Epstein Secrets

e less than $5,000,000.00; 10. That this Court has jurisdiction over said assets as they originated in the United States; That the treaties between the United Stales and the Cayman Islands and related governments clearly establishes the right of the United Slates to seize such assets. That counsel for MORSE has

d to as RRA) was a legal entity organized under the laws of the State of Florida and constituted an Enterprise as that term is defined in Title 18, United States Cod; Section 1961(4). The Enterprise engaged in, and the activities of which affected, interstate and foreign commerce. THE RACKETEERING CONSPIRACY 3.

t of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the United States Attorney, to commit offenses against the United States in violation of Title 18, United States Code, Sections 1956 and I957, that is: i. to knowing

d in the United States; That the treaties between the United Stales and the Cayman Islands and related governments clearly establishes the right of the United Slates to seize such assets. That counsel for MORSE has facilitated the contact between the relative governments and as a Page 2 of 6 EFTA00223350 resu

offices in thirteen (13) states, including a branch office in Weston, Florida. The executive offices of TI) Bank were located in Portland, Maine and Cherry Hill; New Jersey. Defendant ROTHSTEIN and RRA maintained approximately thirty-eight (38) bank accounts at T13 Bank, which were utilized during the cours

as a Page 2 of 6 EFTA00795670 result,. this Court has received clear and convincing evidence that such funds will be immediately transferred to the United Stales: 12. That the Clerk of Court is hereby directed to immediately submit the proper A documentation to the appropriate bank of the Cayman Islands to

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 States in violation of Title 18, United States Code1S 1956 and 1957, that is: i. to knowingly conduct and a

ation of Title 18, United States Code, Selo 34 and 1343, in violation of Title 18, United States Code, Section 1957. All in violation of Title 18, United Sta ection I 956(h). (Mail and Wi ud C nspiracy, 18 U.S.C. §1349) 1. The General All d paragraphs 5 through 40 of Count I of the Information are r

ranch offices in thirteen (13) states, including a branch office in Weston, Florida1 e utive offices of TD Bank were located in Portland, Maine and Cherry Hill, Ne Defendant ROTHSTEIN and RRA maintained approximately thirty-eight (38) nk a ts at TD Bank, which were utilized during the course of the "Pon

able through Title 28, United States Code, Section 2461; and the procedures outlined at Title 21, United States Code, Section 853. JEFFRE H. 3 OMA UNITED STATES AU' EY / 4ft . aUr-1 PAUL F. SCHWARTZ ASSISTANT UNITED STATES ATTORNEY 3 F R N. KAPLAN ASSISTANT UNITED STATES ATTORNEY E D. VECCHIO SISTANT UN

rict of Florida and elsewhere, the defendant, DEBRA VILLEGAS, did knowingly conspire, confederate and agree, with persons known and unknown to the United States Attorney, to commit an offense against the United States in violation of Title 18, United States Code, Section 1957, that is, to knowingly engage an

ch offices in thirteen 13 states, including a branch office in Weston, Florida. The executive offices of TD Bank were located in Portland, Maine and Cherry Hill, New Jersey. RRA maintained EFTA00641478 multiple bank accounts at TD Bank which were utilized during the course of the "Ponzi" scheme, detailed

t of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the United States Attorney, to commit offenses against the United States in violation of Title 18, United States Code, Sections 1956 and 1957, that is: i. to knowing

offices in thirteen (13) states, including a branch office in Weston, Florida. The executive offices of TD Bank were located in Portland, Maine and Cherry Hill, New Jersey. Defendant ROTHSTEIN and RRA maintained approximately thirty-eight (38) bank accounts at TD Bank, which were utilized during the course

t of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the United States Attorney, to commit offenses against the United States in violation of Title 18, United States Code, Sections 1956 and 1957, that is: i. to knowing

offices in thirteen (13) states, including a branch office in Weston, Florida. The executive offices of TD Bank were located in Portland, Maine and Cherry Hill, New Jersey. Defendant ROTHSTEIN and RRA maintained approximately thirty-eight (38) bank accounts at TD Bank, which were utilized during the course

t of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the United States Attorney, to commit offenses against the United States in violation of Title 18, United States Code, Sections 1956 and 1957, that is: i. to knowing

offices in thirteen (13) states, including a branch office in Weston, Florida. The executive offices of TD Bank were located in Portland, Maine and Cherry Hill, New Jersey. Defendant ROTHSTEIN and RRA maintained approximately thirty-eight (38) bank accounts at TD Bank, which were utilized during the course

t of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons knowp and unknown to the United States Attorney, to commit offenses against the United States in violation of Title 18, United. States Code, Sections 1956 and 1957, that is: i. to knowin

offices in thirteen (13) states, including a branch office in Weston, Florida. The executive offices of TD Bank were located in Portland, Maine and Cherry Hill; New Jersey. Defendant ROTHSTEIN and RRA maintained approximately thirty-eight (38) bank accounts at TD Bank, which were utilized during the course

of four offenses: murder and nonnegligent manslaughter, forcible rape, robbery, and aggravated assault." "Violent Crime," Crime in the United States, 2004, at http://www.fbi.gov/ucr/cius 04/offenses reported/violent crime/index.html. 07/26/17 Page 20 of 131 Public Records Request No.: 17-295

r jurisdictions' zoning laws currently restrict such individuals from living within 1000 feet of these institutions, were they to follow the lead of Cherry Hill, New Jersey, the client would most certainly be faced with the added burdens of selling his residences and moving in order to be in compliance with