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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
mpf, PA EFTA00223267 'THE CIRCUIT COURT QF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA &WHEYSett* Plaintiff; v. Complex Litigation, Fla: k cht Pro. 1201 CASE NO. pn 50 2009CAO' -1Oe)"4B SCOTT ROTHSTEIN, indliricluallYt BRADLEY J. EDWARDS, Individually, and L;,M;,. Individua
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
owder's'. Miami TT 200 South Biscayne Boulevard Suite 1000 Miami, Florida 33131-5308 Telephone 306.766.9600 Facsimile 306.714.4340 EFTA00725165 Complex Litigation, Fla. R. Civ. P. 1.201 and has various professionals whose employment have been approved by the United States Bankruptcy County. 4 . Additionally
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
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, STUART ROSENFELDT, individuall
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
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, STUART ROSENFELDT, individually, RUSSELL ADLER, individually, B
, 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
TY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY .1. EDWARDS, individually, and.., individually, Defendants. Complex Litigation, Fla. R. Civ. Pro.1201 Case No. 50 2009CA040800XXXXMB AG RE-NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM TO: All Counsel of Record PLEASE TAKE
in, 495 So. 2d at 262; Alachua Gen. Hosp. v. Zimmer USA, Inc., 403 So. 2d 1087, 1088 (Fla. 1st DCA 1981) (privilege continues after case concludes); United States v. International Business Machs. Corp., 66 F.R.D. 154, 178 (S.D.N.Y.1974) (privilege applies only if the work product was gathered in anticipation o
334011 (561) 802-9044 EFTA00606625 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.120 I Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M
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
EXHIBIT A EFTA00596488 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defen
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
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defenda
do not hesitate to contact me. Sincerely, United States Attorney By: Assistant United States Attorney EFTA00233096 U.S. Department of Justice United Slates Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: Direct Dial: September 6, 2007
Member Dershowitz Ei er & Adelson, P.C. NM= ew York Co. Telephone: Fax: Email: e mail AY Peer Review Rated Practice Areas: Criminal Appeals; Complex Litigation; Civil Litigation; Post-Conviction Remedies Admitted: 1966, New York Law School: New York University, LL.B., 1966 College: Brooklyn College of th
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Ghislaine Maxwell
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ORGANIZATIONthe Southern District
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