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t and were owed a judgement of approximately $23 million. The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands in order to avoid paying the judgement. 27. Defendant ROTHSTEIN and other co-conspirators falsely advised the clients on several occasions that i
that RBA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that at:7.gs to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and o
mitted, COFFEY BURLINGTON Counsel for Plaindffs 2699 South Bayshore Drive, Penthouse Miami, Florida 33133 (305) 858-2900 B OS I LLADNECIV FEIN Florida Bar . 259861 Annexed hereto as Exhibit A is an affidavit from Plaintiff Rosenfeldt attesting to the truthfulness of the allegations contained herein.
t and were owed a judgement of approximately $23 million. The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands in order to avoid paying the judgement. 27. Defendant ROTHSTEIN and other co-conspirators falsely advised the clients on several occasions that i
that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot
t and were owed a judgement of approximately $23 million. The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands in order to avoid paying the judgement. 27. Defendant ROTHSTEIN and other co-conspirators falsely advised the clients on several occasions that i
that RBA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot
t and were owed a judgement of approximately S23 million. The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands in order to avoid paying the judgement. 27. Defendant ROTHSTEIN and other co-conspirators falsely advised the dEents on NJ P several occasions t
THSTEIN investors that RRA's trust accounts in ned with a well established international banking institution, in accordance with d regulations of the Florida Bar, and that access to balances in the trust accoun I egedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and other co
t and were owed a judgement of approximately $23 million. The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands in order to avoid paying the judgement 27. Defendant ROTHSTEIN and other co-conspirators falsely advised the clients on several occasions that in
that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot
ar and convincing evidence presented by counsel for MORSE and counsel's expert witnesses, JONES has Illegally moved funds from the United States to the Cayman Islands in violation of federal law. for the purpose of secreting these assets; 9. That the IRS has provided competent testimony in this regard clearly est
or MORSE shall appear before this Court and testify, under oath. as to his receipt of these funds, under penalty of perjury and subject to action by the Florida Bar; .. 22. That based upon argument and representations of MORSE's counsel, made under oath; MORSE is suffering from significant financial distress du
t and were owed a judgement of approximately $23 million. The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands in order to avoid paying the judgement. 27. Defendant ROTHSTEIN and other co-conspirators falsely advised the clients on several occasions that i
that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot
Entities connected to both the Cayman Islands and Florida Bar

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Kenneth Marra
PERSONScott Rothstein
PERSON
George W. Bush
PERSONthe Southern District
LOCATIONRobert C. Josefsberg
PERSON
Alexander Acosta
PERSONLeon Black
PERSONMichael J. Pike
PERSON
Prince Andrew
PERSON
Paul Cassell
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSONJack Scarola
PERSON
Jay Lefkowitz
PERSON