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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.
Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 14 of 36 COUNT 2 (Money Laundering Conspiracy, 18 U.S.C. §1956(h)) 1. The General Allegations and paragraphs 5 through 40 of Count 1 of the Information arc realleged and incorporated herein by reference. 2. TD Bank, N.A., (hereinafter refer
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
ase 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 14 of 36 COUNT Z (Money Laundering Conspiracy, 18 U.S.C. §1956(h)) . 1. The General Allegations and paragraphs 5 through 40 of Count 1 of the Information are realleged and incorporated herein by reference. 2. T1) Bank, N.A., (hereinafter refe
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
ll in violation of Title 18, United States Code, Section 1962(d). 13 EFTA00683137 COUNT 2 (Money Laundering Conspiracy, 18 U.S.C. §1956(h)) I. The General Allegations and paragraphs 5 through 40 of Count 1 of the Information are realleged and incorporated herein by reference. 2. TD Bank, N.A., (hereinafter refer
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
• Case 0:09-cr-60331-JIC Document 1 Entered on FLSO Docket 12/01/2009 Page 14 of 36 COUNT 2 (Money Laundering Conspiracy, 18 U.S.C. §1956(h)) 1. The General Allegations and paragraphs 5 through 40 of Count 1 of the Information are realleged and incorporated herein by reference. 2. TD Bank, N.A., (hereinafter refer
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
Case 0:09-cr-60331-JIC Document 1 Entered on FLED Docket 12/01/2009 Page 14 of 36 COOT 2 (Money Laundering Conspiracy, l8 U.S.C. §1956(h)) . 1. The General Allegations and paragraphs 5 through 40 of Count 1 of the Information are realleged and incorporated herein by reference. 2. TD Bank, N.A., (hereinafter refer
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
ase 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 14 of 36 COUNT 2 (Money Laundering Conspiracy, 18 U.S.C. §1956(h)) . 1. The General Allegations and paragraphs 5 through 40 of Count 1 of the Information are realleged and incorporated herein by reference. 2. 113 Bank, N.A., (hereinafter refe
Entities connected to both Florida Bar and The General Allegations

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