IN THE CIRCUIT COURT OF THE I'II-1 EENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOOCMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: DAVID CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEDIATION SUMMARY Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files this Mediation Summary in preparation for the Mediation scheduled before you on October 11, 2013, and states: I. PROCEDURAL HISTORY In December 2009, Epstein filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"), based upon Epstein's well-founded belief at the time of filing his Complaint that these two individuals, and other unknown partners of theirs at Rothstein, Rosenfeldt, Adler ("RRA"), engaged in serious misconduct involving a widely publicized illegal Ponzi scheme operated through their law firm (the "Ponzi scheme"). Rothstein himself admitted to, and was convicted for, this Ponzi scheme, which featured civil cases against Epstein as bait to lure unsuspecting investors into the fraudulent scheme. Edwards was lead counsel on these cases. After taking the deposition of Scott Rothstein, and receiving numerous rulings from this Court prohibiting Epstein from receiving discovery germane to proving his case, Epstein dismissed his case against Edwards, without prejudice. In response to Epstein's original lawsuit, Edwards filed a Counterclaim, and after a series of dismissals thereof and four (4) revisions, Edwards has stated two causes of action against Epstein: Abuse of Process and Malicious Prosecution. Epstein has denied liability as to these EFTA00597312