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dulent conduct alleged herein while willfully ignoring and/or failing to exercise reasonable care. 52. Defendant, DEBRA E. VILLEGAS (hereinafter, "Villegas"), is an individual residing in Broward County, Florida and, at all times relevant hereto, was the chief operating officer at RRA. Villegas, Rothst
g these funds, Bekkedam continued pursuit of additional investment funds. 129. In early summer of 2009, Ballamor's Managing Director Al Rapetti put Bekkedam in touch with Abraxac Discala (hereinafter, "Discala"), who was portrayed as a potential investor source with access to high-net worth individuals
he would pay Musser back if the investment with Banyon failed. 175. On or about July 29, 2009, in an effort to bolster his oral representations, Bekkedam provided Musser with BIF's Confidential Offering Memorandum and incorporated Berenfeld audited financials. 176. The representations in the Confide
latinum, and Centurion) and promoters (TD Bank, Spinosa, Kerstetter, Caretsky, Gibraltar Bank, Levin, Preve, Banyon entities, Szafranski, Onyx, ABS, Bekkedam, Ballamor, Pearson, R.L. Pearson & Associates, Platinum, and Centurion) each played a vital role in the successful perpetration of this systemic fr
't remember who asked 24 me that, one of those gentlemen. 25 We talked about transparency. And this was - to Many of them asked questions of Ms. Villegas because she was represented to have been with me for over two decades and my COO and worked her way up from secretary, and they inquired about my
pital? 4 A I recall that as well. S Q Do you recall that Razorback was sort of a next 6 generation version of the Banyon Income Fund that 7 Bekkedam had brought Von Allmen into? 8 A I don't recall. 9 Q That basically Razorback was lending -- that 10 A.J.'s group lent money to a Banyon enti
ow long my employees had been with 10 me and whether I trusted them, specifically my CFO, Irene 11 Stay. 12 Many of them asked questions of Ms. Villegas 13 because she was represented to have been with me for over 14 two decades and my COO and worked her way up from 15 secretary, and they inquir
pital? 4 A I recall that as well. 5 Q Do you recall that Razorback was sort of a next 6 generation version of the Banyon Income Fund that 7 Bekkedam had brought Von Allmen into? 8 A I don't recall. 9 Q That basically Razorback was lending -- that 10 A.J.'s group lent money to a Banyon enti
r."; xiv. Preve received over $440,000.00 in payments from the Principal Conspirators; C. Villegas 310. Plaintiffs have discovered relative to Villegas that: a. on July 27, 2009, Rothstein transferred a property with an assessed value of $407,750.00 to Villegas for "love and affection" and $100.00
sary to sustain the Ponzi scheme over a period of four years; E. Ballamor and Bekkedaro 312. Plaintiffs have discovered relative to Ballamor and Bekkedam that: a. Bekkedam and Ballamor, in their role as investment advisors, induced client investments into the Rothstein Ponzi despite particular facts
Entities connected to both Villegas and Bekkedam

George W. Bush
PERSON
Jeffrey Epstein
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSON
Clockwork
ORGANIZATION
Morocco
LOCATION
Rosenfeldt
PERSONBanyon
ORGANIZATION
TD Bank
ORGANIZATIONSpinosa
PERSON
Barry Diller
PERSON
Adler
PERSONFrank Spinosa
PERSONPreve
ORGANIZATIONSzafranski
PERSON
Lawrence Krauss
PERSONthe Clifford Chance
PERSONA.J. Discala
PERSONthe Banyon Income Fund
ORGANIZATIONBoden
PERSON