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.

nancial Holdings, Inc.; aa. C107 LLC; ab. CI08 LLC; ac. C116 LLC; ad. C127 LLC; ae. CSU LLC; at I) & D Management & Investment LLC; ag. D & S Management and Investment LLC; ah. DJB Financial Holdings LLC; 29 EFTA00729468 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 30 of 36 ai. DYMMU

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

nancial Holdings, Inc.; aa. CI07 LLC; ab. C108 LLC; ac. CII6 LLC; ad. C127 LLC; ae. CSU LLC; af. D & D Management & Investment LLC; ag. D & S Management and Investment LLC; ah. DJB Financial Holdings LLC; 29 EFTA00596553 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 30 of 36 ai. DYMMU

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

nancial Holdings, Inc.; aa. CI07 LLC; ab. CI08 LLC; ac. CII 6 LLC; ad. CI27 LLC; ae. CSU LLC; at D & D Management & Investment LLC; ag. D & S Management and Investment LLC; ah. DJB Financial Holdings LLC; 29 EFTA00683153 ai. DYMMU LLC; aj. Full Circle Fort Lauderdale LLC; ak. Full Circle Trademark Holdings LL

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

OVCU LLC; LLC; Broward F. Idings, Inc.; C107 W i LLC; CN14 CLILC; C127 LLC; + Ilirite. CSU LLC; af. D & D Management & Investment LLC; ag. D & S Management and Investment LLC; ah. DJB Financial Holdings LLC; 29 EFTA00795652 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 30 of 36 ai. DYMMU

or MORSE shall appear before this Court and testify, under oath. as to his receipt of these funds, under penalty of perjury and subject to action by the Florida Bar; .. 22. That based upon argument and representations of MORSE's counsel, made under oath; MORSE is suffering from significant financial distress du

Financial Holdings, Inc.; aa. CI07 LW; ab. CI08 LW; ac. CII6 LLC; ad. CI27 LLC; ae. CSU LLC; af. D & D Management & Investment LLC; ag. D & S Management and Investment LLC; alt DM Financial Holdings LLC; 29 EFTA00193879 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 30 of 36 ai. DYMMU

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

ncial Holdings, Inc.; aa. CI07 LLC; ab. CI08 LLC; ac. CII 6 LLC; ad. CI27 LLC; ae. CSU LLC; af. 13 & D Management & Investment LLC; ag. D & S Management and Investment LLC; ah. 13.1B Financial Holdings LLC; 29 EFTA00223332 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 30 of 36 ai. DYM