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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.
(5), as set forth herein below at paragraph 4. 2 EFTA00729441 Case 0:09-cr-60331-JIC Document 1 Entered on FLED Docket 12/01/2009 Page 3 of 36 THE PATTERN OF RACKETEERING ACTIVITY 4. The pattern of racketeering activity as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), through which the defen
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
(5), as set forth herein below at paragraph 4. 2 EFTA00596526 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 3 of 36 THE PATTERN OF RACKETEERING ACTIVITY 4. The pattern of racketeering activity as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), through which the defen
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
ity as that term is defined in Title 18, United States Code, Sections 1961(1) and (5), as set forth herein below at paragraph 4. 2 EFTA00683126 THE PATTERN OF RACKETEERING ACTIVITY 4. The pattern of racketeering activity as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), through which the defen
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
and (5), as set forth herein b paragraph 4. 2 EFTA00795625 • Case 0:09-cr-60331-JIC Document 1 Entered on FLSO Docket 12/01/2009 Page 3 of 36 THE PATTERN OF RACKETEERING ACTIVITY 4. The pattern of racketeering activity as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), through which the defen
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
(5), as set forth herein below at paragraph 4. 2 EFTA00223305 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 3 of 36 THE PATTERN OF RACKETEERING ACTIVITY 4. The pattern of racketeering activity as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), through which the defen
Entities connected to both Florida Bar and THE PATTERN OF RACKETEERING

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONScott Rothstein
PERSON
United States
LOCATION
George W. Bush
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATIONMichael J. Pike
PERSONLeon Black
PERSON
Bill Clinton
PERSON
Donald Trump
PERSON
Palm Beach County
LOCATION
Prince Andrew
PERSON
the United States District Court
ORGANIZATIONRothstein Rosenfeldt Adler
ORGANIZATION
Marc Rich
PERSON
Rosenfeldt
PERSON
Bill Richardson
PERSON