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arra. 4. On 411k 25, 009 and on April 23, 2009, Judge Marra entered detailed orders 0 in this matter of hic
ARD MORSE and CAROL MORSE, Petitioners. O C. Appeal from the United States District Court for the Southern District of Fl In der Seal- Civ-Marra), Kenneth A. Marra, Judge. PETITIONERS' MOTION FOR EMERGENCY WRIT OF MANDAMUS Petitioners, EDWARD MORSE and CAROL MORSE, by and through their undersigned counsel, fi
3. This nutter is pen4t, Ifore the Honorable United States District Court Judge, Kenneth Marra. 4. On 411k 25, 009 and on April 23, 2009, Judge Marra entered detailed orders 0 in this matter of hich are attached hereto and incorporated by reference herein. t forth in the Orders, Judge Mama order
t and were owed a judgement of approximately S23 million. The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands in order to avoid paying the judgement. 27. Defendant ROTHSTEIN and other co-conspirators falsely advised the dEents on NJ P several occasions t
Rothstein's scheme went so far as to manufacture false and fraudulent Court opinions/orders including forging the signatures of U.S. District Judge, Kenneth A. Marra and U.S. Circuit Court Judge, Susan H. Black, 11th Circuit in other cases. It is not yet known if he forged similar documents in Esptein related mat
This matter is pending before the Honorable United States District Court Judge, Kenneth Marra. 4. On March 25, 20O9 and on April 23, 2009, Judge Marra entered detailed orders in this matter, copies of which are attached hereto and incorporated by reference herein. 5. As set forth in the Orders, J
ra. 4. On March 25, 20O9 and on April 23, 2009, Judge Marra entered detailed orders in this matter, copies o
t and were owed a judgement of approximately $23 million. The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands in order to avoid paying the judgement. 27. Defendant ROTHSTEIN and other co-conspirators falsely advised the clients on several occasions that i
es. 4. On March 25, 2009 and on April 23, 2009, Judge Marra entered detailed orders in this matter, copies o
DWARD MORSE and CAROL MORSE, Petitioners. Appeal from the United States District Court for the Southern District of Florida (Under Seal- Civ-Marra), Kenneth A. Marra, Judge. PETITIONERS' MOTION FOR EMERGENCY WRIT OF MANDAMUS Petitioners, EDWARD MORSE and CAROL MORSE, by and through their undersigned counsel, fi
This matter is pending before the Honorable United States District Court Judge, Kenneth Mires. 4. On March 25, 2009 and on April 23, 2009, Judge Marra entered detailed orders in this matter, copies of which are attached hereto and incorporated by reference herein. 5. _ As set forth in the Orders,
ar and convincing evidence presented by counsel for MORSE and counsel's expert witnesses, JONES has Illegally moved funds from the United States to the Cayman Islands in violation of federal law. for the purpose of secreting these assets; 9. That the IRS has provided competent testimony in this regard clearly est
Rothstein's scheme went so far as to manufacture false and fraudulent Court opinions/orders including forging the signatures of U.S. District Judge, Kenneth A. Marra and U.S. Circuit Court Judge, Susan H. Black, 11th Circuit in other cases. It is not yet known if he forged similar documents in Esptein related mat
This matter is pending before the Honorable United States District Court Judge, Kenneth Marra. 4. On March 25, 2009 and on April 23, 2009, Judge Marra entered detailed orders in this matter, copies of which are attached hereto and incorporated by reference herein. 5. _ As set forth in the Orders,
ra. 4. On March 25, 2009 and on April 23, 2009, Judge Marra entered detailed orders in this matter, copies o
t and were owed a judgement of approximately $23 million. The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands in order to avoid paying the judgement. 27. Defendant ROTHSTEIN and other co-conspirators falsely advised the clients on several occasions that i
Rothstein's scheme went so far as to manufacture false and fraudulent Court opinions/orders including forging the signatures of U.S. District Judge, Kenneth A. Marra and U.S. Circuit Court Judge, Susan H. Black, 11th Circuit in other cases. It is not yet known if he forged similar documents in Esptein related mat
he signatures of U.S. District Judge, Kenneth A. Marra and U.S. Circuit Court Judge, Susan H. Black, 11t
t and were owed a judgement of approximately $23 million. The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands in order to avoid paying the judgement. 27. Defendant ROTHSTEIN and other co-conspirators falsely advised the clients on several occasions that i
he signatures of U.S. District Judge, Kenneth A. Marra and U.S. Circuit Court Judge, Susan H. Black, 11t
Rothstein's scheme went so far as to manufacture false and fraudulent Court opinions/orders including forging the signatures of U.S. District Judge, Kenneth A. Marra and U.S. Circuit Court Judge, Susan H. Black, 11th Circuit in other cases. It is not yet known if he forged similar documents in Esptein related mat
t and were owed a judgement of approximately $23 million. The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands in order to avoid paying the judgement 27. Defendant ROTHSTEIN and other co-conspirators falsely advised the clients on several occasions that in
ut the complained-of conduct.” Special Purpose Accounts Receivable Co-op Corp. v. Prime One Capital Co., .L.L.C, 2007 WL 4482611 (S.D. Fla. 2007) (Marra, J.). Obtaining information about the whereabouts of Epstein’s assets is particularly difficult, given his financial sophistication in structurin
s “one of its most important individual clients”). Given the fact that asset transfers can take place to such countries as Israel, Switzerland, and the Cayman Islands, placing the burden on Jane Doe to document fraudulent asset transfers to such destinations effectively gives a green light to massive fraud – a fr
08-CV-80232-MARRAJJOHNSON CASE NO.: 08-CV-80380-MARRA/JOHNSON CASE NO.: 08-CV-80381-M.ARRA/JOHNSON EF
12. In the very next sentence, Jane Doe asserts "[g]iven the fact that asset transfers can take place to such countries as Israel, Switzerland, and the Cayman Islands, placing the burden on Jane Doe to document fraudulent asset transfers to such destinations effectively give a green light to massive fraud — a fra
08-CV-80232-MARRAJJOHNSON CASE NO.: 08-CV-80380-MARRA/JOHNSON CASE NO.: 08-CV-80381-M.ARRA/JOHNSON EF
12. In the very next sentence, Jane Doe asserts "[g]iven the fact that asset transfers can take place to such countries as Israel, Switzerland, and the Cayman Islands, placing the burden on Jane Doe to document fraudulent asset transfers to such destinations effectively give a green light to massive fraud — a fra
08-CV-80232-MARRAJJOHNSON CASE NO.: 08-CV-80380-MARRA/JOHNSON CASE NO.: 08-CV-80381-M.ARRA/JOHNSON EF
12. In the very next sentence, Jane Doe asserts "[g]iven the fact that asset transfers can take place to such countries as Israel, Switzerland, and the Cayman Islands, placing the burden on Jane Doe to document fraudulent asset transfers to such destinations effectively give a green light to massive fraud — a fra
Entities connected to both Kenneth Marra and the Cayman Islands

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSON
Paul Cassell
PERSON
United States
LOCATIONJack Goldberger
PERSON
A. Marie Villafana
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATIONLeon Black
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONSouthern District
LOCATION
Jay Lefkowitz
PERSON
Prince Andrew
PERSONRoy Black
PERSON
Ghislaine Maxwell
PERSON