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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
on Income Fund. 18. Plaintiff, DEAN KRETSCHMAR (hereinafter, "Kretschmar"), is an individual residing in Broward County, Florida. On June 3, 2009, Kretschmar invested $8,000,000.00 into the Ponzi scheme through Banyon Income Fund. Page 10 of 2210 CONRAD & SCHERER, LLP, 633 SOUTH FEDERAL HIGHWAY, FORT LA
the Ponzi scheme through Banyon USVI, LLC. Von Allmen Dynasty Trust, D&L Partners, David Von Allmen Living Trust, Ann Von Allmen Living Trust, and Kretschmar were also major investors in Razorback. 12. Plaintiff, D3 CAPITAL CLUB, LLC (hereinafter, "D3"), is a Delaware limited liability company with its
Ponzi scheme, RRA was also engaged in litigation against Epstein in three civil cases. The cases were Jane Doe v. Epstein, Case No. 08-CIV- 80893 ("Jane Doe"), U.S. District Court, Southern District of Florida; L.M. v. Epstein ("LM"), Case No. 50-2008 CA 028051XXXXMB-AB; and E.W. v. Epstein ("EW" or "Jan
ught in the case files for the Epstein Actions, which numbered as many as nineteen (19) boxes. 16. On or about October 13, 2009, Dean Kretschmar ("Kretschmar"), a representative of one of the investor groups, was encouraged by Rothstein, in a meeting with other partners of RRA, to look at the Epstein cas
nt was not made soon he would lose the client group to other lawyers. d) During this same time frame, specifically on or around October 13, 2009, Kretschmar and Legamaro of the investor group were shown by Rothstein the actual case files of RRA in the Epstein Actions. The Epstein files were brought to th
Ponzi scheme, RRA was also engaged in litigation against Epstein in three civil cases. The cases were Jane Doe v. Epstein, Case No. 08-CIV- 80893 ("Jane Doe"), U.S. District Court, Southern District of Florida; L.M. v. Epstein ("LM"), Case No. 50-2008 CA 028051XXXXMB-AB; and E.W. v. Epstein ("EW" or "Jan
4215 Epstein v Rothstein, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint 16. On or about October 13, 2009, Dean Kretschmar ("Kretschmar"), a representative of one of the investor groups, was encouraged by Rothstein, in a meeting with other partners of RRA, to look at the Epstein cas
nt was not made soon he would lose the client group to other lawyers. d) During this same time frame, specifically on or around October 13, 2009, Kretschmar and Legamaro of the investor group were shown by Rothstein the actual case files of RRA in the Epstein Actions. The Epstein files were brought to th
f in deposition which had no legitimate baring on the case or the issues to be tried, including questions regarding size of his genitalia; (4) In Jane Doe 2, Edwards represented in pleading to the federal Magistrate that records of communications by and between the United States Government and Epstein's
Fisten and Jenne bring into his office the case files for the Epstein Actions which numbered approximately nineteen (19) boxes. Dean Kretschmar, ("Kretschmar"), a representative of one of the investment companies was permitted by Rothstein to review the case files of RRA against Epstein. 16. On another
Entities connected to both Jane Doe and Kretschmar

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATION
George W. Bush
PERSONScott Rothstein
PERSONJack Scarola
PERSON
Prince Andrew
PERSONMartin Weinberg
PERSON
Donald Trump
PERSONFBI
ORGANIZATIONAtterbury Goldberger & Weiss
ORGANIZATIONFlorida Bar
ORGANIZATION
Barry Diller
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATION
Prince Charles
PERSON
David Copperfield
PERSONJoseph L. Ackerman
PERSON