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PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. 50 2009 CA 0 h 03 \MCCOMB COPY RECEIVED FOR FILING oic 0 1Mg EMIVION It PUCK COMPLAINT Gl
nt, ROTHSTEIN and Stuart Rosenfeldt, are and were the principal owners of equity in RRA and each co-founded RRA. 6. Defendant, BRADLEY J. EDWARDS ("EDWARDS"), is an individual residing in Broward County, Florida and is licensed to practice law in the State of Florida. At all times relevant hereto, EDWA
etoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing th
Caput', up to the amount of $1,000,000; 25 EFTA00596549 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 26 of 36 (BA9) Toronto Dominion Bank, N.A. account 6860291266 in the name of Rothstein Rosenfeldt Adler, P.A. which, on or about November 11, 2009, contained the approximate amount of
PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defendants. 50 2009 CA 0 b 0 3 MOUE 4) COPY RECEIVED FOR HUNG DEC u ( 2008 sriesnoN Ii poCK COMPLAINT p
nt, ROTHSTEIN and Stuart Rosenfeldt, are and were the principal owners of equity in RRA and each co-founded RRA. 6. Defendant, BRADLEY J. EDWARDS ("EDWARDS"), is an individual residing in Broward County, Florida and is licensed to practice law in the State of Florida. At all times relevant hereto, EDWA
etoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing th
aputi, up to the amount of $1,000,000; 25 EFTA00729464 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 26 of 36 (BA9) Toronto Dominion Bank, N.A. account 6860291266 in the name of Rothstein Rosenfeldt Adler, P.A. which, on or about November 11, 2009, contained the approximate amount of
ET as Trustee of the IRA SOCHET REVOCABLE INTER VIVOS TRUST, INVESTORS RISK ADVANTAGE, LP, SUSSCO, INC., EDWARD PALEY, FLORENCE PALEY, THE EDWARD AND FLORENCE PALEY FOUNDATION, STEVEN PALEY, LAURA PALEY, JANE ZARETSKY, STEVEN ZARETSKY as Trustee of the JANE ZARETSKY DYNASTY TRUST, LAWRENCE
classic Ponzi scheme.2 3. The Principal Conspirators, however, did not act alone. Defendant TD Bank, N.A. (hereinafter, "TD Bank"), a subsidiary of Toronto Dominion Bank, was complicit in this scheme, serving as a critical lynchpin "legitimizing" the Principal Conspirators' plot and providing crucial inducements to
Entities connected to both Bradley Edwards and Toronto Dominion Bank

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONScott Rothstein
PERSON
George W. Bush
PERSON
United States
LOCATIONSouthern District
LOCATION
Prince Andrew
PERSONLeon Black
PERSONthe Southern District
LOCATION
Donald Trump
PERSONMichael J. Pike
PERSON
Department of Justice
ORGANIZATION
Bill Clinton
PERSON
Marc Rich
PERSON
Joe Biden
PERSON
Palm Beach County
LOCATIONRothstein Rosenfeldt Adler
ORGANIZATIONCourtney Wild
PERSON