Epstein Secrets

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.

fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to

otion is being filed, the undersigned has not received a response from Mr. Coffey or Mr. Singerm By: s/Robert D. Critton ROBERT D. CRITTON, JR., Florida Bar No. 224162 [email protected] Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of

In each of these civil actions, each of the Plaintiffs is represented by Bradley J. Edwards, William Berger and the RRA law firm, 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. Attorneys Russell Alder and Peter Feaman have also appeared for the Plaintiffs. 4. Based upon recent and ongoing media repor

lawyers have years of experience - former state attorney, civil practitioners, a circuit court judge — all of whom probably have served on various Florida Bar committees. Yet they claim a lack of knowledge when: a. The firm had 24 hour security in the form of Broward County Sheriff's officers on each floo

employed over 70 attorneys and 200 support staff. RRA also maintains EFTA00725322 Epstein v. RRA, et al. Page 5 an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to

A lawyers have years of experience former state attorney, civil practitioners, a circuit court judge — all of whom probably have served on various Florida Bar committees. Yet they claim a lack of knowledge of any indication that problems with the firm existed when: a. RRA had 24 hour security in the form

employed over 70 attorneys and 200 support staff. RRA also maintains EFTA00725294 Epstein v. RRA, et al. Page 7 an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to

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

fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to

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

ffices in Florida, Cv York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-85'15. RRA, through its attorneys, including those named as Defendant n, conducted business throughout Florida, and relevant to thi

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

fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to

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

fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to