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n of the firm and an accounting pursuant to Florida Statutes Section 607.1430(3). Additionally, Plaintiffs seek transfer of all corporate powers to Plaintiff Rosenfeldt, or, in the alternative, the appointment of Plaintiff Rosenfeldt as custodian of the firm or the appointment of a receiver, pursuant to Florida Stat
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
n of the firm and an accounting pursuant to Florida Statutes Section 607.1430(3). Additionally, Plaintiffs seek transfer of all corporate powers to Plaintiff Rosenfeldt, or, in the alternative, the appointment of Plaintiff Rosenfeldt as custodian of the firm or the appointment of a receiver, pursuant to Florida Stat
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
utes Section 60 3). Additionally, Plaintiffs seek transfer of all corporate powers to Plaintiff Rom dt, or, in the alternative, the appointment of Plaintiff Rosenfeldt as custodian of or the appointment of a receiver, pursuant to Florida Statutes Sections 607.193 17.1432. Plaintiff Rosenfeldt is the firm's pres
• 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
n of the firm and an accounting pursuant to Florida Statutes Section 607.1430(3). Additionally, Plaintiffs seek transfer of all corporate powers to Plaintiff Rosenfeldt, or, in the alternative, the appointment of Plaintiff Rosenfeldt as custodian of the firm or the appointment of a receiver, pursuant to Florida Stat
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 Plaintiff Rosenfeldt and The General Allegations

United States
LOCATIONLeon Black
PERSONthe Southern District
LOCATIONFlorida Bar
ORGANIZATION
Jeffrey Epstein
PERSONScott Rothstein
PERSON
George W. Bush
PERSON
the Cayman Islands
LOCATION
Morocco
LOCATIONFederal LLC
ORGANIZATION
Charlie Crist
PERSON
South Florida
LOCATION
Kenneth Marra
PERSON
TD Bank
ORGANIZATION
Fort Lauderdale
LOCATION
Maine
LOCATION
Joe Biden
PERSON
Venezuela
LOCATION
Adler
PERSON
Poland
LOCATION