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

November 11, 2009, contained the approximate amount of $10,085.00; (33A11)Toronto Dominion Bank, N.A. account 6860420923 in the name of Rothstein Rosenfeldt Adler, P.A, Attorney Trust Account 3, which, on or about November 11, ' 2009, contained the approximate amount of $720,892.08; (BA12)Toronto Dominion Ban

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

on or about November 11, 2009, ned the approximate amount of $10,085.00; dee (M11)Toronto Dominion Bank, N.A. account 6860420923 in of Rothstein Rosenfeldt Adler, P.A, Attorney Trust Account 3, which 2009, contained the approximate amount of $7 (BAI2)Toronto Dominion Bank, N.A. account Holding, which, on or

ached to this Notice as Exhibit A, and Edwards' clients' Appellee Brief filed in that case, attached to this Notice as Exhibit B. In Jane Doe No. 1, the United States Court of Appeals for the Eleventh Circuit held that Epstein's former counsel had waived the work- product privilege with respect to documents sought by Ed

F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settlement, the United States was undoubtedly adverse to Epstein during its investigation of him for federal offenses, and the intervenors' disclosure of their work product waiv

ection as to grand jury materials). Exhibit B, at 36 n.13. Epstein also files as Exhibit C the August 4, 2010, hearing transcript; In re Rothstein Rosenfeldt Adler, P.A., United States Bankruptcy Court, Southern District of Florida, Case No. 09- 34791-BKC-RBR, The following are statements made by William Scherer

se originate from a matter pending in the Central Region of the U.S. Attorney's Office prior to September 1, 2O07? — Yes _X_ No CO lo ASSISTA T UNITED STA ES ATTORNEY Flo Ida Bar No. A005500030 EFTA00193885 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 36 of 36 UNITED STATE

erms of the Non-Prosecution Agreement, the United States Attorney's Office for the Southern District of Florida hereby provides you with notice that the United States Attorney has determined, based on reliable evidence, that Jeffrey Epstein has willfully violated one of the conditions of the Non-Prosecution Agreem

t November 11, 2009, contained the approximate amount of $10,085.00; (BA11)Toronto Dominion Bank, N.A. account 6860420923 in the name of Rothstein Rosenfeldt Adler, P.A, Attorney Trust Account 3, which, on or about November 11, 2009, contained the approximate amount of $720,892.08; (BA12)Toronto Dominion Bank,

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

t November 11, 2009, contained the approximate amount of $10,085.00; (BA11)Toronto Dominion Bank, N.A. account 6860420923 in the name of Rothstein Rosenfeldt Adler, P.A, Attorney Trust Account 3, which, on or about November 11, 2009, contained the approximate amount of $720,892.08; (BAl2)Toronto Dominion Bank,

T IN A CRIMINAL CASE v. Case Number - 0:09CR60331-COHN-1 SCOTT W. ROTHSTEIN USM Number: 91256-004 Counsel For Defendant. Marc Nurik Counsel For The United Stales: Lawrence LaVecchio. Jeffrey Kaplan. and Paul Schwartz Coun Reporter: Tammy Nestor Thc defendant pleaded guilty to Counts 1, 2, 3, 4 and 5 of the

31-JIC Document 290 Entered on FLSD Dockot 06/09/201.0 P,go 1Q of 9Q (BAI()Toronto Dominion Bank, N.A. account 6860420923 in the name of Rothstein Rosenfeldt Adler, P.A, Attorney Trust Account 3, which, on or about November 11, 2009, contained the approximate amount of $720,892.08; (BA12)Toronto Dominion Bank,

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

t November 11, 2009, contained the approximate amount of $10,085.00; (BA11)Toronto Dominion Bank, N.A. account 6860420923 in the name of Rothstein Rosenfeldt Adler, P.A. Attorney Trust Account 3, which, on or about November 11, 2009, contained the approximate amount of $720,892.08; (BAl2)Toronto Dominion Bank,

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

t November 11, 2009, contained the approximate amount of $10,085.00; (BA11)Toronto Dominion Bank, N.A. account 6860420923 in the name of Rothstein Rosenfeldt Adler, P. A, Attorney Trust Account 3, which, on or about November 11, 2009, contained the approximate amount of $720,892.08; (BA12)Toronto Dominion Bank