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or concealment by incurring additional attorney's fees, costs, and expenses in aggressively defending the civil actions whereas in reality, because the Civil Actions against Plaintiff were being exploited and over-valued so as to lure additional investors and to attempt to extort as much money as possible from EPSTEIN so as to co
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
or concealment by incurring additional attorney's fees, costs, and expenses in aggressively defending the civil actions whereas in reality, because the Civil Actions against Plaintiff were being exploited and over-valued so as to lure additional investors and to attempt to extort as much money as possible from EPSTEIN so as to co
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
or concealment by incurring additional attorney's fees, costs, and expenses in aggressively defending the civil actions whereas in reality, because the Civil Actions against Plaintiff were being exploited and over-valued so as to lure additional investors and to attempt to extort as much money as possible from EPSTEIN so as to co
• 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
or concealment by incurring additional attorney's fees, costs, and expenses in aggressively defending the civil actions whereas in reality, because the Civil Actions against Plaintiff were being exploited and over-valued so as to lure additional investors and to attempt to extort as much money as possible from EPSTEIN so as to co
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
or concealment by incurring additional attorney's fees, costs, and expenses in aggressively defending the civil actions whereas in reality, because the Civil Actions against Plaintiff were being exploited and over-valued so as to lure additional investors and to attempt to extort as much money as possible from EPSTEIN so as to co
ase 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 are realleged and incorporated herein by reference. 2. 113 Bank, N.A., (hereinafter refe
Entities connected to both the Civil Actions against Plaintiff and The General Allegations

Broward County
LOCATIONScott Rothstein
PERSON
George W. Bush
PERSON
Morocco
LOCATIONAdler, P.A.
ORGANIZATION
TD Bank
ORGANIZATIONLeon Black
PERSON
Jeffrey Epstein
PERSON
David Copperfield
PERSON
Marc Rich
PERSON
Bill Clinton
PERSONWilliam Berger
PERSONAlan Sakowitz
PERSONFla. Stat.
ORGANIZATIONTommy Mottola
PERSON
Kenneth Marra
PERSONXanax, Ecstasy
ORGANIZATIONSusan H. Black
PERSONU.S. Circuit Court
ORGANIZATIONFlorida Professional Service Corporation
ORGANIZATION