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with its principal place of business in Fort Lauderdale, Florida. BIF, at all times relevant hereto, was operated by its Managing Members Levin and Preve as a putative investment entity formed exclusively to purchase interests in Ponzi scheme settlements. 55. Defendant, BANYON USVI, LLC (hereinafter
vestigative team representative privately told a D3 representative that they found three additional claimants about whom Rothstein did not yet know. Preve was present for this meeting, despite the fact that he was not involved as an investor or representative in the D3 deal. Page 35 of 2210 CONRAD &
g these funds, Bekkedam continued pursuit of additional investment funds. 129. In early summer of 2009, Ballamor's Managing Director Al Rapetti put Bekkedam in touch with Abraxac Discala (hereinafter, "Discala"), who was portrayed as a potential investor source with access to high-net worth individuals
he would pay Musser back if the investment with Banyon failed. 175. On or about July 29, 2009, in an effort to bolster his oral representations, Bekkedam provided Musser with BIF's Confidential Offering Memorandum and incorporated Berenfeld audited financials. 176. The representations in the Confide
latinum, and Centurion) and promoters (TD Bank, Spinosa, Kerstetter, Caretsky, Gibraltar Bank, Levin, Preve, Banyon entities, Szafranski, Onyx, ABS, Bekkedam, Ballamor, Pearson, R.L. Pearson & Associates, Platinum, and Centurion) each played a vital role in the successful perpetration of this systemic fr
top of that there was questions being 3 asked of me through Mr. Preve. Somebody would contact 4 him from the group, one of these people. And then Preve 5 would say, the Clockwork group wants to know this, the 6 whatever he's calling it, the Von Allmen group, whatever 7 he was referring to. 8
EFTA00314948 Page 2248 1 get questions and have to answer things. 2 Then on top of that there was questions being 3 asked of me through Mr. Preve. Somebody would contact 4 him from the group, one of these people. And then Preve 5 would say, the Clockwork group wants to know this, the 6 wh
pital? 4 A I recall that as well. S Q Do you recall that Razorback was sort of a next 6 generation version of the Banyon Income Fund that 7 Bekkedam had brought Von Allmen into? 8 A I don't recall. 9 Q That basically Razorback was lending -- that 10 A.J.'s group lent money to a Banyon enti
top of that there was questions being 3 asked of me through Mr. Preve. Somebody would contact 4 him from the group, one of these people. And then Preve 5 6 7 8 9 was 10 fairly significant due diligence, and they kept prodding 11 and pushing. They kept us on our toes, that's for 12 certain
EFTA01735047 Page 2248 1 get questions and have to answer things. 2 Then on top of that there was questions being 3 asked of me through Mr. Preve. Somebody would contact 4 him from the group, one of these people. And then Preve 5 6 7 8 9 was 10 fairly significant due diligence, and th
pital? 4 A I recall that as well. 5 Q Do you recall that Razorback was sort of a next 6 generation version of the Banyon Income Fund that 7 Bekkedam had brought Von Allmen into? 8 A I don't recall. 9 Q That basically Razorback was lending -- that 10 A.J.'s group lent money to a Banyon enti
r TD Bank. In fact, the fictitious $8,000,000.00 wire is powerful evidence of the frenzied push by the Principal Conspirators, along with Levin and Preve, to do and say whatever was needed to secure investor funding as the Ponzi scheme began to unravel. Indeed, in their feverish zeal to induce Razorb
e had knowledge of a prior deficit and serves as an unwitting admission of their involvement in the perpetuation of the Ponzi scheme; d. Levin and Preve often claimed to be continuously "reinvesting" all principal and profits back into the Principal Conspirators' settlement scheme. Plaintiffs aver t
sary to sustain the Ponzi scheme over a period of four years; E. Ballamor and Bekkedaro 312. Plaintiffs have discovered relative to Ballamor and Bekkedam that: a. Bekkedam and Ballamor, in their role as investment advisors, induced client investments into the Rothstein Ponzi despite particular facts
Entities connected to both Preve and Bekkedam

George W. Bush
PERSONScott Rothstein
PERSONSpinosa
PERSON
Bradley Edwards
PERSON
Villegas
PERSONBanyon
ORGANIZATION
Clockwork
ORGANIZATION
Rosenfeldt
PERSON
Morocco
LOCATION
Jeffrey Epstein
PERSONSzafranski
PERSON
Lawrence Krauss
PERSONFrank Spinosa
PERSON
BROWARD COUNTY
LOCATION
TD Bank
ORGANIZATION
Barry Diller
PERSONthe Clifford Chance
PERSONthe Banyon Income Fund
ORGANIZATION
Bradley Cooper
PERSON
Adler
PERSON