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ow, trust, and operating accounts. Despite the grossly inordinate amount of funds being rapidly wired in and out of RRA's accounts held at two local South Florida branches, these suspicious account activities inexplicably circumvented several fraud-risk tripwires and avoided detection by TD Bank's internal ba
ntiffs for their damages. 9. Furthermore, as alleged in detail infra, the Principal Conspirators' inner-circle of facilitators (TD Bank, Spinosa, Kerstetter, Caretsky, Gibraltar Bank, Berenfeld, Weintraub, Berkowitz, Leitstein, Levin, Preve, Banyon entities, Szafranski, Onyx, Villegas, Boden, Barnett, S
, v. Scott W. Rothstein, et at Complex Litigation Division - Case No.: 09-062943 (19) Third Amended Complaint a. March 20, 2009, letter signed by Kerstetter enclosing RRA trust/escrow account statements for: i. account number 6860699146 showing a balance of $104,211,711.22; ii. account number 6860420
ing in Broward County, Florida and, at all times relevant hereto, was acting within the scope of her employment as an assistant manager for TD Bank. Kerstetter contributed to the scheme by, among other things, making material misrepresentations in meeting with investors, providing falsified account stateme
t time you joined the fire and through the end of October of 2009, how would you describe the perception of the firm, the firm's reputation in the South Florida legal community? A I think it was in very high regard by the legal community. When I joined the firm, I looked up ea the Internet, articles about
who does it sue -- who does he sue? 13 A Scott Rothstein, David Roden, Debra 'Allegan, 14 Andrew Barnett, TO Bank, Frank Spinoaa, Jennifer IS Kerstetter, Rosanne Caretsky and Frank Prove. 14 Q And Mr. Rothstein was the chairman of the 17 Rothstein firm? IS A On November 20, 2009, I don't beli
t all these defendants. The Rothstein racketeering enterprise endeavored to compromise the core values of both state and federal justice systems in South Florida and to vindicate the hardworking and honest lawyers and their clients who were adversely affected by the misconduct that is the subject of this Com
mplaint against ROTHSTEIN, David Boden, Debra Villegas, Andrew Bamett, TD Bank, N.A., Frank EFTA00193822 Epstein I RRA, et al. Page 9 Spinosa, Kerstetter, Rosanne Caretsky and Frank Preve asserting various allegations that further prove the massive Ponzi scheme behind the RRA facade; and as of Novemb
t all these defendants. The Rothstein racketeering enterprise endeavored to compromise the core values of both state and federal justice systems in South Florida and to vindicate the hardworking and honest lawyers and their clients who were adversely affected by the misconduct that is the subject of this Com
mplaint against ROTHSTEIN, David Baden, Debra Villegas, Andrew Barnett, TD Bank, N.A., Frank EFTA00223275 Epstein RRA, et al, Page 9 Spinosa, Kerstetter, Rosanne Caretsky and Frank Preve asserting various allegations that further prove the massive Ponzi scheme behind the RRA facade; and as of Novemb
Entities connected to both South Florida and Kerstetter

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