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'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
y spent time asking me about the lock letters 20 at the point in time we were utilizing them and the 21 mechanics, and I had to refer them to Mr. Spinosa to 22 answer that question. 23 They asked me about my history with other 24 investors, Thane Ritchie. I don't remember, again, 25 whether it
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
y spent time asking me about the lock letters 20 at the point in time we were utilizing them and the 21 mechanics, and I had to refer them to Mr. Spinosa to 22 answer that question. 23 They asked me about my history with other 24 investors, Thane Ritchie. I don't remember, again, 25 whether it
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
udulent conduct alleged herein while willfully ignoring and/or failing to exercise reasonable care. 46. Defendant, FRANK A. SPINOSA (hereinafter, "Spinosa"), is an individual residing in Broward County, Florida and, at all times relevant hereto, was acting within the scope of his employment as a senio
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
ssly allowed itself to become a conduit for these activities and, accordingly, is liable for its participation; m. in late November, TD Bank fired Spinosa; B. Levin, Preve and Banyon 309. Plaintiffs have discovered, relative to Levin, Preve, and Banyon, that: a. an $8,000,000.00 wire transfer conf
Entities connected to both Villegas and Spinosa

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSONthe Southern District
LOCATIONJane Doe
PERSON
Prince Andrew
PERSON
Clockwork
ORGANIZATION
Rosenfeldt
PERSONBanyon
ORGANIZATION
Morocco
LOCATION
Barry Diller
PERSON
TD Bank
ORGANIZATIONPreve
ORGANIZATION
Adler
PERSON
Lawrence Krauss
PERSONBekkedam
PERSONSzafranski
PERSONFrank Spinosa
PERSONFlorida Bar
ORGANIZATION