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

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

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

"pump" w money without any relevance to the existing cla y the RRA clients. 41 /4 I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

T SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson IN RE: JANE DOE, Petitioner. DECLARATION OF A. MARIE VILLAFARA IN SUPPORT OF UNITED STATES' RESPONSE 1Q/LCIM'jjiMERGENCirEIMDAEQREIEWICEMEMT QF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771 I. 1, A. Marie Villafatia, do hereby declare that I

ey Edwards (Exs. 6 & 7). A notification was not provided to ■. because the U.S. Attorney's modification limited Epstein's liability to victims whom the United States was prepared to name in an indictment. In light of ■.'s prior statements to law enforcement, your Affiant could not in good faith include ■. as a v

in"), by and through his undersigned counsel moves this court for clarification of the record regarding representations made by Plaintiffs counsel, William Berger, Esq., at the September 23, 2009 hearing on Plaintiffs Motion for Protective Order, and as grounds therefore, would state: 1. Plaintiffs counsel wa

LEX SINK; (C2) $40,000 IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA, "FLORIDA" ACCOUNT AND VOLUNTARILY OFFERED, AND TURNED OVER, TO 'HIE UNITED STATES BY THE REPUBLICAN PARTY OF FLORIDA, (C3) $10,000 IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA, "FEDERAL" ACCOUNT AND VOLUNTARILY OFFE

y Plaintiff and the law firm RRA. 3. All emails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or whic

, will take the video deposition of: NAME AJ DiScala DATE AND TIME PLACE Wednesday May 25, 2011 10:30 a.m. Dewey I,eBoeuf 1301 Avenue of the Americas New York, NY 10019 *The deponent has been instructed to bring with him all documents listed in Schedule A attached hereto. upon oral examination

Rothstein law firm regarding investment opportunities in any claim or litigation against Jeffrey Epstein: a) Scott Rothstein b) Russell Adler c) William Berger d) Bradley Edwards e) Michael Fisten f) Kenneth Jenne g) David Baden h) Deborah Villegas i) Andrew Barnett j) Patrick k) Richard (Rick) Fandr

are generally construed according to the principles of contract law, and the government, as drafter, must be held to an agreement's literal terms," United States 'Anglin, 215 F.3d 1064, 1066 (962 Cir, 2000). We believe Epstein has conformed to the Agreement's requirements and would welcome the opportunitytto m

33401-5913 Phone: Jeffrey H. Sloman, Esq. U.S. Attorney's Office-Southern District 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 William Berger, Esq. Attorney For: E.W. Rothstein Rosenfeldt Adler 401 E. Las Olas Blvd., Suite 1650 Ft. Lauderdale, FL 33394 Diana L. Maftin Florida Bar No.

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

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

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

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

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

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three