IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. 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") and alleges: INTRODUCTION This litigation has its genesis in the creation and operation of a criminal $1.2 billion Ponzi scheme designed to inject funds into the law firm of Rothstein, Rosenfeldt and Adler, ("RRA"), to personally enrich Rothstein and others at RRA, and to raise capital to fund the prosecution of civil claims against Epstein for alleged sexual assault and battery by defrauding investors into purchasing interests in assignments of alleged structured settlements, including those reached by RRA for clients with claims against Epstein, all to the detriment of the Plaintiff. Defendants Scott Rothstein and Bradley Edwards, made improper use of the judicial system and civil process by inter alia engaging in unreasonable and vexatious discovery in the underlying actions against Epstein, making unfounded allegations in the underlying actions, using improper FOWLER WHITE BURNETP .• 901 PHILLIPS POINT WEST, 777 SOUTH FLAOLER DRIVE, WEST PALM HFACII, FLORIDA 33401 • (561) 802.9044 EFTA00621477