Epstein Secrets

20, 2009, William Scherer, on behalf of certain clients, filed a 147 page Complaint against ROTHSTEIN, David Boden, Debra Villegas, Andrew Barnett, TD Bank, N.A., Frank EFTA00729411 Epstein v. RRA, et al. Page 9 Spinosa, Jennifer Kerstetter, Rosanne Caretsky and Frank Preve asserting various allega

that RBA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that at:7.gs to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and o

mitted, COFFEY BURLINGTON Counsel for Plaindffs 2699 South Bayshore Drive, Penthouse Miami, Florida 33133 (305) 858-2900 B OS I LLADNECIV FEIN Florida Bar . 259861 Annexed hereto as Exhibit A is an affidavit from Plaintiff Rosenfeldt attesting to the truthfulness of the allegations contained herein.

Counly Records,Taxes & ItC0.541:y hhavngtbrowardorg John L. Heller john la@marcuml lpeom. 1103@ecfcbiscom John B. I IØ Ill tm behalf of Dr:indam TD Bank, N A. huttoniggtJaw com, [email protected];rnialitdoctgethw.ccen,[email protected] John B. Ilunon 111 on hekelt a/Hand:fr1D Bad, N.A. huttorM

MIECF) Roth & Schol Attn: Jeffrey C. Roth, Esq .(VIA CMIEC Ft Rogers, Morris & Ziegler, LIP «IA CMIECF) Arthur C. Nelvát, Esq. -(VIA CMIECF) The Florida Bar Mia E. Charnels, Esq. Alan Anthony Pascal, Esq. -(VIA CMIECF) Micheal W. Moskowitz, Esq. -(1/1A CWECF) Francis L Carter, Esq. -(VIA CMIECF) Brad

ed by the local rules of this court, the rules of professional conduct and all other requirements governing the professional behavior of members of the Florida Bar, WHEREFORE, Movant respectfully requests entry of the attached proposed Order Admitting Attorney Pro Hac Vice, authorizing his special admission to

Counly Records,Taxes & ItC0.541:y hhavngtbrowardorg John L. Heller john la@marcuml lpeom. 1103@ecfcbiscom John B. I IØ Ill tm behalf of Dr:indam TD Bank, N A. huttoniggtJaw com, [email protected];rnialitdoctgethw.ccen,[email protected] John B. Ilunon 111 on hekelt a/Hand:fr1D Bad, N.A. huttorM

MIECF) Roth & Schol Attn: Jeffrey C. Roth, Esq .(VIA CMIEC Ft Rogers, Morris & Ziegler, LIP «IA CMIECF) Arthur C. Nelvát, Esq. -(VIA CMIECF) The Florida Bar Mia E. Charnels, Esq. Alan Anthony Pascal, Esq. -(VIA CMIECF) Micheal W. Moskowitz, Esq. -(1/1A CWECF) Francis L Carter, Esq. -(VIA CMIECF) Brad

ed by the local rules of this court, the rules of professional conduct and all other requirements governing the professional behavior of members of the Florida Bar, WHEREFORE, Movant respectfully requests entry of the attached proposed Order Admitting Attorney Pro Hac Vice, authorizing his special admission to

fact, on November 20, 2009, William Scherer, on behalf of certain clients, filed a 147 page Complaint against ROTHSTEIN, BODEN, VILLEGAS, BARNETT, TD Bank, N.A., Frank Spinosa, Jennifer Kerstetter, Rosanne Caretsky and Frank Preve asserting various allegations that further prove the massive Ponzi sche

lawyers have years of experience - former state attorney, civil practitioners, a circuit court judge — all of whom probably have served on various Florida Bar committees. Yet they claim a lack of knowledge when: a. The firm had 24 hour security in the form of Broward County Sheriff's officers on each floo

fact, on November 20, 2009, William Scherer, on behalf of certain clients, filed a 147 page Complaint against ROTHSTEIN, BODEN, VILLEGAS, BARNETT, TD Bank, N.A., Frank Spinosa, Jennifer Kerstetter, Rosanne Caretsky and Frank Preve asserting various allegations that further prove the massive Ponzi sche

A lawyers have years of experience former state attorney, civil practitioners, a circuit court judge — all of whom probably have served on various Florida Bar committees. Yet they claim a lack of knowledge of any indication that problems with the firm existed when: a. RRA had 24 hour security in the form

20, 2009, William Scherer, on behalf of certain clients, filed a 147 page Complaint against ROTHSTEIN, David Boden, Debra Villegas, Andrew Barnett, TD Bank, N.A., Frank EFTA00596496 Epstein v. RRA, et al. Page 9 Spinosa, Jennifer Kerstetter, Rosanne Caretsky and Frank Preve asserting various allega

that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot

(h)) I. The General Allegations and paragraphs 5 through 40 of Count 1 of the Information are realleged and incorporated herein by reference. 2. TD Bank, N.A., (hereinafter referred to as TD Bank) was a commercial bank with branch offices in thirteen (13) states, including a branch office in Weston,

that RBA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot

ase No.: 09-062943 (19) Third Amended Complaint By ignoring evidence of the Principal Conspirators' misconduct and permitting the continued use of TD Bank accounts to accomplish this fraud, TD Bank knowingly or recklessly allowed itself to become a conduit for these activities and, accordingly, is lia

n concocted a story about how Platinum's and Centurion's halt in funding caused a client settlement backlog and, as a result, he was facing imminent Florida Bar suspension and a total freeze on RRA's accounts. This was Rothstein cover story for why mounting scheduled settlement payments were not being made

20, 2009, William Scherer, on behalf of certain clients, filed a 147 page Complaint against ROTHSTEIN, David Boden, Debra Villegas, Andrew Barnett, TD Bank, N.A., Frank EFTA00795595 Epstein v. RRA, et al. Page 9 Spinosa, Jennifer Kerstetter, Rosanne Caretsky and Frank Preve asserting various allega

THSTEIN investors that RRA's trust accounts in ned with a well established international banking institution, in accordance with d regulations of the Florida Bar, and that access to balances in the trust accoun I egedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and other co

20, 2009, William Scherer, on behalf of certain clients, filed a 147 page Complaint against ROTHSTEIN, David Boden, Debra Villegas, Andrew Barnett, TD Bank, N.A., Frank EFTA00193783 Epstein J RRA, et al. Page 10 24. In each of RRA's Civil Actions, the Plaintiffs are or were represented by RRA and

that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot