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525 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 2 of 36 COUNT 1, (Racketeering Conspiracy, 18 U.S.C. §1962(d)) 1. The General Allegations of this Information are realleged and expressly incorporated herein as if set forth in full. THE ENTERPRISE 2. The law firm, Rothstein, Rosenfeldt and Adler, P.A. (h
iry concerning Defendant Rothstein's conduct, and to make appropriate recommendations to the Court concerning any further investigation. Misuse of the Investor Trust Accounts 14. With respect to the settlement funding scenario, Plaintiffs only recently discovered troubling information concerning Defendant Rothstein's in
5624 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 2 of 36 COUNT I (Racketeering Conspiracy, 18 U.S.C. §I 962(d)) 1. The General Allegations of this Information are realleged and expressly incorporated herein as if set forth in full. THE ENTERPRISE 2. The law firm, Rothstein, Rosenfeldt and Adler, P.A. (h
iry concerning Defendant R in's conduct, and to make appropriate recommendations to the Court \/ conceinaig any further investigation. Misuse of the Investor Trust Accounts y 14. With respect to the settlement funding scenario, Plaintiffs only recently discovered troubling information concerning Defendant Rothstein's
3304 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12101/2009 Page 2 of 36 COUNT 1 (Racketeering Conspiracy, 18 U.S.C. §1962(d)) 1. The General Allegations of this Information are realleged and expresslyincorporated herein as if set forth in full. THE ENTERPRISE 2. The law firm, Rothstein, Rosenfeldt and Adler, Y.A. (he
iry concerning Defendant Rothstein's conduct, and to make appropriate recommendations to the Court concerning any further investigation. Misuse of the Investor Trust Accounts 14. With respect to the settlement funding scenario, Plaintiffs only recently discovered troubling information concerning Defendant Rothstein's in
Entities connected to both The General Allegations of this Information and the Investor Trust Accounts

United States
LOCATIONLeon Black
PERSON
Jeffrey Epstein
PERSONFlorida Bar
ORGANIZATIONthe Southern District
LOCATIONScott Rothstein
PERSON
George W. Bush
PERSON
the Cayman Islands
LOCATION
Morocco
LOCATIONCherry Hill
LOCATION
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