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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
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
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
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
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
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
Entities connected to both South Florida and Toronto Dominion Bank

Jeffrey Epstein
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
Bill Clinton
PERSONLeon Black
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSONScott Rothstein
PERSONthe Southern District
LOCATION
Joe Biden
PERSON
Kenneth Marra
PERSON
Palm Beach County
LOCATION
Boca Raton
LOCATION
Broward County
LOCATION
Samantha Power
PERSON