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illionaire financier. In fact, RRA did have inside 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-su
ntiffs for their damages. 9. Furthermore, as alleged in detail infra, the Principal Conspirators' inner-circle of facilitators (TD Bank, Spinosa, Kerstetter, Caretsky, Gibraltar Bank, Berenfeld, Weintraub, Berkowitz, Leitstein, Levin, Preve, Banyon entities, Szafranski, Onyx, Villegas, Boden, Barnett, S
, v. Scott W. Rothstein, et at Complex Litigation Division - Case No.: 09-062943 (19) Third Amended Complaint a. March 20, 2009, letter signed by Kerstetter enclosing RRA trust/escrow account statements for: i. account number 6860699146 showing a balance of $104,211,711.22; ii. account number 6860420
ing in Broward County, Florida and, at all times relevant hereto, was acting within the scope of her employment as an assistant manager for TD Bank. Kerstetter contributed to the scheme by, among other things, making material misrepresentations in meeting with investors, providing falsified account stateme
riod and say, You 25 know, I should have realized there was something that were being prosecuted on behalf of throe young 1 woman: M., B.N. and Jane Doe. And w➢ will refer to them when I talk to you about them in that ➢ame way, 4 referring to sham by those initial➢ and that 5 pseudonym. 4 Desc
who does it sue -- who does he sue? 13 A Scott Rothstein, David Roden, Debra 'Allegan, 14 Andrew Barnett, TO Bank, Frank Spinoaa, Jennifer IS Kerstetter, Rosanne Caretsky and Frank Prove. 14 Q And Mr. Rothstein was the chairman of the 17 Rothstein firm? IS A On November 20, 2009, I don't beli
THSTEIN, EDWARDS (who either know or should have known) and, at times, L.M. in her Civil Action against EPSTEIN: a) Included claims for dirnages in Jane Doe's federal action in excess of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Organized a Jane Doe TV media interview witho
mplaint against ROTHSTEIN, David Boden, Debra Villegas, Andrew Bamett, TD Bank, N.A., Frank EFTA00193822 Epstein I RRA, et al. Page 9 Spinosa, Kerstetter, Rosanne Caretsky and Frank Preve asserting various allegations that further prove the massive Ponzi scheme behind the RRA facade; and as of Novemb
ROTHSTEIN, EDWARDS (who either know or should have known) and, at times, in her Civil Action against EPSTEIN: a) Included claims for de-triages in Jane Doe's federal action in excess of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Organized a Jane Doe TV media interview witho
mplaint against ROTHSTEIN, David Baden, Debra Villegas, Andrew Barnett, TD Bank, N.A., Frank EFTA00223275 Epstein RRA, et al, Page 9 Spinosa, Kerstetter, Rosanne Caretsky and Frank Preve asserting various allegations that further prove the massive Ponzi scheme behind the RRA facade; and as of Novemb
Entities connected to both Jane Doe and Kerstetter

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSONRobert D. Critton
PERSON
George W. Bush
PERSONLeon Black
PERSONScott Rothstein
PERSON
Prince Andrew
PERSONRoy Black
PERSONMartin Weinberg
PERSON
Donald Trump
PERSON
Bill Clinton
PERSON
Palm Beach County
LOCATION
Marc Rich
PERSONRothstein Rosenfeldt Adler
ORGANIZATIONFlorida Bar
ORGANIZATION