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

3304 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12101/2009 Page 2 of 36 COUNT 1 (Racketeering Conspiracy, 18 U.S.C. §1962(d)) 1. The General Allegations of this Information are realleged and expresslyincorporated herein as if set forth in full. THE ENTERPRISE 2. The law firm, Rothstein, Rosenfeldt and Adler, Y.A. (he

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

5624 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 2 of 36 COUNT I (Racketeering Conspiracy, 18 U.S.C. §I 962(d)) 1. The General Allegations of this Information are realleged and expressly incorporated herein as if set forth in full. THE ENTERPRISE 2. The law firm, Rothstein, Rosenfeldt and Adler, P.A. (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

525 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 2 of 36 COUNT 1, (Racketeering Conspiracy, 18 U.S.C. §1962(d)) 1. The General Allegations of this Information are realleged and expressly incorporated herein as if set forth in full. THE ENTERPRISE 2. The law firm, Rothstein, Rosenfeldt and Adler, P.A. (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

a wide range of specialties, including labor and employment law. can f EFTA00683125 COUNT 1 (Racketeering Conspiracy, 18 U.S.C. § 1962(d)) 1. The General Allegations of this Information are real leged and expressly incorporated herein as if set forth in full. THE ENTERPRISE 2. The law firm, Rothstein, Rosenfeldt and Adler, P.A. (

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

3851 Case 0:09-cr-60331-JIC Document 1 Entered on FLSD Docket 12/01/2009 Page 2 of 36 COUNT 1 (Racketeering Conspiracy, 18 U.S.C. §1962(d)) 1. The General Allegations of this Information are realleged and expressly incorporated herein as if set forth in full. THE ENTERPRISE 2. The law firm, Rothstein, Rosenfeldt and Adler, P.A. (h