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ring the course of the "Ponzi" scheme. 4. From in or about 2005 and continuing thereafter through in or about November 2009, in Broward County, in the Southern District of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the U
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
ring the course of the "Ponzi" scheme. 4. From in or about 2005 and continuing thereafter through in or about November 2009, in Broward County, in the Southern District of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the U
$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
de information due to its representation of one of Epstein's alleged victims in a civil case styled Jane Doe v. Jefrey Epstein, currently pending in the Southern District of Florida. Representatives of D3 were offered "the opportunity" to invest in a pre-suit, $30,000,000.00, court settlement against Epstein arising
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
ring the course of the "Ponzi" scheme. 4. From in or about 2005 and continuing thereafter through in or about November 2009, in Broward County, in the Southern District of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the U
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
Entities connected to both the Southern District and Toronto Dominion Bank

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSONLeon Black
PERSON
Donald Trump
PERSON
Bill Clinton
PERSON
Palm Beach County
LOCATION
Joe Biden
PERSON
Marc Rich
PERSONCourtney Wild
PERSONScott Rothstein
PERSON
Samantha Power
PERSON
Bill Richardson
PERSONFlorida Bar
ORGANIZATION