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roximately seventy (70) attorneys and engaged in the practice of law involving a wide range of specialties, including labor and employment law. 3. 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, F
ENERAL ALLEGATIONS I. Debra Villegas was the Chief Operating Officer (COO) of Rothstein, Rosenfeldt and Adler, P.A. 2. Rothstein, Rosenfeldt and Adler, P.A. (hereinafter referred to as "RRA") was a law firm with offices located at 401 East Las Olas Boulevard, Fort Lauderdale, Florida and elsewhere. The
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
e State of Florida. In November 2009, ROTHSTEIN voluntarily relinquished his law license in the midst of the implosion of Rothstein, Rosenfeldt and Adler, P.A. ("RRA"). He was disbarred by the Florida Supreme Court on November 20, 2009. 4. At all times relevant hereto, ROTHSTEIN was the managing partner an
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
e State of Florida. In November 2009, ROTHSTEIN voluntarily relinquished his law license in the midst of the implosion of Rothstein, Rosenfeldt and Adler, P.A. ("RRA"). He was disbarred by the Florida Supreme Court on November 20, 2009. 10. At all times relevant hereto, ROTHSTEIN was the managing partner a
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 EFTA00190033 Epstein I RRA, et al. Page 9 Spinosa, Jennifer Kerstetter, Rosanne Caretsky and Frank Preve asserting various allegat
dingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and professional obligations to the
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
dingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and professional obligations to the
(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,
ida. Defendant Rothstein was the Chief Executive Officer (CEO) and Chairman of Rothstein, Rosenfeldt and Adler, P.A. 2. Rothstein, Rosenfeldt and Adler, P.A. was a law firm with offices located at 401 East Las Olas Boulevard, Fort Lauderdale, Florida and elsewhere. The law firm employed approximately sev
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
dingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and professional obligations to the
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
dingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and professional obligations to the
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 EFTA00286290 Epsteh v. RRA, et al. Page 9 Spinosa, IMMI Kerstetter, Rosanne Caretsky and Frank Preve asserting various allegations
Defendants. COMPLAINT SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and professional obligations to the
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
rdingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyerS and emplOyeesat the firm of Rothstein, Rosenfeld!, and Adler, P.A. for personal greed and enrichment in betrayal of the ethical, legal and fiduciary duties to their own clients and professional ObligatiOnS to the a
Entities connected to both TD Bank and Adler, P.A.

Jeffrey Epstein
PERSONScott Rothstein
PERSONLeon Black
PERSON
George W. Bush
PERSON
Prince Andrew
PERSON
United States
LOCATION
Bradley Edwards
PERSONJane Doe
PERSON
Marc Rich
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Rosenfeldt
PERSON
Morocco
LOCATIONMaria Farmer
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Kenneth Marra
PERSON
Fort Lauderdale
LOCATION
Maine
LOCATIONLuttier & Coleman
ORGANIZATION