Elcctronically Filcd 09/26/2013 08:24:50 PM El' IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN individually, J. individually, Cos Defendant/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFF NT ON DEFEND FOURTH AI E SUPPORTING MEMO Plaintiff/Counter-Defendant, Je st TEIN'S MOTION R-PLAINTIFF UNTERCLAIM AND OF LAW ("Epstein"), by and through his undersigned counsel and pursuant toolllle 1. 0 of the Florida Rules of Civil Procedure, files this Motion for Sum Fourth Amended ent on Defendant/Counter-Plaintiff (claim, and in support thereof states the following: I. PROCEDURAL HISTORY In Dege4er 2 a"), fili , Epstein filed suit against Scott Rothstein ("Rothstein") and based upon Epstein's justifiable belief at the time of mplaint 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, part of which featured the use of civil cases that had been filed against Epstein by Rothstein's partner EFTA02772471