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. 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") and (collectively referred to as "Defendants") 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, P.A ("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, Bradley Edwards, and others conspired to induce investors to fund the prosecution of the Epstein Actions and in so doing made improper use of the judicial system and civil process by inter alia engaging in unreasonable and vexatious discovery in the FOWLER WHITE BURNETT P.A. • 903 PHILLIPS POINT WEST, 777 SOUTH FLA0LER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA01082338