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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
ertain of the named Defendants, which scheme directly impacted EPSTEIN as a named defendant in the Civil Actions. 19. Miami attorney and developer, Alan Sakowitz, was quoted in a November 2009 article as saying that he had met with,ROTHSTEIN as a potential investor in August.of 2009, but became suspicious. H
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
ertain of the named Defendants, which scheme directly impacted EPSTEIN as a named defendant in the Civil Actions. 19. Miami attorney and developer, Alan Sakowitz, was quoted in a November 2009 article as saying that he had met with ROTHSTEIN as a potential investor in August of 2009, but became suspicious. H
xner; (iii) Alan Dershowitz (noted constitutional attorney and one of EPSTEIN'S criminal defense attorneys); (iv)Bill Clinton (Former President of the Untied States); and EFTA00725330 Epstein v. RRA, et al. Page 13 (v) David Copperfield (illusionist). 39. The above-named individuals were friends of EPSTEIN
ress conferences. The most recent estimate of the financial scope of the scheme is as much as $1 billion dollars. 49. Miami attorney and developer, Alan Sakowitz, was quoted in a recent article as saying that he had met with ROTHSTEIN as a potential investor in August of 2009, but became suspicious. He state
witz (noted Harvard Law professor, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the Untied States); EFTA00725302 Epstein v. RRA, et al. Page 15 (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 48
ress conferences. The most recent estimate of the financial scope of the scheme is as much as $1 billion dollars. 30. Miami attorney and developer, Alan Sakowitz, was quoted in a recent article as saying that he had met with ROTHSTEIN as a potential investor in August of 2009, but became suspicious. He state
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
ertain of the named Defendants, which scheme directly impacted EPSTEIN as a named defendant in the Civil Actions. 19. Miami attorney and developer, Alan Sakowitz, was quoted in a November 2009 article as saying that he had met with ROTHSTEIN as a potential investor in August of 2009, but became suspicious. H
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
ertain of the named Defendants, which scheme directly impacted EPSTEIN as a named defendant in the Civil Actions. 19. Miami attorney and developer, Alan Sakowitz, was quoted in a November 2009 article as saying that he had met with ROTHSTEIN as a potential investor in August of 2009, but became suspicious. H
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
ertain of the named Defendants, which scheme directly impacted EPSTEIN as a named defendant in the Civil Actions, 19. Miami attorney and developer, Alan Sakowitz, was quoted in a November 2009. article as saying that he had met with, ROTHSTEIN as a potential investor in August of 2009, but became suspicious.
Entities connected to both United States and Alan Sakowitz

Jeffrey Epstein
PERSON
George W. Bush
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Marc Rich
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONMaria Farmer
PERSON
Samantha Power
PERSONSouthern District
LOCATION
Joe Biden
PERSON
Paul Cassell
PERSON
A. Marie Villafana
PERSON
the United States District Court
ORGANIZATIONRoy Black
PERSON