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

nt RP4," includes all buildings, improvements, fixtures, attachments and easements found therein or thereon, and is more particularly described as: Isla Bahia 47-27 B Lot 63 with a Folio Number of 5042 13 16 0640; (RP5) 29 Isla Bahia Drive, Fort Lauderdale, Florida, hereafter also referred to as "Defendan

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

dant hir 4," udes all buildings, improvements, fixtures, attachments and easements bu d therein or thereon, and is more particularly described as: Isla Bahia 47-27 B Lot 63 with a Folio Number of 5042 13 16 0640; 1RP5) 29 Isla Bahia Drive, Fort Lauderdale, Florida, hereafter also referred to as "Defendan

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

nt RP4," includes all buildings, improvements, fixtures, attachments and easements found therein or thereon, and is more particularly described as: Isla Bahia 47-2713 Lot 63 with a Folio Number of 5042 13 16 0640; (RP 5) 29 Isla Bahia Drive, Fort Lauderdale, Florida, hereafter also referred to as "Defenda

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

nt RP4," includes all buildings, improvements, fixtures, attachments and easements found therein or thereon, and is more particularly described as: Isla Bahia 47-27 B Lot 63 with a Folio Number of 5042 13 16 0640; (RP5) 29 Isla Bahia Drive, Fort Lauderdale, Florida, hereafter also referred to as "Defendan

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

nt RP4," includes all buildings, improvements, fixtures, attachments and easements found therein or thereon, and is more particularly described as: Isla Bahia 47-27 B Lot 63 with a Folio Number of 5042 13 16 0640; (RP5) 29 Isla Bahia Drive, Fort Lauderdale, Florida, hereafter also referred to as "Defendan

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

Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 20 of 36 found therein or thereon, and is more particularly described as: Isla Bahia 47-27 B Lot 35 with a Folio Number of 5042 13 16 0360; (RP6) 350 SE 2nd Street, Unit 2840, Port Lauderdale, Florida, hereafter also referred to as