Epstein Secrets

Razorback Funding, LLC, et at, v. Scott W. Rothstein, et at Complex Litigation Division - Case No.: 09-062943 (19) Third Amended Complaint By ignoring evidence of the Principal Conspirators' miscondu

Plaintiffs have discovered, relative to Levin, Preve, and Banyon, that: a. an $8,000,000.00 wire transfer confirmation used by Levin, Preve, and Rothstein to induce Razorback's $32,000,000.00 payment was never received by RRA or TD Bank. In fact, the fictitious $8,000,000.00 wire is powerful evidence

and has not been returned. Specific examples of Gibraltar Bank's overt acts, assistance and/or omissions in furtherance of the conspiracy include: a. Rothstein learned early in his scheme that he could not convince wealthy investors to give him money unless he established relationships with financial insti

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

UIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: 09-062943 07 RAZORBACK FUNDING, LLC, et al, Plaintiffs, vs. SCOTT W. ROTHSTEIN, et al, Defendants. DAY 8 - AFTERNOON SESSION DEPOSITION OF SCOTT W. ROTHSTEIN DATE TAKEN: TIME: PLACE: Wednesday, December 21, 2011 1:00 p.m

k was taken.) 11 (Whereupon, The Funds' Exhibit No. 261 was 12 marked for identification.) 13 BY MR. LAUER: 14 Q Okay. I am handing you, Mr. Rothstein, 15 Exhibit 261, which is a photostatic copy of Confidential 16 Settlement Agreement and Release. It bears production 17 PRODA 21183 through 21

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

UIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: 09-062943 07 RAZORBACK FUNDING, LLC, et al, Plaintiffs, vs. SCOTT W. ROTHSTEIN, et al, Defendants. DAY 8 - AFTERNOON SESSION DEPOSITION OF SCOTT W. ROTHSTEIN DATE TAKEN: TIME: PLACE: Wednesday, December 21, 2011 1:00 p.m

k was taken.) 11 (Whereupon, The Funds' Exhibit No. 261 was 12 marked for identification.) 13 BY MR. LAUER: 14 Q Okay. I am handing you, Mr. Rothstein, 15 Exhibit 261, which is a photostatic copy of Confidential 16 Settlement Agreement and Release. It bears production 17 PRODA 21183 through 21

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

, STEVEN ZARETSKY as Trustee of the JANE ZARETSKY DYNASTY TRUST, LAWRENCE E. DEKELBAUM, AND SHALOM STRICTLY KOSHER MEATS, INC., Plaintiffs, v. SCOTT W. ROTHSTEIN, DAVID BODEN, DEBRA VILLEGAS, ANDREW BARNETT, IRENE STAY, TD BANK, N.A., FRANK A. SPINOSA, JENNIFER KERS 1 El 1 ER, ROSANNE CARETSKY, BANYON I

943 (19) Third Amended Complaint II. Overview 2. This action arises out of a fraudulent scheme orchestrated by Scott W. Rothstein (hereinafter, "Rothstein"), who admittedly bilked investors out of hundreds of millions of dollars in what has come to be known as the largest financial fraud in Florida his

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 &

UIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: 09-062943 07 RAZORBACK FUNDING, LLC, et al, Plaintiffs, vs. SCOTT W. ROTHSTEIN, et al, Defendants. DAY 1 - AFTERNOON SESSION DEPOSITION OF SCOTT ROTHSTEIN DATE TAKEN: TIME: PLACE: Monday, December 12, 2011 1:00 p.m. - 5:

FUNDING, LLC, et al, Plaintiffs, vs. SCOTT W. ROTHSTEIN, et al, Defendants. DAY 1 - AFTERNOON SESSION

22 23 24 25 Page 58 funds that were supposed to be held in trust? A It was simply what Frank and I had -- the whole reason it stayed in, Mr. Preve and I discussed from time to time the fact that anything we could do to add additional levels of security for the investors was good. So, it staye

, STEVEN ZARETSKY as Trustee of the JANE ZARETSKY DYNASTY TRUST, LAWRENCE E. DEKELBAUM, AND SHALOM STRICTLY KOSHER MEATS, INC., Plaintiffs, v. SCOTT W. ROTHSTEIN, DAVID BODEN, DEBRA VILLEGAS, ANDREW BARNETT, IRENE STAY, TD BANK, N.A., FRANK A. SPINOSA, JENNIFER ICERSTETTER, ROSANNE CARETSKY, BANYON INCOM

sing from the same set of operative facts as the Jane Doe case, but involving a different underage female plaintiff To bolster his concocted story, Rothstein invited D3 representatives to his office to view the thirteen banker's boxes of actual case files in Jane Doe in order to demonstrate that the claim

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 &