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M v. Jeffrey Epstein, 502008CA028051XXXXMB AB; EW v. Jeffrey Epstein, 502008CA028058XXXXMB AB; and Jane Doe v. Jeffrey Epstein, 08-80893- CIV Marra/Johnson; deposition of Jeffrey Epstein, p. 23, line 4; p. 38, line 22. R. 809-10, citing amended complaint in Razorback Funding, LLC, et al. v. Scott W Rot
rm, which enhanced the credibility of the purported investment opportunity; (d) Rothstein and other co-conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA, to expand RRA by the hiring of additional attorneys and support staff, to fund sala
on requested is protected by a privilege, then a privilege log must be prepared and attached to the response. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Moreover, Florida Rule of Civil Procedure 1.280(b)(3) permits discovery of fact work product where the request
res on improper pleadings, discovery and motion practice by Edwards in the cases he was litigating against Epstein while a Partner at RRA and while the Ponzi Scheme was then in critical need of additional investment and about to unravel, as well as a subsequent Federal court order characterizing one of those mo
aL, Case No. 09-062943(19); Deposition Transcript of Jeffrey Epstein. 502008CA028058XXXXMB AB; and Jane Doe v. Jeffrey Epstein, 08-80893-CIV Marra/Johnson. Rothstein returned to South Florida in November 2009 to face federal criminal charges and civil claims by private investors arising out of what w
ews outlets also reported at that time that the Florida Bar had begun actively investigating dozens of attorneys employed by RRA in connection with the Ponzi Scheme. [Cite Epstein Affidavit]; Miami Herald, Scott Rothstein Scandal: Scott Rothstein Partners Probed (January 14, 2010)("The Florida Bar is investigat
the existence of a Ponzi scheme and a wrongdoer's 8 EFTA00595537 Case 10-02612-RBR Doc 148-1 Filed 12/14/10 Page 9 of 10 fraudulent intent. See Johnson v. Neilson (In re Slatkin), 525 F.3d 805,811-12 (9th Cir. 2008). Further, 'criminal convictions based on operating a Ponzi scheme establish fraudule
tody. [D.E. 106 at '68-69]. At Rothstein's sentencing, Judge James I. Cohn made several findings regarding the role that RRA played in facilitating the Ponzi Scheme. In particular he noted that Millis case is about the selling of fake financial products. The marketing, however, was anything but simple. It was so
LM v. Jeffrey Epstein, 502008CA028051XXXXMB AB; EW v. Jeffrey Epstein, 502008CA028058XXXXMB AB; and Jane Doe v. Jeffrey Epstein, 08-80893-CIV Marra/Johnson; Deposition Transcript of Jeffrey Epstein, p. 23; line 4-p. 38; line 22. 5 Among the allegations in the Razorback Complaint regarding the fraudulen
time that Rothstein had been disbarred and the Florida Bar had begun actively investigating dozens of attorneys employed by RRA in connection with the Ponzi Scheme. [Cite Epstein Affidavit]; Miami Herald, Scott Rothstein Scandal: Scott Rothstein Partners Probed (January 14, 2010)("The Florida Bar is investigati
on requested is protected by a privilege, then a privilege log must be prepared and attached to the response. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Moreover, Florida Rule of Civil Procedure 1.280(b)(3) permits discovery of fact work product where the request
res on improper pleadings, discovery and motion practice by Edwards in the cases he was litigating against Epstein while a Partner at RRA and while the Ponzi Scheme was then in critical need of additional investment and about to unravel, as well as a subsequent Federal court order characterizing one of those mo
on requested is protected by a privilege, then a privilege log must be prepared and attached to the response. See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Florida Rule of Civil Procedure 1.280(b)(3) permits discovery of fact work product where the requesting party
res on improper pleadings, discovery and motion practice by Edwards in the cases he was litigating against Epstein while a Partner at RRA and while the Ponzi Scheme was then in critical need of additional investment and about to unravel, as well as a subsequent Federal court order characterizing one of those mo
Entities connected to both Scarlett Johansson and the Ponzi Scheme

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSONJack Goldberger
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Bill Clinton
PERSONScott Rothstein
PERSONJack Scarola
PERSONWright
PERSONWalker
PERSONAtterbury
ORGANIZATION
Murray
PERSONRothstein Rosenfeldt Adler
ORGANIZATION
South Florida
LOCATION
Chris Christie
PERSONWolfe
PERSON