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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
stein's equity interest in Edify LLC; (B111) Scott W. Rothstein's equity interest in, Georgio Vodka; (3112) Scott W. Rothstein's equity interest in Sea Club; (B113) Scott W. Rothstein's equity interest in North Star Mortgage; (BI14) Scott W. Rothstein's equity interest in Kip Hunter Marketing; (BI15) S
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
W. Rot Equity interest in Edify LLC; (B111) Scott W. Rothstein's equity interest in V Georgio Vodka; (B112) ott W. Rothstein's equity interest in Sea Club; ( W. Rothstein's equity interest in North Star Mortgage; \ NIL Scott W. Rothstein's equity interest in Kip Hunter Marketing; O(15) Scott W. Rot
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
in's equity interest in Edify LLC; (BIl 1) Scott W. jtothstein's equity interest in I Georgio Vodka; (B112) Scott W. Rothstein's equity interest in Sea Club; (BI13) Scott W. Rothstein's equity interest in North Star Mortgage; (BI14) Scott W. Rothstein's equity interest in Kip Hunter Marketing; (8115) S
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
tein's equity interest in Edify LLC; (BD I) Scott W. Rothstein's equity interest in V Georgio Vodka; (B112) Scott W. Rothstein's equity interest in Sea Club; (BI13) Scott W. Rothstein's equity interest in North Star Mortgage; (BI14) Scott W. Rothstein's equity interest in Kip Hunter Marketing; (3115) S
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
tein's equity interest in Edify LLC; (B111) Scott W. Rothstein's equity interest in V Georgio Vodka; (BI12) Scott W. Rothstein's equity interest in Sea Club; (BI13) Scott W. Rothstein's equity interest in North Star Mortgage; (BI I 4) Scott W. Rothstein's equity interest in Kip Hunter Marketing; (BI15)
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
hstein's equity interest in Edify LLC; (BM) Scott W. Rothstein's equity interest in V Georgio Vodka; (BI12) Scott W. Rothstein's equity interest in Sea Club; WI I3) Scott W. Rothstein's equity interest in North Star Mortgage; (B114) Scott W. Rothstein's equity interest in Kip Hunter Marketing; (BI15) S
Entities connected to both United States and Sea Club

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
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSON
Samantha Power
PERSON
Joe Biden
PERSON
the United States District Court
ORGANIZATIONRoy Black
PERSONCourtney Wild
PERSON
Palm Beach County
LOCATION