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Epstein as well as the improper litigation tactics outlined above) occurred within a five-year time period. 58. As a direct and proximate result of ROTHSTEIN, EDWARDS and L.M.'s violations of §772.103, Fla. Stat., EPSTEIN has been injured. 59. Pursuant to §772.104(1), Fla. Stat., Plaintiff EPSTEIN is entitled to
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
Epstein as well as the improper litigation tactics outlined above) occurred within a five-year time period. 58. As a direct and proximate result of ROTHSTEIN, EDWARDS and ■.'s violations of §772.103, Fla. Stat., EPSTEIN has been injured. 59. Pursuant to §772.104(1), Fla. Stat., Plaintiff EPSTEIN is entitled to th
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
Epstein as well as the improper litigation tactics outlined above) occurred within a five-year time period. 58. As a direct and proximate result of ROTHSTEIN, EDWARDS and L.M.'s violations of §772.103, Fla. Stat., EPSTEIN has been injured. 59. Pursuant to §772.104(1), Fla. Stat., Plaintiff EPSTEIN is entitled to
• 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
TEIN, EDWARDS and L.M. possessed ulterior motives or purposes in exercising such illegal, improper, or perverted use of process. 72. As a result of ROTHSTEIN, EDWARDS and L.M.'s actions, EPSTEIN suffered damages. WHEREFORE, Plaintiff EPSTEIN respectfully demands the entry of a judgment for damages against all th
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
Entities connected to both ROTHSTEIN, EDWARDS and The General Allegations

George W. Bush
PERSONAdler, P.A.
ORGANIZATIONScott Rothstein
PERSON
Broward County
LOCATIONLeon Black
PERSON
Jeffrey Epstein
PERSON
TD Bank
ORGANIZATION
Morocco
LOCATIONJane Doe TV
PERSONthe Civil Actions against Plaintiff
ORGANIZATIONRacketeering Conspiracy
ORGANIZATIONDade County
LOCATIONFlorida Professional Service Corporation
ORGANIZATIONU.S. Circuit Court
ORGANIZATIONSusan H. Black
PERSON
Kenneth Marra
PERSONXanax, Ecstasy
ORGANIZATIONFederal Case
ORGANIZATIONthe Civil Actions'
ORGANIZATIONFrank Preve
PERSON