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.

aputi, up to the amount of $1,000,000; 25 EFTA00729464 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 26 of 36 (BA9) Toronto Dominion Bank, N.A. account 6860291266 in the name of Rothstein Rosenfeldt Adler, P.A. which, on or about November 11, 2009, contained the approximate amount of

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

Caput', up to the amount of $1,000,000; 25 EFTA00596549 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 26 of 36 (BA9) Toronto Dominion Bank, N.A. account 6860291266 in the name of Rothstein Rosenfeldt Adler, P.A. which, on or about November 11, 2009, contained the approximate amount of

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

$2,000,000; (BA8) Bank account at Banque Populaire, Morocco, in the name of Steve Caputi, up to the amount of $1,000,000; 25 EFTA00683149 (BA9) Toronto Dominion Bank, N.A. account 6860291266 in the name of Rothstein Rosenfeldt Adler, P.A. which, on or about November 11, 2009, contained the approximate amount of

back Funding, LLC, et at, v. Scott W. Rothstein, et at Complex Litigation Division - Case No.: 09-062943 (19) Third Amended Complaint wired into a Florida Bar trust account with strict instructions to only release the funds in that account to the specified investment £under. 278. At some point during the

classic Ponzi scheme.2 3. The Principal Conspirators, however, did not act alone. Defendant TD Bank, N.A. (hereinafter, "TD Bank"), a subsidiary of Toronto Dominion Bank, was complicit in this scheme, serving as a critical lynchpin "legitimizing" the Principal Conspirators' plot and providing crucial inducements to