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 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 by defrauding investors into purchasing fake interests in assignments of fictitious structured settlements, including those falsely claimed to have been reached by RRA for clients with claims against Epstein, all to the detriment of the Plaintiff. Defendants Rothstein, Edwards, and others, conspired to induce investors to fund the prosecution of the civil claims against Epstein and in furtherance thereof, made improper use of the judicial system and civil process by inter alia engaging in unreasonable and vexatious discovery and motion practice in certain underlying actions against Epstein, making unfounded allegations in FOWLER WHITE BURNED' P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE.. WEST PALM BEACH, FLORIDA 33401 • EFTA01084208