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e of these potentially explosive facts, putative defendant Epstein had allegedly offered $200,000,000.00 for settle
involved herein was based upon facts surrounding Jeffrey Epstein, the infamous billionaire financier. In f
t fraudulent, were based on actual cases being handled by RRA. For example, one of the settlements involved herein was based upon facts surrounding Jeffrey Epstein, the infamous billionaire financier. In fact, RRA did have inside information due to its representation of one of Epstein's alleged victims in a civ
facts surrounding Jeffrey Epstein, the infamous billionaire financier. In fact, RRA did have inside information due to its representation of one of Epstein's alleged victims in a civil case styled Jane Doe v. Jeffiv Epstein, currently pending in the Southern District of Florida. Representatives of D3 w
inancier. In fact, RRA did have inside information due to its representation of one of Epstein's alleged victims in a civil case styled Jane Doe v. Jeffiv Epstein, currently pending in the Southern District of Florida. Representatives of D3 were offered "the opportunity" to invest in a pre-suit, $30,000,000.00
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
t fraudulent, were based on actual cases being handled by RRA. For example, one of the settlements involved herein was based upon facts surrounding Jeffrey Epstein, the infamous billionaire financier. In fact, RRA did have inside information due to its representation of one of Epstein's alleged victims in a civ
facts surrounding Jeffrey Epstein, the infamous billionaire financier. In fact, RRA did have inside information due to its representation of one of Epstein's alleged victims in a civil case styled Jane Doe v. Jefrey Epstein, currently pending in the Southern District of Florida. Representatives of D3 w
e of these potentially explosive facts, putative defendant Epstein had allegedly offered $200,000,000.00 for settle
involved herein was based upon facts surrounding Jeffrey Epstein, the infamous billionaire financier. In f
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
million settlement of an underage woman who had settled the claim United Reporting, Inc. (954) 525- 2221 EFTA00314946 Page 2246 1 against Mr. Epstein? 2 A I don't recall specifically. But if you show me 3 the paperwork, it will refresh my recollection. I just 4 don't recall the terms of that
te Delivery Systems? 5 MR. SCHERER: Object to form. 6 A No, but they did ask me what Elite Delivery 7 Systems were if I'm settling a case with Jeff Epstein. B Q And presumably you told them it was an Epstein 9 front or something like that? 10 A Correct. 11 Q We've got the idea, but did they te
) 525- 2221 EFTA00314946 Page 2246 1 against Mr. Epstein? 2 A I don't recall specifically. But if you s
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
t of an underage woman who had settled the claim United Reporting, Inc. (954) 525- 2221 EFTA_R1_00015705 EFTA01735045 Page 2246 1 against Mr. Epstein? 2 A I don't recall specifically. But if you show me 3 the paperwork, it will refresh my recollection. I just 4 don't recall the terms of that
Elite Delivery Systems? MR. SCHERER: Object to form. 6 A No, but they did ask me what Elite Delivery 7 Systems were if I'm settling a case with Jeff Epstein. 8 Q And presumably you told them it was an Epstein 9 front or something like that? 10 A Correct. 11 Q We've got the idea, but did they te
R1_00015705 EFTA01735045 Page 2246 1 against Mr. Epstein? 2 A I don't recall specifically. But if you s
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
Entities connected to both Jeffrey Epstein and Spinosa

Prince Andrew
PERSON
Woody Allen
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
Lawrence Krauss
PERSONJane Doe
PERSON
Barry Diller
PERSONthe Southern District
LOCATION
Bradley Cooper
PERSONScott Rothstein
PERSON
Michael Douglas
PERSON
Morocco
LOCATION
South Florida
LOCATIONFlorida Bar
ORGANIZATION
TD Bank
ORGANIZATION
Adler
PERSONLevin
PERSON
Rosenfeldt
PERSONSavage
ORGANIZATIONWhereupon
ORGANIZATION