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Liability Company, by its manager, Bahia Property IS,agement, LLC, a Delaware Limited Liability Company, by its co-manager, Scott Rothstein; (B12) Scott W. Rothstein's equity interest in QTask; frW.i (313) Scott W. Rothstein's equity interest in Broward Bank erce; (814) Scott W. Rothstein's equity interest in Bov
thereafter through in or about November 2009, \ \\;\ in Broward County, in the Soutite \District of Florida and elsewhere, the defendant, /SCOTT W. ROTHSTEIN, 1,1eZNIK did knowingly conspi federate, and agree with persons known and unknown to the United States Atto mmit offenses against the United Sta
se of Conspiracy to Commit Mail Fraud and Wire Fraud and to 't re Fraud as set forth in Counts 3, 4, and 5 of the Information, the defendant, S . OTHSTEIN, shall forfeit to the United States, all property, real or personal, which eons! tes or is derived from proceeds traceable to the offense. 5. The
ffices in Florida, Cv York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-85'15. RRA, through its attorneys, including those named as Defendant n, conducted business throughout Florida, and relevant to thi
A is currently a debtor in bankruptcy. RRA is not named as a Defendant). FACTUAL ALLEGATIONS 9. The United States in United States of America I Scott W. Rothstein, Case No. 09-60331CR-Cohn, United States District Court, Southern District of Florida, has brought an action for Racketeering Conspiracy, 18 U.S.C.
icle or other commodity. THE ROLES AND RESPONSIBILITIES OF THE CONSPIRATORS 7. The roles of the conspirators were as follows: A. Defendant scorr W. ROTHSTEIN was a shareholder, Chairman and CEO of RRA. Through his position at RRA, defendant ROTHSTEIN promoted, managed, and supervised the administration o
hn, United States District Court, Southern District of Florida, has brought an action for Racketeering Conspiracy, 18 U.S.C. § 1962(d) against Scott.W. Rothstein who was the chief executive officer and chairman of RRA. Within the information which was filed, the United States of America has identified the ent
fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to
r third party investors to invest in any plaintiffs case against Jeffrey Epstein 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any plaintiffs case. 7. All investment packages, or information, settlement agreeme
orated Memorandum of Law Page 4 of9 7. Miami attorney and developer, Alan Sakowitz, was quoted in a recent article as saying that he had met with Rothstein as a potential investor in August of 2009, but became suspicious. He stated "I was convinced it was all a Ponzi scheme and I notified the FBI in de
In each of these civil actions, each of the Plaintiffs is represented by Bradley J. Edwards, William Berger and the RRA law firm, 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. Attorneys Russell Alder and Peter Feaman have also appeared for the Plaintiffs. 4. Based upon recent and ongoing media repor
ential investor in August of 2009, but became suspicious. He stated "I was convinced it was all a Ponzi scheme and I notified the FBI in detail how Scotty ROTHSTEIN was hiding behind a legitimate law firm to peddle fake investments." Attorney Sakowitz was also quoted as saying ROTHSTEIN had sophisticated eavesd
ey claim a lack of knowledge when: a. The firm had 24 hour security in the form of Broward County Sheriff's officers on each floor of the offices; b. ROTHSTEIN had 24 hour (firm paid) security at his home; c. Partners/attorneys/staff could not directly access ROTHSTEIN without going through extensive secur
employed over 70 attorneys and 200 support staff. RRA also maintains EFTA00725322 Epstein v. RRA, et al. Page 5 an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to
ential investor in August of 2009, but became suspicious. He stated "I was convinced it was all a Ponzi scheme and I notified the FBI in detail how Scotty ROTHSTEIN was hiding behind a legitimate law firm to peddle fake investments." Attorney Sakowitz was also quoted as saying ROTHSTEIN had sophisticated eavesd
problems with the firm existed when: a. RRA had 24 hour security in the form of Broward County Sheriffs officers on each floor of the law offices; b. ROTHSTEIN had 24 hour (firm paid) security at his home; c. Partners/attorneys/staff could not directly access ROTHSTEIN without going through extensive secur
employed over 70 attorneys and 200 support staff. RRA also maintains EFTA00725294 Epstein v. RRA, et al. Page 7 an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to
(RRA is currently a debtor in bankruptcy. RRA is not named as a Defendant). FACTUAL ALLEGATIONS 9. The United States in United States of America'. Scott W. Rothstein, Case No. 09-60331CR-Cohn, United States District Court, Southern District of Florida, has brought an action for Racketeering Conspiracy, 18 U.S.C.
d L.M., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and prof
fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to
ability Company, by its manager, Bahia Property Management, LLC, a Delaware Limited Liability Company, by its co-manager, Scott W. Rothstein; (312) Scott W. Rothstein's equity interest in QTask; (B13) Scott W. Rothstein's equity interest in Broward Bank of Commerce; (1314) Scott W. Rothstein's equity interest in Bo
d L.M., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and prof
fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to
ability Company, by its manager, Bahia Property Management, LLC, a Delaware Limited Liability Company, by its co-manager, Scott W. Rothstein; (Bt2) Scott W. Rothstein's equity interest in QTask; (BD) Scott W. Rothstein's equity interest in Broward Bank of Commerce; (BM) Scott W. Rothstein's equity interest in Bova
and E., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and prof
fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to
ability Company, by its manager, Bahia Property Management, LLC, a Delaware Limited Liability Company, by its co-manager, Scott W. Rothstein; (BI2) Scott W. Rothstein's equity interest in QTask; (313) Scott W. Rothstein's equity interest in Broward Bank of Commerce; (B14) Scott W. Rothstein's equity interest in Bov
ive billion-dollar conspiracy created and run by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad Edwards, and others with tortuous and fraudulent abuses of process that resulted in serious injury to Mr. Epstein. A copy of the
fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to
Entities connected to both Scott Rothstein and Hallendale Beach

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSONRobert D. Critton
PERSON
Donald Trump
PERSONRothstein Rosenfeldt Adler
ORGANIZATIONMichael J. Pike
PERSON
Prince Andrew
PERSON
United States
LOCATION
Bill Clinton
PERSONLeon Black
PERSON
Marc Rich
PERSONthe Southern District
LOCATION
Palm Beach County
LOCATION
Lauderdale
LOCATION
Adler
PERSON