowledgeable, voluntary and consensuat 
actions by each of the claimants and substantial prB-'Epsleln psychological and 
emotlo·na1 C1:>nditions of each df the claimants and substantial se'-Wal experiences pre-
Epstein; RRA and ·the- Litigation Team =sought ·through protective orders aad -objections 
·to block relevant discovery regarding their d13lmants; The.y Instead forged ahead with 
-discovery the main p.urpose of which was to pressure Epstein into settling the cases. 
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Epstein V, AAA, etal. 
P~,28 
Fortu.nate1Y, .their tacUcs have not been successful. 
As Magll.trate Judge Linnea 
Johnson ,wtot.e • In a disctwe,Y order dated· September 15, 2009 {DE 299 :fn Feder-a_l Case 
ffl.:.80=t19}"Jn·denyl~ -Plaintiffs' MQtton f()r Prqtectfv,e Order: 
"This ls his ffepsteln'sl right The Retolti In Dils case ·Is Glear that.the childhood of 
many of ~ 
Plaintiffs was marred by lns1ahcet Of abuse and negl~, which In 
lt!im ma1 have 1'88.uJted, In wbsfe or lri par.t. In the damages claimed by the . 
1P.J~tlffs/. 
lh· ad~Gn, tA-11~ Omn1~ Order &i~ ~ber H, 2009 (OE 377 In Federal 
Case-#08-801t9.)"Magtstrate·Judge Unnea Jolmsonwrot1;J: 
~ere the request EitlSWe goes to the very heart Gf the Plalnttff s damage clalms, 
i'eqµestlng not only gemuaJ ·rntermauon relating ·to Plalntifrs &eXUel history. but 
lnq~rtng as t!) specUJc Instances Wherein 'Ptalnttff reG&lved compensation or 
cqns1d'ere1ion for se~ acts, claim other males sexuallY assaulted, battere.d) or 
lEIWsns heri and/0t'tliilm·othermales committed tewd or lesclvioue acts on her, 
~ a global matter., PtaJntiffs qlearly and unequlvecally .place their sexual history 
In Issue by their aUegatfons that Epster n's actions In this ease· has negativ.ely 
affected thelr- relationships by~ among other things, •distrust In mer:i,• •sexual 
Intimacy proble!'fls, • •diminished trust," "soo!al problems, D 
• problems In personal 
relatlbh~tps,
0 
• feeling of stress around men,· ~premature teenage pregnancy,• 
•aritfsoclal behaviors,• and •hyper-sexuality and promiscuity." Considering these 
allegation, there slmply can be no question that Epstein Is entitted to know 
wh~ther·Plalntiffs wete molested or the subject of other "sexual acuv1ty· or '1ewd 
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Epstein "· RRA. et al. 
Pii~e~ 
and :lascivious .conduct" In oroer to detertrune whether there is an -a1temative 
bast$ fbf :U:l~. psycho_lGQtcal disoroem PlalmHfs claim to hav~ sustained, whether 
'Pl~lotifffJ ~trgs~d In pmstltutton or other slrrlllar type acts .and. ~w ~in• act$ 
aiiegeti:lri th~ Comi,laint mat-erlafly. affected Plaintiffs' relaflomhlps -with-others or 
how -thaee ads dR:tnot ~f.lve such an affect on those retaUonsf\lps:amf/or whe'ffler 
Plaintlffs suffered fr.om .the alJeged emotkmsl and psychologlcel dfsordets • as a 
result of·Of.her- sexual acts prfor to the acts ,alle.ged In· the Complaint. To deny 
'E'psteln U:lus, dls~IY, would be tantalllOunt to oerring· htm, from mo.Jjntlng a 
·defne✓~, 
. 
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50. FtO'THS'tSN, EDWARDS and L.M.'s actions consUwte a fraud upon EPSTEIN 
BS''RAA. RoTHSTI:fN ·and the LIUgatlon Team represented- themselves to be acting In 
:good tatth -and with the·bests Interests of their clients In rnlnd at.an times wtten·in reality, 
they wen, ·,acilrig ln .. furtheranee of the Investment or Ponzi sebeme described hereln. 
EP·STEfN ft1'11ffa1Jiy,· rened to his ·detr:tment on the representations of ,RRA, and 
t;:)efi:,Ad~ts. ROTHSTSN~ Eb.WARDS and L.M. as to how he conducted and. defended 
the CMI-Actlorrs brought ag:alnsthlm. 
51. As a direct and· proximate result of the fraudulent and Illegal Investment or· Ponzi 
-~cheme orchestrated by ROTHSTE\N and as yet other unknown ~nsp\ratoJS and- as 
.,a .. resulf of the lltlgation 1act1cs ·undertaken by the Litigation Tsam and L.M. as set forth 
herein, ,pratntJff·EPSTEIN has,lncurred and continues to Incur the monetary damages 
Including, but not :nmtted to, having to pay an amount In excess of the Civil Actions' true 
va!t.1$ as a result of them t.efusing to settle In that a percentage of any :payment by 
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Epstein "'•·RRA.-et a1. 
i'age30 
EPSTEJf,l ;may nave . been promised ·fo third party investors; lncumng significant 
-:edditionallegat· fees and costs as result of Defendants refusal to condust settlement 
·Fl&gotfatlons in a· forthright and good faith manner be.cause any. rnonfes paid by 
E.P~N ts-tn reality a promls.ed r.etum oa an fnvestme.nt; and in~ired -significant 
attomera• fees :and tosts In ·defendlng the dtscovary thQt ~s not: relevant, ~~lia1-
and/or' caJcoliltsd to lead to the admlsalbllity of evfdem::e, but which We$- done for the 
-sole.pwpQse -of •.pwnprng• lhe cases to lnvsttors. 
~~- ~Te~N has also ·been Injured In that the scope ;of .the fraudut~nt end trim1~1 
·01" raekete.-e.tng .~otli/Jty .. sQ permEJBted the RRA ii~ flm, that EP$TEiN has beeA 
pr.ev~n~ from fuUf .and falr1y defending the ctvn action& broUght- agaln.st hltn. In 
essense, the very exist~nce of RRA was based on the contf~uatio.n uf the massive 
•Ponzi- schema ·orotie.strated by ROTHSTEIN and other co..:consplralom. In orEfet to 
-~tlnueta:bijng-ln monies from Investors, ROTHSTEIN and otherco-consplratocs used 
the-•CMl· Actfons agatnst EPS°TEfN, aJong•wJth other manursetured lawsutts, as a means 
ofobtalnf ng masslve BfY18Unts .of money. 
"53. ROTHSTEIN, EDWARDS and L.M. are llable for •'damages-caused ·to·EPSTE!N -
indlvldually.. :and ·Jo1ntly and sev.erally, 
64. Plaintiff rea0egas and lncorpora~es. paragraphs 1 through 53 a$ If fully set forth 
her.eln. 
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:Epstetn :Y, 'ARA. el--tJL 
'P.Qg_e ~1 
55. AAA, ROTHSTE1N, EDWARDS arid L.M. each and oolfueOv~ly constl1ut& an 
. 
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• eAterpnss pursuant to §772, 102(3), Fla. Stat (200$). 
&8; ROT+IST~N, EDWARDS and -LM. en;ao~d In ~ pattem !)f crlminal actJ-vitf es 
·defilJed &, §772.-102{:!).and (4)4.Ffa. Stat. (2008). 
51. M alleged hareln, ROTH.STEIN and ~OWAROS committed.-multfplEt predicate 
a~ 1n Vlo1atloi'l"bf·§172.103(1), ·(2), (3) and (4)., Fla. Stat., lnchldtng,violatkm& ef Florida 
:StaMes ~ ~pter =517, refaUng to :secur.liles ·ht1$S~r1Sl ~pter" -8:1-7, relatlng• to 
fral:ldulerit ~ratttces, false preternses, .and bud genarally :{whlc=h lndudes l.~.); Chapter 
831, relating to forgery, §836,05, relating to exto1tlon (which {nolud88 l,M.); and Chapter 
-837, relating td perjury (wh1ch lncfudes L.M.), S1Jbstantmlly more than two· 1"dtqate 
'acis ;(f,b~ 1tie ~eUJrtg tit or partJcTpatJoo- of ·ttte ~lf:'••af-fabrloated settJemems 01:.1t1lned 
~ei'ein, irtGtudin-~ the OlvD Acttans lnwlving Epsre1n :as'wen 4U• -flte lmprop·et nttgatlon 
ta8llos outtrn~. above) occurred within a-ftv.e,:.yearllme- perfoU~ 
$6. As a ~I~ end proximate result of ROTHST-EtN; EDWARDS -and LM_.'s 
violetf(?ns of§772.·103, Aa.-Stal, EPSTEIN has been·lnjured. 
59. Purnuant to §772.104(1), Fla. Stal, Plaln6ff·EPSTEIN ts en~tlad to threefoJd of 
his actual damages sustained, reasonable attor:neYs fees .and co.urt oosts-, and such 
other-damages as allowed by law. 
WHEREFORE. Plalntlff EPSTEtN respectfUDy demands the entry of a judgment for 
damages against all the.named Defendants . 
. ~~-,, FJ0&16tt.ffl®"' • 
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-1:psleln v. RRA, et el. 
Page32 
60. Plaintiff reaUeges and Incorporates paragraphs 1 through 63 as .If fulfy et forth 
-heretn. 
Bi. RRA, atong wffll RQTHSTEIN, EDWARDS ~~ LM., each and cafte_dively, 
·constltute-an:eraterpn~ p~rsuaQU0·'§8$5~02.($)v Fta;. :staL (:2009). 
62. During an tll"!les re.leV.ant. hefefo, ROTHS"feJN, 'EDWARDS and LM. weTe· and 
are assocla1ed wlttl the enteFprlse, RRA, and eecll.oiher, 
63. DefendaRb, ROTHSTEIN, EDWARDS -and LM .• as persons ass~ted with the 
enterprise, R-RA and each o.ther (as an anterpdset, unlawfully Cf>nduoted or ptntlcfpated, 
directly or ;lndfrectly, In such- BA enterpnse lllroug_h a -pattem of racketeering, § 
895.03(3). Fl~. Stat; ~ alleged aboV&·herefn. 
64. The ·bre~th- and stope of ROTHSTEIN, EDWARDS and; potelitfally, LM.'s 
racketeering ~ctivlty continues to be Investigated by the FB1, 'Ba iiumerous cMI lawsuits 
·against some of the Defendants and others continua to be flied by pers.ans who have 
• be·en damaged. As of the flilng of thls Complaint. crlmlnlll charges have only been 
brought against ROTHSTE1N~ 
-
. 65; Substahtlauy more than two· predica1a· ·acts (.i.e~, tile selling- ·of fa!:nfcated 
s·ettlements outlined herein, ineludlng· the CMI Actions tnvoMng Epstein as waU as the 
• Improper frtigatfon tactics oufflned above) occurrad·withfn a five year time period. 
66. Pursuant to §895.02, Fla. Stal, ROTHSTEIN and EDWARDS engaged In a 
-pattern of "racketeering acUvi~ through the comrtdss~n of crimes as defined In § 
• -B95.02{1)(a)-(b), Ffa. Stat, 1n·c1uding Chspfer 6i7, relating to securities; Chapter 817, 
relating to ·fraudulent practlcas, false pretenses, end fraud {lnclucllng LM.) generally; 
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l:psteltl v. RRA, ,et al. 
PElge.33 
Chapter 813,.relaflng ,to 1ei;gery; §836.05, relating to .extortlon-Oncludlt-\g LM.); Ch~pter 
~ 
.. ralatJng·m pe;JuryTincludlng LM.). 
67·, Pursuant to ·§895,05, Fla. Stat, Plalntlff seeks the following relief aga\nf3t 
• O~~. F'tQTHSTE1N, -EDWARDS. dnd LM.; 
ll) -Ot.der1ng 00,THsr-Et-N ·and EDWARDS- ,to divest themselves of 
·arw·lnte~ In tbs-enterprise, ~AA;· 
b) Eli]Cln ~11,.Defendants from ,engaging in ·the sam& type l!lf conduGt 
and aotJvfffes as described -hete~n; -ar:id 
<:) Teniperartly· enJcitnlng ROTHSTEIN .. EDWAADS and- L'M., hm 
the continuation of the CMl .Actrons brooght against EPSTEIN . 
untll criminal. charges have been fonnally brought against RAA 
a·ndlor any· of the Defendants, such thal EPS'fEIN may· be 
alfowed to.eva1uate whether a stay or dismissal of:all CMJ 'Actions 
:against ·him Is merited. 
a:s. EPSTEIN fii'j(her -see'ks an award of his reasonable attomey's fees end costs, 
and such otber·re1lefithat:this Courtdeems appropriate. 
WHEREFORE, Platntlff EP:STEJN respectfuUy demands the· entry of a judgment for 
the -relief sought end .damages-against the named Defendants. 
Cpunt 111- Abyse of Pf-ocess,.-
Agafnst AD .Defendants 
(;>9. Plaintiff realleges -and Incorporates paragraphs 1 through 53 as if fulfY set fOfth 
herein. 
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Ep1;telt1 v. RRA. ehll. 
Psge34 
·to. Mer tnstJtutJng: the clvli Actions against EPSTEIN, the acttons of Oefen¢ants1 
RO:fHSTBN, E0W·AROS "BTld LM. as alfeged In paragraphs ·9 throogh 53 herein, 
ooAStitute an:.illegat, Improper or perverted use of process. 
·71. ROTHSTE)N, EOWA.ttt>S .. and LM. possessed ulterior motlves er .~es In 
texeit:lstn;=sueh.-R'lagal,,1lmp~p.er.. or perverted usa:of pro~. 
:rt, Nl a result ·of ROTJ\fSTEtH-,. EDWARDS and LM...'s' atitiom. =EFS1'SN &Uffered·. 
damages~ 
WH~1 Plalhtiff"f!PSTEIN respeetfully '1~RU)nds· fba .entry o.f a Judgment .for 
=dam~$& agatnst alt_'Oie =named· ~Jidants. 
Cuum.lV - Fr.aVd 
Agalnst All befeRdunl§ 
73. Platr:itiff ~aneges and Incorporates paragraphs 1 through ·53 as if-fiJl~Y set forth-
h~.retn. 
74. ROTHSl!ElN,. by and through Defendant -EDWARDS and LM • . med.e fame 
statem~ts offed ID EPSTEffil and his attomeys and ager$, "known·to·-be·tars~ at the 
~rne matle, and/or lntentlonall'y concealed matetla1 lnformatlo!l mm, EPSTEIN. and his 
attomays ·and agents, for the purpose of lnducfng·EPSTEiN to act in reliance 'the,:eon. 
7-S. EPSTEIN did so act on the misrepresentation- and/or concealment by lncurrlng 
add1Uonal attorneys fees, -cos-ts, and expenses in .aggreHiVely defending the .clvD 
actions wl\e~~s In reality, because the Civll Actions aga{nst Plaintiff were being 
e)(p\oited and over•valued ·so as to lure adC,Hlonal investors- and to attempt to extort as 
much money as possible from EPS~IN so as to continue the mas:slve fraud. 

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EP,Steln Y. MA,etal, 
Pago°.a6 
• Wt.-lEREFORE Pratntlff EPSTEIN demands .judgment against Defendants mr 
:dam_ag13f,tnc;:urred and for any ~tber relief-to whlt:h,he:Js entitfed·under-the lav.t. 
·Con=m·«:&;~•rruJ!, 
7G.. Platntfff reallegas and Incorporates paragraphs 1 .throogh- 53, and 74 .and 75 ts If 
'fully -set 'fotth ·heretti. 
77 ~ -ROTHSTEiN,_ EDWARDS end LM. cc,nsp~ ta eom~lt ~ U"dtiti·opo-n EPSTBN, 
78. ROTHSTEIN, EDWARDS and LM. combined by .and ihrough. ooncerted aetton 
$'8. ttutBVed neren, to aGCOmpllsh an unlawful purposo- or aCGOmpUsh s(J.me purpose by 
unl~-meam. The unlawtul purpose was, armng other thing~, ,the t,rd1estreUng aDd 
,continuaUon qf the ma~slve fraOtJulent Ponzi scheme and r:ecefpl -of ~les for the 
--contlriuatton of 1he scheme. The, untawful:means Includes, but le not Hm'lted to, the- use 
-of the ,Civil Actions against EPSTSN In an unlawftJI, l~jnopar, ·and ftaUdulem. manner. 
79. ,As a direct and proximate ;~suit of ROTHSTEIN, EDWARDS and LM."s 
censplrecy to defraud.EPST-EIN, EPSTEIN suffered,damages. 
WHEREFORE Plalntiff ~?STEIN demands ~ment against Defendants for 
damaEJes lncuf.l'ed and for any other relief to which he ls,entitled unde:r the 1aw. 
Jury.Trta1. 
Plalrrtlff d~mands Jury Trial Qn all Issues so triable. 
By. 
. 
ROBE~ 
.. CRlTrOt( JR., :e$~l~ 
Florida'.·' ·,No. 2241"62 
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~tetn v. AAA.el&L 
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-lCdt@~com-
MJCHAEL JI :p·1~ ESQ. 
flo~ BaM#61'7296 
m~aw:wm 
S~1,CR1 I _I ON~ LUTTIER &-COLEMAN 
303 ,Banvan.B~-~ $ul.ie·400 
West:Palm-Beaeh~ FL.33481 
tm1-842-2Mn 
Fax: Btn-258-0154 
(Attomeyslor Pialr1tlff) • 

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UNITED STA TES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 09-60331-CR-COHN 
UNITED STA TES OF AMERlCA, 
Plaintiff, 
v. 
SCOTT W. ROTHSTEIN, 
Defendant 
___________ ./ 
eLEA AGREEMENT 
The United States of America and SCOTT W. ROTHSTEIN (hereinafter referred to as "the 
defendant") enter into the following agreement: 
l. 
The defendant agrees to plead guilty to the five count Infonnation, which charges the 
defendant in Count 1 with a Racketeering Conspiracy, in violation of Title 18, United States Code, 
Section 1962( d); in Count 2 with Conspiracy to Commit Money Laundering, in violation of Title 18, 
United States Code, Section l 956(h); in Count 3 with Conspiracy to Commit Mail Fraud and Wire 
Fraud, in violation of Title 18, United States Code, Section 1349; and in Counts 4 and 5 with Wire 
Fraud, in violation of Title 18, United States Code, Section 1343. 
2. 
The defendant is aware that the sentence will be imposed by the Court after 
considering the Federal Sentencing Ouidelines and Policy Statements (hereinafter ''the Sentencing 
Ouidelines") in an advisory capacity. The defendant acknowledges and understands that the Court 
will compute an advisory sentence wider the Sentencing Ouidelines and that the applicable advisory 
guidelines will be determined by the Court relying in part on the results of a Pre-Sentence 
Investigation by the Court's probation office, which investigation will commence after the guilty plea 
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has been entered. The defendant is also aware that, under certain circumstances, the Court may 
depart from the applicable advisory guideline range and impose a sentence that is either more severe 
or less severe than the advisory guidelines range. The Court is pennitted to tailor the ultimate 
sentence in light of other statutory concerns. Knowing these facts, the defendant understands and 
acknowledges that the Court has the authority to impose any sentence within and up to the statutory 
maximum authorized by law for the offenses identified in paragraph I and that the defendant may 
nm withdraw the plea solely as a result of the sentence imposed. 
3. 
The defendant also understands and acknowledges that the Court may impose a 
statutory maximwn tenn of imprisonment ofup to twenty years for each of the offenses set forth in 
ColUlts I through 5, for a total ofup to one hundred years, followed by a tenn ofup to three years 
of supervised release for each offense. In addition to a tenn ofimprisonment and supervised release, 
the Court may impose a fine of up to $250,000.00 with respect to the offenses set forth in Counts 
I, 3, 4, and S, and may impose a fine with respect to the offense set forth in Count 2 of the greater 
ofSS00,000.00 or twice the value of the property involved in the money laundering transactions. 
4. 
The defendant further understands and acknowledges that, in addition to any sentence 
imposed under paragraph 3 of this agreement, a special assessment in the amount ofSI00.00 with 
respect to each of the offenses set forth in counts I through S, for a total of $500.00, will be imposed 
on the defendant, which will be paid by the defendant at the time of entry of this plea. 
5. 
The defendant further understands and acknowledges that, in addition to any sentence 
imposed under paragraphs 3 and 4 of this agreement, that restitution may be imposed as part of that 
sentence. The defendant agrees that for purposes of triggering the...

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guilty under this agreement in this case are "offenses against property" and were "committed by 
fraud and deceit," as those terms are understood within Title 18, United States Code. Section 
3663A( c )(1 )(A)(ii). The defendant accordingly understands and acknowledges that as a result ofhis 
plea of guilty pursuant to the tenns of the plea agreement in this case the Court may order that he pay 
restitution pursuant to the provisions of Title 18, United States Code, Sections 3663A and 3664. 
Promptly following the entry of his guilty plea. the defendant agrees to take all necessary steps to 
make the following property available, as partial satisfaction of any restitution order entered in this 
case: (a) all property subject to the post-Information Protective Order in this matter; and (b) all 
property identified in the Bill of Particulars for Forfeiture. 
6. 
The defendant further understands and acknowledges that, in addition to any sentence 
imposed under paragraphs 3, 4 and S of this agreement, forfeiture may be imposed as part of that 
sentence. The defendant agrees to the forfeiture of all of his right, title and interest to all assets listed 
in the Information and listed in the Bill of Particulars, and/or their substitutes (hereinafter "the 
assets"), whether controlled individually or through defendant's wholly owned or partially owned 
corporations or third-parties, which are subject to forfeiture pursuant to Title 18, United States Code, 
Sections 1963, 982(a)(l) and/or 98l(a)(l)(C). The defendant agrees to assist the United States in 
achieving forfeiture of the assets and agrees to assist the United States with forfeiture of same, such 
assistance to include truthful testimony, especially to the extent that the assets are in the names of 
corporations or other entities or individuals. The defendant knowingly and voluntarily waives any 
right to a jury trial or any other adversarial proceeding regarding the assets and waives any 
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whether administrative or judicial. The defendant also waives any defenses to the forfeiture, 
including any claim of excessive fine or penalty under the Eighth Amendment. The defendant also 
agrees to waive any appeal of the forfeitme. The defendant further acknowledges that the property 
forfeited cannot, either in whole or in part, be used to satisfy any obligation the defendant may have 
for any federal, state or local taxes, interest and/or other penalties which may now exist or which 
may come into existence. 
7. 
The Office of the United States Attorney for the Southern District of Florida 
(hereinafter ''this Office") reserves the right to inform the Court and the probation office of all facts 
pertinent to the sentencing process, including all relevant information concerning the offenses 
committed, whether charged or not, as well as concerning the defendant and the defendant's 
background. Subject only to the express tenns of any agreed-upon sentencing recommendations 
contained in this agreement, this Office further reserves the right to make any recommendation as 
to the quality and quantity of punishment. 
8. 
The United States agrees that it will recommend at sentencing that the Court reduce 
by three levels the advisory sentencing guideline level applicable to the defendant's offense, pursuant 
to Section 3El.l of the Sentencing Guidelines, based upon the defendant's recognition and 
affinnative and timely acceptance of personal responsibility. However, the United States will not 
be required to make this sentencing recommendation if the defendant: ( 1) fails or refuses to make 
full, accurate and complete disclosure to the probation office of the circumstances surrounding the 
relevant offense conduct; (2) is found to have misrepresented facts to the government prior to 
entering this plea agreement; or (J) commits any misconduct after entering into this plea agreement, 
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including but not limited to committing a state or federal offense or makirtg, false; s_ta~ments or 
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misrepresentations to any governmental entity or.official. 
9. 
The defendant is aware that the sentence has not yet been detennined by t4e_ Court. 
The defendant also is aware that any estimate ofthe,probable.sentencing range or sentence that.the • 
defendant may receive, whether that estima~e comes from the defendant's attorney, the government. 
or the probation office, is· a prediction, not a pf9mise, and is not binding on the government, the 
probation office or the Court. The defendant understands· further .that any recommendation that the 
government makes to the Court as to sentencing, whe:ther pursuant to this agreement or otherwise, 
is not binding 011 the Court and the Court may disregard the recommendation in its entirety. The 
defendant understands and acknowledges, as previously acknowledged in paragraph. 2 above, that 
the defendant may mt withdraw his plea based upon the Court's decision not to acc~pi a sentencing 
·recommendation made by the defendant, the government. or a recommendation made jointly by 
both the defendant and the government. 
10. 
In the event that the applicable offense level is deemed•by the Court to be 43 _or above 
(life); the government agrees to not oppose a variance; however, the Government reserves the right 
to oppose any sentence recommended by the defendant, 
J 1. 
This agreement resolves the defendarit'.s federal criminal liability in the So\ithem 
District of Florida growing out of any criminatconduct by the defendant known to~ United States 
Attorney's Office for ~e Southern District of Florida as of the date ofthi~ plea ~greement.' ;Said 
provision does notprohibit potential prosecution for any acts of violence presently unknown to the 
United States. 
5 
'•' 
. ·,. i~;.-

NOT A CERTIFIED COPY
I ~~" : • • :.:~~ ,\~; ~--
._,_:-
•~.~~ /~~>> }:~~ 
12. 
The United States agrees that it WJll not oppose defendimt~s requ~uhat'the'Court 
recommend to the Bureau of Prisons that the defendant be designated to the lowest'security level 
faciJity:dcemed appropriate by the Bureau of Prisons. 
13. 
The defendant is aware that Title 18, United States Code, Section 3742 affoids'the 
defendant the right to appeal the sentence imposed in this case. Acknowledging this, and in 
exchange· for the undertakings made by the United· States in this plea agreement, the def~ndant 
. 
. 
. 
hereby waives all rights conferred by Section 3742 to appeal any sentence imposed, including any 
restitution order, or to appeal _the-manner in which the sentence was imposed, unle5$ the sentence 
. 
. . 
exceeds the maximum pennitted by statute or is the result of an upward 'departure and/or a variance 
from-the guideline range that the court establishes at sentencing. The defendant further understands . 
that nothing in this &grmllent shall affect the government> s right and/or duty to appeal as set forth 
• in Title 18, United States Code, Section 3742(b). However, if the United ·states appeals the 
defendant's sentence pursuant to Section 3742(b), the defendant shall be released from the above 
. 
. 
waiver of appellate rights. By signing this agreement, the defendant acknowledges that h~ has 
discussed the appeal waiver set-forth in this agreement with his attorney. The defendant further 
agrees, together with the United States, to request that the district court enter a specific finding that· 
the defendant's waiver of-his right to appeal the sentence to be imposed in this case .was knoy.ring 
and voluntary. 
. 
. 
J 4. 
The defendant further waives any right to file any motion or make any claim, whether 
under 28 U.S.C. §§2255, 2254, 2241, 'Or any other provision of law, to collaterally attack his 
conviction, his se_ntence, or the manner in which sentence was imposed,...

NOT A CERTIFIED COPY
IS. 
The defendant confirms that he is guilty of the offenses to which he is pleading guilty; 
that his decision to plead guilty is the decision that he has made; and that nobody has forced, 
threatened, or coerced him into pleading guilty. The defendant affmns that he has discussed the 
matter of pleading guilty in the above-referenced cases thoroughly with his attorney. The defendant 
further affinns that his discussions with his attorney have included discussion of possible defenses 
that he may raise if the case were to go to trial, as well as possible issues and arguments that he may 
raise at sentencing. The defendant additionally affinns that he is satisfied with the representation 
provided by his attorney. The defendant accordingly affirms that he is entering into this agreement 
knowingly, voluntarily, and intelligently, and with the benefit of full, complete, and effective 
assistance by his attorney. The defendant accordingly agrees that by entering into this agreement he 
7 

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waives any right tofileanymotionor make any claim, whetherwider28 U.S.C.§§2255, 2254, 2241, 
or any other provision of law, that contests the effectiveness of counsel's representation up to the 
time of the entry of his guilty plea. 
16. 
This is the entire agreement and widerstanding between the United States and the 
defendant. There are no other agreements, promises, representations, or understandings, unless 
contained in a letter from the United States Attorney's Office executed by all parties and counsel 
prior to the change of plea. 
Date:~/tJ 
Dale,#/10 
Dale,$1,v 
JEFFREY H. SLOMAN 
UNITED STATES ATTORNEY 
L(_ .;;..~ 
PAULF. SCHWARTZ 
ASSIST ANT UNITED STATES A 1TORNEY 
ASSISTANT UNITED STA TES ATTORNEY 
CCHIO 
D STA TES ATTORNEY 
TI W. ROTHSTEIN 
DEFENDANT 
8 

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STATEMENT OF FACTS 
The United States of America and SCOTI W. ROTHSTEIN enter into the following 
stipulated statement of facts in support of the defendant's plea of guilty: 
Had this case proceeded to trial, the government would have presented evidence which would 
have established beyond a reasonable doubt that ftom in or about 2005, through in or about 
November 2009, Defendant ROTHSTEIN conspired with persons known and unknown to the United 
States Attorney, to use the law firm, Rothstein, Rosenfeldt and Adler P.A. (hereinafter referred to 
as "RRA j as a criminal Enterprise in order to conduct a pattern of racketeering activity. Such 
pattern of racketeering activity included criminal acts which violated mail fraud, wire fraud, money 
laundering and conspiracy statutes. 
The government would have presented evidence at trial which would have involved witness 
testimony and documentary and electronic evidence seized pursuant to a search warrant. The 
government's trial evidence would have established the following: 
Defendant ROTHSTEIN was an attorney admitted to practice Jaw in Florida. He was the 
Chief Executive Officer and Chainnan of RRA. In or about 2005, Defendant ROTHSTEIN and 
other co-conspirators initiated a scheme to generate criminal pl'OQnds through fraudulent acts. 
Defendant ROTHSTEIN induced investors through the use of false statements to loan money to 
himself and fictitious borrowers in return for promissory notes. He solicited bridge loans on behalf 
ofpwported clientsofRRA, that is, he would falsely infonn individuals that clients ofRRA desired 
to borrow funds for undisclosed business deals and in return would agree to pay high rates of 
interest. Defendant ROTHSTEIN was aware that no such clients or requests for business fmancing 
actually existed. 
Defendant ROTHSTEIN and co.conspirators also solicited investors to pw-chase purported 
1 

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confidential settlement agreements, Such settlement agreements were falsely presented as having 
been reached between putative defendants based upon claims of sexual harassment and/or whistle-
blower actions. The investors were falsely informed that such settlement agreements were pre-
litigation and therefore there was no pending litigation or court oversight. Defendant ROTHSTEIN 
and other co-conspirators relied upon the purported success of RRA, the existence of actual RRA 
civil matters and his standing in the community to lure potential investors in order to convince them 
to make such investments. The investors were falsely informed that the confidential settlement 
agreements were available for purchase. The purported settlements were allegedly available in 
amounts ranging from hundreds of thousands of dollars to millions of dollars and could be purchased 
at a discount and repaid to the investors at face value over time. For instance, in or about late 2009, 
a potential investor was solicited by Defendant ROTiiSTEIN and/or ~onspirators to purchase a 
purported settlement in the amount of $450,000. The settlement was alleged to be paid to the 
purported plaintiff' in three installments of SJ 50,000 each, over the course of three months. The 
payment schedule was alleged to insure the confidentiality of the settlement. The purported plaintiff 
allegedly had agreed to accept an immediate payment of$37S,OOO in satisfaction of the settlement 
agreement. In order to facilitate the scheme, the investor ~eived a fraudulent settlement agreement 
which set forth the terms of the civil settlement, but the names of the purported plaintiff and 
defendant were excised due to the alleged confidentiality of the settlement. 
The government would further establish that in order to facilitate and perpetrate the scheme, 
Defendant ROTHSTEIN and co-conspirators created false and fraudulent settlement agreements, 
bank statements, assignments of settlement a...

NOT A CERTIFIED COPY
Defendant ROTHSTEIN and other co-conspirators falsely infonncd investors that the 
purported confidential settlements were either negotiated on behalf of clients of RRA or had been 
referred by other law finns. The investors were falsely informed that the purported settlements were 
• based upon sexual harassment and/or whistle-blower (qui-tam) actions against corporate defendants. 
• Defendant ROTIISTEIN and othcrco~nspirators established and maintained trustuccounts 
at several financial institutions in order to receive the investor funds and to give the appearance of 
legitimacy and security. False and fictitious trust account bank balance $tements were created 
along with purported "lock letters." Such letters allegedly reflected that the funds in the trust 
accounts would be disbursed only to specific investors. Instead funds were disbursed among and 
between the various trust accounts and elsewhere by interstate wire transfers and other means in 
order to facilitate, promote and conceal the fraud, to launder the proceeds derived therefrom, and to 
enrich ROTHSTEIN and his co-conspirators. . ROTHSTEIN and his co-conspirators created 
fraudulent on-line banking documents to further mislead investors and to facilitate the fraud. 
Defendant ROTIISTEIN and co-conspirators also initiated and conducted a separate scheme 
to defraud clients ofRRA in order to perpetuate the "Ponzi" scheme. Such clients had retained RRA 
to institute and file a civil lawsuit. Unknown to the clients, RRA settled the lawsuit and had 
obligated the clients to pay $500,000 to the defendant. In order to perpetrate the fraud and deceive 
the clients, defendant ROTHSTEIN created a false and fraudulent court order purportedly signed by 
a Federal District Court Judge which falsely alleged that the clients of RRA had prevailed in the 
lawsuit and were owed a judgement of approximately $23 million. The fraudulent court order also 
falsely stated that the defendant had transfe...

NOT A CERTIFIED COPY
Defendant ROlllSTEIN and other co-conspirators falsely advised the clients on several 
occasions that in order to recover the defendant's funds, they had to post bonds to be held in the 
RRA trust account Defendant ROTHSTEIN and other co-conspirators fraudulently caused the 
clients to wire transfer a total of approximately $57 million over several years to a trust accowit 
controlled by defendant ROTHSTEIN, purportedly to satisfy the bonds. Defendant ROTHSTEIN 
and other co-conspirators were questioned by the clients as to the progress of the alleged lawsuit. 
In order to delay the return of funds to the clients, defendant ROTHSTEIN fraudulently created a 
false Federal coun order purportedly issued by a United States Magistrate Judge ordering RRA to 
return the transmitted funds by a later date. 
Defendant ROTHSTEIN and other co-conspirators utilized funds obtained through the 
"Ponzi" scheme to supplement and support the operation and activities of RRA, to expand RRA by 
the hiring of additional attorneys and support staff, to fund salaries and bonuses, and to acquire larger 
and more elaborate office space and equipment in order to promote the ongoing scheme and to enrich 
the personal wealth of persons employed by and associated with RRA. 
Defendant ROTHSTEIN and other co-conspirators engaged in the below described conduct 
in order to facilitate the activities of the Enterprise and to conceal and promote the scheme to defraud 
investors. 
Defendant ROTHSTEIN and other co-conspirators utilized funds illegally obtained through 
the "Ponzi" scheme to make political contributions to local, state and federal political candidates, 
in a manner designed to conceal the true source of such funds and to circumvent state and federal 
laws governing the limitations and contribution of such funds. 
4 

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Defendant ROTHSTEIN and other co-conspirators distributed lavish gifts, including exotic 
cars, jewelry, boats, loans, cash and bonuses, to individuals and to membets of RRA in order to 
engender goodwill and loyalty and to create the appearance of a successful Jaw firm. 
Defendant ROTHSTEIN and other co-conspirators made large charitable contributions to 
public and private charitable institutions, including hospitals and other legitimate charitable and 
nonprofit organizations, using funds derived from the "Ponzi" scheme. "Ponzi" scheme funds were 
also used to provide gratuities to high-ranking members of police agencies in order to curry favor 
with such police personnel and to deflect law enforcement scrutiny of RRA. 
Defendant ROTHSTEIN and other co-conspirators utilized funds obtained through the 
"Ponzi" scheme in order to purchase controlling interests in restaurants located in the Southern 
District of Florida. Such restaurants were used in part as a mechanism to give gratuities to 
individuals, including politicians, business associates and attorneys, in order to foster goodwill and 
loyalty. as locations to solicit potential investors and as secure locations for conspiratorial meetings. 
Defendant ROTHSTEIN and other co-conspirators associated with well known politicians, 
in public forums and elsewhere, in order to gain greater notoriety and to create the appearance of 
wealth and legitimacy. Such acts were calculated in part to enhance defendant ROTHSTEIN and 
other co-conspirators' ability to solicit potential investors in the "Ponzi" scheme. 
Defendant ROTHSTEIN and other co-conspirators used funds derived from the "Ponzi" 
scheme to maintain the appearance of affluence and wealth, by purchasing expensive real and 
personal property, in order to convince potential investors of the legitimacy of RRA and of the 
purported investment opportunities. Defendant ROTHSTEIN purchased expensive real property. 
personal property, business i...

NOT A CERTIFIED COPY
The government's evidence would establish that Defendant ROTHSTEIN and co• 
conspirators, through the use of RRA as the criminal Enterprise, knowingly and intentionally 
engaged in the above-described pattern of racketeering activity in order to generate proceeds for their 
enrichment through various criminal activities, including mail fraud, wire fraud and money 
laundering, The government's evidence would establish that the activities of the Enterprise affected 
interstate commen::e through the transmission of funds among and between financial institutions and 
across state boundaries, among other means. 
The Enterprise maintained offices in Broward County, Florida, and elsewhere and the pattern 
of racketeering activity emanated from the Southern District of Florida. Investors were solicited 
through wire and mail transmissions through the United States and elsewhere. In order to further 
the fraud scheme, Defendant ROTIISTEIN and other co-conspirators caused to be transmitted wire 
communications, in interstate and foreign commerce, including an interstate wire transfer sent from 
TD Bank to Gibraltar Bank on or about December 2, 2008 and an interstate wire transfer sent to TD 
Bank from JP Morgan Chase on or about October 16, 2009. The proceeds derived from the "Ponzi" 
scheme were laundered through the accounts maintained at several financial institutions in order to 
promote, carry on and conceal the criminal activities of RR.A. 
Had the forfeiture portion of the case proceeded to trial, the government would have 
established, at least by a preponderance of the evidence, the standard of proof required for 
sentencing, that the properties listed for forfeiture in the forfeiture allegations of the Jnfonnation and 
in the Bill of Particulars for Forfeiture, were properly sought for forfeiture because the defendant 
acquired or maintained an interest therein or were derived from proceeds obtained directly and 
indirectly through the commissio...

NOT A CERTIFIED COPY
money laundering activity described above, and that such properties were aJso the proceeds of, or 
were derived from, the mail and wire ftaud activity described above. 
The undersigned hereby stipulate and agree that the aforesaid facts are true and correct and 
that they encompass all of the necessary elements to establish the guilt of the defendant to the 
charges of Conspiracy to Violate the RICO Act, in violation of Title 18, United States Code, Section 
1962(d); Conspiracy to Commit Money Laundering, in violation of Title 18, United States Code, 
Section I 956(h); Conspiracy to Commit Mail Fraud and Wire Fraud, in violation of Title 18, United 
States Code, Section 1349; and Wire Fraud, in violation of Title 18, United States Code, Section 
1343. 
Da1e:/21;f) 
0a1e, 1/ d/ro 
JEFFREY H. SLOMAN 
UNITEDSTATESAITORNEY 
/2~ cld£4 
PAUL F. SCHWARTZ 
SIST ANT UNITED STA TES A TrORNEY 
W. ROTHSTEIN 
DEFENDANT 
7 
A TES A TIORNEY 
ATTORNEY 

NOT A CERTIFIED COPY
INRE: 
UNITED STATES BANKRUPTCY COURT 
SOUTHERN DISTRICT OF FLORIDA 
FORT LAUDERDALE DIVISION 
www.flsb.uscowts.gov 
ROTHSTEIN ROSENFELDT ADLER, P.A., 
Debtor. 
CASE NO.: 09-34791-RBR 
CHAPTER 11 
-------------' 
PRIVILEGE LOG 
FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & 
LEHRMAN 
Dated: February 23, 2011 
Total of I 59 pages 
EXHIBITQ 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
Farmer. Jaffe. Weissing. Edwards. Flstos& Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
08076-08089 08/04/2009 
Bradley Edwards 
Spencer Kuvin 
Transcript of Alfredo Rodriguez 
Joint W/P Priv. 
Deposition 
08311-08318 
05/26/2009 
Bradley Edwards 
!Catherine Ezell 
WPS-Confidential-General-
Joint W /P Priv. 
Fina ncia I Disclosure/Discovery 
08319-08324 
10/16/2009 
Bradley Edwards 
AmyEderi 
WPS-General-Confidential 
Joint W/P Priv. 
08398 
09/01/2009 
Bradley Edwards 
Kikka Claudio 
C.M.A. 
vs. 
Epstein, 
et Joint W/P Priv. 
al.(File#:281849) 
08402 
09/17/2009 
Bradley Edwards 
Paul Cassell 
Report this as a parole violation 
Joint W/P Priv. 
08415 
09/16/2009 
Bradley Edwards 
Margaret Berk 
Scanned 
document 
from Joint W /P Priv. 
Margaret Berk 
08422 
08/11/2009 
Bradley Edwards 
Katherine Ezell 
Subpoena 
directed 
to 
the 
Joint W/P Priv. 
investigators 
10060 
08/03/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein-Depa-New York 
Joint W/P Priv. 
.10069-10074 08/04/2009 
Bradley Edwards 
Spencer Kuvfn 
RE:Transcript 
of 
Alfredo Joint W/P Priv. 
Rodriguez Deposition 
10077-10079 08/06/2009 
Bradley Edwards 
Mercedes Estrada 
RE:Epstein vs. Jane Doe No.101 Joint W/P Priv. 
& Epstein vs. Jane doe No. 102 
10099-10102 
08/27/2009 
Bradley Edwards 
Spencer Kuvin 
RE: Epstein Oepo 
Joint W/P Priv. 
10192 
08/11/2009 
Adam Horowitz 
Jacquie Johnson 
Trump Depo moved 08/18 to Joint W/P Priv. 
9/24in NY 
10194-10195 08/11/2009 
Jacquie Johnson 
Kikka Oaudio 
FW: Out of state subpoenas 
Joint W/P Priv. 
10264-10266 08/09/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein-Letter 
regarding 
Joint W/P Priv. 
Leslie Wexner 
1 

NOT A CERTIFIED COPY
privilege.Log'.'"" Dated 2·23'."2011 
_ 
-
I 
I 
I. 
I 
-
farmer Jaffe· W~issfn1r' Edwafct~ '°Ff st.is & Lehrman· 
BATES 
DATE 
TO 
FROM. 
':DESCRIPTION 
, 
OBJECTION 
- . 
'. 
10279-10291 08/10/2009 
Adam Horowitz 
Jacquie Johnson 
RE: EpsteiiFNo~ce of production Joint VJ/P Priv. 
C 
from non: parties/depo of Jane 
Doe. 
~-
' 
.. 
-
10372-10373 09/17/2009 
Bradley Edwards 
Katherine Ezell 
RE: Leslie Wexner 
Joint W/P Priv. 
.10490-10493 09/21/2009 
Bradley Edwards • Amy Ederi , -' 
FW: Eps~ein Oepo 
Joint W/P Priv. 
. 10592-10593 09/29/2009 
Bradley Edwards 
Katherine Ezell 
RE: Leslie Wexner 
Joint W/P Priv. 
10.604-10620 10/01/2009 .. 
Bradley Edwards 
• Katherine Ezell 
FW:meeting w/ atty fr wexner 
Joint W/P Priv. 
• .. 
.. 
10639-10643 10/06/2009 
Bradley Edwards 
Stuart Mermelstein 
Meeting w/Leslie Wexner 
Joint W/P Priv. 
10700-10702 10/13/2009 
Adam Horowitz 
Jacquie Johnson 
Depo 
Joint W/P Priv. 
10724-1073 
10/14/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein·depo of Alan Dershowitz 
Joint W/P Priv. 
.. 
·-
10897 
10/29/2009 
Bradley Edwards 
Stuart Mermelstein 
Leslie Wexner 
Joint W/P Priv. 
10992-11005 06/22/2009 
Bradley Edwatds 
Amy Ederi 
RE:Regular Monthly Cong. Call 
Joint W/P Priv. 
11011°11021 06/23/2009 
,radley Edwards 
Katherine Ezell 
RE:Regular Monthly Cong. Call 
Joint W/P Priv. 
11026-11032 07/09/2009 
Bradley Edwards 
Spencer l<uvin 
RE:Epstein 
commissioner Joint W/P Priv. 
appointees 
. 11072-11074 07/28/2009 
Bradley Edwards 
Katherine Ezell 
Pe>ssible 
witness 
from 
Joint W/P Priv . 
Switzerland 
11166-11169 06/23/2009 
Katherine Ezell 
Bradley Edwards 
RE:Article:Bear Stearns 
Joint W /P Priv. 
2 
;,·.:., 
'-
'·, .... 
~~: --~'. .. -> • .. 
.... ~· .. _~,·, °((, 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
Farmer Jaffe Weissina. Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
11240-11245 06/22/2009 
Katherine Ezell 
Bradley Edwards 
Article:Bear Stearns 
Joint W/P Priv. 
11248-11250 06/22/2009 
Amy Ederi 
Bradley Edwards 
Article:Bear Steams 
Joint W/P Priv. 
11255-11259 
06/23/2009 
Katherine Ezell 
Bradley Edwards 
USAO Chose Bradley Edwards 
Joint W/P Priv. 
conversation 
11269-11281 06/30/2009 
Stuart 
Bradley Edwards 
RE:Epstein 
Depo;possible 
Joint W/P Priv. 
Mermelstein 
deponents 
11316-11319 06/28/2009 
Katherine Ezell 
Bradley Edwards 
Discussion 
about 
possible 
Joint W/P Priv. 
witness from Switzerland 
11332-11336 08/04/2009 
Spencer Kuvin 
Bradley Edwards 
FW:Transcrlpt 
of 
Alfrefo 
Joint W/P Priv. 
Rodriguez Oepo and Copperfeild 
and Clinton's whereabouts 
11340-11341 08/05/2009 
Mercedes 
Bradley Edwards 
RE:Epstein vsJane Doe No.101 & 
Joint W/P Priv. 
Estrada 
102 
11348-11358 
08/06/2009 
Adam Horowitz 
Bradley Edwards 
RE:Motion 
for 
protective Joint W/P Priv. 
order/discussion 
11430-11434 08/27/2009 
Spencer Kuvin 
Bradley Edwards 
Discussion 
RE:Wexner 
Joint W/P Priv. 
involvement 
11443 
09/17/2009 
Katherine Ezell 
Bradley Edwards 
Wexner served subpoena OH 
Joint W/P Priv. 
11541-11542 09/29/2009 
Katherine Ezell 
Bradley Edwards 
RE:Leslie Wexner & Bob 
Joint W/P Priv. 
11551-11559 
10/01/2009 
Spencer Kuvin 
Bradley Edwards 
RE:Meeting w.Stanely Arkin 
Joint W/P Priv. 
11585-11586 
10/14/2009 
Adam Horowitz 
Bradley Edwards 
RE:Epstein;Larry 
Visoski 
Joint W/P Priv. 
confirmed 
11675-11676 10/29/2009 
Stuart 
Bradley Edwards 
RE:leslie Wexner attorney info 
Joint W/P Priv. 
Mermelstein 
3 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Welssin2 Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
15981-15988 08/04/2009 
Spencer Kuvin 
Jacquie Johnson 
Attachment:Kellen 
& 
Trump Joint W/P Priv. 
subpoena 
15999-16007 
08/05/2009 
Bert Patton 
Jacquie Johnson 
RE:Epstein Depo-New York 
Joint W/P Priv. 
16057-16065 
08/06/2009 
Mercedes 
Jacquie Johnson 
Trump and Maxwell Dep dates 
Joint W /P Priv. 
Estrada 
15918-15949 
08/04/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein Depo's 08/14,17,18 in Joint W/P Priv. 
NY&OH 
16066-16069 
08/06/2009 
Adam Horowitz 
Jacquie Johnson 
Maxwell,Trump, Wexner convo Joint W/P Priv. 
RE:Depo dates 
16095-16098 
08/11/2009 
Adam Horowitz 
Jacquie Johnson 
Maxwell, Trumo, Wexner 
Convo Joint W/P Priv. 
RE:Oepo dates cont .. 
15813-15814 
10/29/2009 
Stuart 
Bradley Edwards 
Wexler Lawyer's info 
Joint W/P Priv. 
Mermelstein 
15856 
08/03/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein Pepo-NY;2 Attachments 
Joint W/P Priv. 
15866-15881 
08/03/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein Oepos 08/14,17 ,18 in Joint W/P Priv. 
NY&OH/PDF of Sarah 
Kellen 
Notice of Videotaped Depo 
15893-15901 
08/03/2009 
Kikka Claudio 
Jacquie Johnson 
Oepo &subpoena 
notice 
for Joint W/P Priv. 
Trump 
15360-15363 
09/01/2009 
Jacquie Johnson 
Mercedes Estrada 
RE:Alan Dershowitz;Harvard Law Joint W/P Priv. 
Info 
15394-15397 09/09/2009 
Jacquie Johnson 
Katherine Ezell 
RE:Epstein-Depos of Marcinkova 
Joint W/P Priv. 
& Sarah Kellen 
15413-15428 
09/10/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Esptein-Notice of Prodcutlon Joint W/P Priv. 
from Non Parties 
15434-15437 
09/10/2009 
Jacquie Johnson 
Katherine Ezell 
Notice Of Productk>n from Non-
Joint W/P Priv. 
Parties discussion 
4 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
Farmer Jaffe Weissin2. Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
0BJEOION 
15454-15475 
09/15/2009 
Adam Horowitz 
Jacquie Johnson 
Critton's notice of depo;Epstein Joint W/P Priv. 
notice of hearing,Mart Epstein 
notice of depo 
01465 
07/13/2009 
Katherine Ezell 
Bradley Edwards 
Epstein 
Joint W/P Priv. 
15485-15492 
09/17/2009 
Jacquie Johnson 
Mercedes Estrada 
RE:Epstein Depo 
Joint W/P Priv. 
15493-15500 09/18/2009 
Jacquie Johnson 
Katherine Ezell 
RE:Deposition 
of 
Jean 
Luc 
Joint W/P Priv. 
Bruhnel 
15501-15555 09/18/2009 
Jacquie Johnson 
Adam Horowitz 
RE:Epstein Depo 
Joint W/P Priv. 
15556-15564 09/22/2009 
Jacquie Johnson 
Margaret Berk 
Epstein Depos 
Joint W/P Priv. 
15565-15S75 
09/25/2009 
Jacquie Johnson 
Lisa Rivera 
FW:Deposition 
of 
Jean 
Luc 
Joint W/P Priv. 
Bruhnel 
15687-1S688 
10/01/2009 
Jacquie Johnson 
Lisa Rivera 
Depo ~f David Hart Rogers 
Joint W/P Priv. 
15692-15707 
10/01/2009 
Jacquie Johnson 
Katherine Ezell 
FW:Meeting w/Sranley Arkin 
Joint W/P Priv. 
15708-15709 
10/06/2009 
Jacquie Johnson 
Mercedes Estrada 
RE:Jane Does 2-8v. Epstein-Cross 
Joint W/P Priv. 
Nod's of Oct 6-8 depos 
l 5033-15032 08/05/2009 
Jacquie Johnson 
Mercedes Estrada 
RE:Epstein-Depo for 8/17 
Joint W/P Priv. 
15087-15093 08/06/2009 
Jacquie Johnson 
Mercedes Estrada 
RE:Epstein-Depo for 8/17 
Joint W/P Priv. 
15094-15100 08/06/2009 
Jacquie Johnson 
Kikka Claudio 
RE:Epstein Depo-New York 
Joint W/P Priv. 
15109-15112 
08/10/2009 
Jacquie Johnson 
Adam Horowitz 
RE:Epstein 
Depositions 
for Joint W/P Priv. 
8/14,17,18 in NY & OH 
5 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weisslna: Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
15122-15125 
08/11/2009 
Jacquie Johnson 
Kikka Claudio 
RE: 
Ms. 
Maxwell 
Depo 
Joint W/P Priv. 
rescheduled 
15142-15158 08/11/2209 
Bradley Edwards 
Kikka Claudio 
FW:out of state subpoenas 
Joint W/P Priv. 
15166-15170 08/11/2009 
Jacquie Johnson 
Kikka Claudio 
RE:out of state subpoenas 
Joint W/P Priv. 
15171-15172 
08/11/2009 
Jacquie Johnson 
Kikka Claudio 
RE:Epstein 
Joint W/P Priv. 
15178-15182 
08/12/2009 
Jacquie Johnson 
Kikka Claudio 
RE:Epsteln 
Joint W/P Priv. 
15306-15355 
08/25/2009 
Jacquie Johnson 
Kikka Claudio 
FW:Epstein Depo Notices & Subs 
Joint W/P Priv. 
14951-14952 
08/03/2009 
Jacquie Johnson 
Kikka Claudio 
RE:Epstein Depo-New York 
Joint W/P Priv. 
14954-14972 
09/16/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein-Depo of Mark Epstein 
Joint W/P Priv. 
on 9/21 in NY will take place as 
scheduled 
14979-14981 
08/03/2009 
Jacquie Johnson 
Kikka Claudio 
RE:Epstein Depo-NewYork 
Joint W/P Priv. 
14983-15015 08/04/2009 
Jacquie Johnson 
Adam Horowitz 
RE:Epstein Depositions 8/14.17, 
Joint W/P Priv. 
&18in NY &OH 
16501-16519 09/15/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein Hearing 
Joint W/P Priv. 
16520-16547 09/09/2009 
Spencer Kuvin 
Jacquie Johnson 
RE:Epstein•Deposition of Jane 
Joint W/P Priv. 
Doe-9/30/2009 
16355-16384 
08/24/2009 
Adam Horowitz 
Jacquie Johnson 
Epstein Oepo Notices and Subs 
Joint W/P Priv. 
16554·16568 09/16/2009 
Kikka Claudio 
Jacquie Johnson 
RE:Epstein Depo 
Joint W/P Priv. 
6 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissimz Edwards Flstos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
16574-16S77 09/17/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein Depo 
Joint W/P Priv. 
16396-16398 09/01/2009 
Margaret Estrada 
Jacquie Johnson 
Alan Oershowitz 
Joint W/P Priv. 
16578-16581 09/17/2009 
Katherine Ezell 
Jacquie Johnson 
RE:Depo 
Joint W/P Priv. 
16582-16585 09/18/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Deposition 
of 
Jean 
Luc 
Joint W/P Priv. 
Bruhnel 
16585-16611 09/18/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein Depo 
Joint W/P Priv. 
16612-16439 09/18/2009 
Adam Horowiu 
Jacquie Johnson 
RE:Epstein Oepo of Mark Epstein 
Joint W/P Priv. 
16440 
08/18/2009 
Spencer Kuvin 
Jacquie Johnson 
RE:Epstein Sub to Bear Stearn 
Joint W/P Priv. 
16740-16753 09/22/2009 
Margaret Berk 
Jacquie Johnson 
RE:Epstein Oepos 
Joint W/P Prlv. 
16443-16452 09/09/2009 
Katherine Ezell 
Jacquie Johnson 
RE:Epstein-Oepos of Marcinkova Joint W/P Prlv. 
& Sarah Keller 
16777-16786 09/30/2009 
Adam Horowiu 
Jacquie Johnson 
RE:Epstein 
Joint W/P Priv. 
16793-16794 10/01/2009 
Lisa Rivera 
Jacquie Johnson 
RE:Depo of David Hart Rogers 
Joint W/P Priv. 
16462-16477 09/10/2009 
Adam Horowiu 
Jacquie Johnson 
RE:Epstein-Notice of Production Joint W/P Priv. 
from Non Parties 
16802-16823 10/02/2009 
Margaret Berk 
Jacquie Johnson 
RE:Epstein depos 
Joint W/P Priv. 
16483-16486 09/10/2009 
Katherine Ezell 
Jacquie Johnson 
RE:Epstein-Notice of Production Joint W/P Priv. 
from Non Parties 
7 

NOT A CERTIFIED COPY
Privilege Log - Dated 2-23-2011 
I 
I 
I 
I 
Farmer Jaffe Weissim? Edwards Fistos & Lehrman 
BATES 
DATE 
TO 
FROM 
DESCRIPTION 
OBJECTION 
16874-16880 
10/13/2009 
Adam Horowitz 
Jacquie Johnson 
Depo 
Joint W/P Priv. 
16904-16905 
10/14/2009 
Spencer Kuvin 
Jacquie Johnson 
RE:Epstein 
Joint W/P Priv. 
16945 
10/26/2009 
Klkka Oaudio 
Jacquie Johnson 
RE:Epstein depos on 10/28 
Joint W/P Priv. 
17033-17034 
10/26/2009 
Kikka Claudio 
Jacquie Johnson 
RE:Epstein depos on 10/28 
Joint W/P Priv. 
02065-02068 
06/08/2009 
Bradley Edwards 
Mercedes Estrada 
FW: Epstein-Confirming 
AT&T 
Joint W/P Priv. 
Dial Telephone Conference for 
Mon 6/8/09 at 2:00 p.m. 
02070 
09/02/2009 
Jacquie Johnson 
Spencer Kuvin 
FW:Epstein-Depos 
of Joint W /P Priv. 
Marcinkova & Sarah Kellen 
02071 
08/18/2009 
Adam Horowitz 
Jacquie Johnson 
RE:Epstein Sub to Bear Sterns 
Joint W/P Priv. 
02072-02078 
09/04/2009 
Jacquie Johnson 
Spencer Kuvin 
FW:Epstein-Depos 
of Joint W/P Priv. 
Marcinkova & Sarah Kellen 
03466-03468 
05/14/2009 
Spencer Kuvin 
Bradley Edwards 
RE:Actvity 
in 
Case 
9:08-cv-
Joint W/P Priv. 
80893-KAM Doe"· Epstein Order 
on Motion to Stay 
02301-02302 
09/09/2009 
Paul Cassel 
Bradley Edwards 
FW:Epsteln 
Joint W/P Priv. 
03122-03123 
06/10/2009 
Adam Horowitz 
Bradley Edwards 
FW: Motion to Dismiss 
Joint W/P Priv. 
02805-02806 
05/26/2009 
Susan Stirling 
Katherine Ezell 
RE:WPB·Confldential-Genereal-
Joint W/P Priv. 
Financial Disclosure/Discovery 
02670-02671 
10/21/2009 
Bradley Edwards 
Spencer Kuvin 
FW:Subpoena Info 
Joint W/P Priv. 
02S17-02519 
10/02/2009 
Bradley Edwards 
Katherine Ezell 
FW:Meeting w/Stanley Arkin 
Joint W/P Priv. 
8