Epstein Secrets

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

y spent time asking me about the lock letters 20 at the point in time we were utilizing them and the 21 mechanics, and I had to refer them to Mr. Spinosa to 22 answer that question. 23 They asked me about my history with other 24 investors, Thane Ritchie. I don't remember, again, 25 whether it

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

y spent time asking me about the lock letters 20 at the point in time we were utilizing them and the 21 mechanics, and I had to refer them to Mr. Spinosa to 22 answer that question. 23 They asked me about my history with other 24 investors, Thane Ritchie. I don't remember, again, 25 whether it

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 &

udulent conduct alleged herein while willfully ignoring and/or failing to exercise reasonable care. 46. Defendant, FRANK A. SPINOSA (hereinafter, "Spinosa"), is an individual residing in Broward County, Florida and, at all times relevant hereto, was acting within the scope of his employment as a senio

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

ssly allowed itself to become a conduit for these activities and, accordingly, is liable for its participation; m. in late November, TD Bank fired Spinosa; B. Levin, Preve and Banyon 309. Plaintiffs have discovered, relative to Levin, Preve, and Banyon, that: a. an $8,000,000.00 wire transfer conf

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 &

he Razorback transaction. 162. On or about October 15, 2009, as part of its due diligence, D3 obtained a copy of a TD Bank "lock letter" signed by Spinosa stating the following: Pursuant to your written instructions to us of October 14, 2009, please be advised that all funds contained in the above ref