IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800X.XXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. SECOND AMENDED COMPLAINT The Plaintiff, Jeffrey Epstein, ("Epstein"), by and through his undersigned attorneys, files this action against the Defendants, Scott Rothstein, ("Rothstein") and Bradley J. Edwards ("Edwards") (collectively referred to as "Defendants") and alleges: INTRODUCTION This litigation has at its core a law firm that has been described by a United States Attorney as a criminal enterprise. Its founder, Scott Rothstein — Edwards' partner, is currently serving a 50-year sentence in federal prison for selling fake settlements to unsuspecting investors. This $1.2 billion Ponzi scheme was based on the crafting of fake agreements, forged signatures and a fundamental corruption of the many legal protections that the legal system has in place. By claiming to be engaged in what is tantamount to legal extortion, the law firm of Rothstein, Rosenfeldt and Adler, P.A ("RRA") defrauded investors, convincing them into purchasing fake interests in assignments of fictitious structured settlements, including those falsely claimed to have been reached by RRA for Edwards' clients with claims against Epstein, to the detriment of the Plaintiff. Defendants Rothstein, Edwards, and others, conspired to induce FOWLER WHITE BuRNEET P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE. WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00584212