IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMII-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCO'IT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. CORRECTED 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. Through the law firm of Rothstein, Rosenfeldt and Adler, P.A ("RRA"), Rothstein and others in this criminal enterprise conducted a $1.2 billion Ponzi scheme which was perpetrated with, 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 was essentially legal extortion, Rothstein persuaded investors, that he could pressure defendants, including Epstein, into paying astronomical settlements and further defrauded investors by convincing them to purchase fake interests in assignments of fictitious structured settlements, EFTA01079777