y spent time asking me about the lock letters 20 at the point in time we were utilizing them and the 21 mechanics, and I had to refer them to Mr. Spinosa to 22 answer that question. 23 They asked me about my history with other 24 investors, Thane Ritchie. I don't remember, again, 25 whether it

y spent time asking me about the lock letters 20 at the point in time we were utilizing them and the 21 mechanics, and I had to refer them to Mr. Spinosa to 22 answer that question. 23 They asked me about my history with other 24 investors, Thane Ritchie. I don't remember, again, 25 whether it

he Razorback transaction. 162. On or about October 15, 2009, as part of its due diligence, D3 obtained a copy of a TD Bank "lock letter" signed by Spinosa stating the following: Pursuant to your written instructions to us of October 14, 2009, please be advised that all funds contained in the above ref

udulent conduct alleged herein while willfully ignoring and/or failing to exercise reasonable care. 46. Defendant, FRANK A. SPINOSA (hereinafter, "Spinosa"), is an individual residing in Broward County, Florida and, at all times relevant hereto, was acting within the scope of his employment as a senio

ssly allowed itself to become a conduit for these activities and, accordingly, is liable for its participation; m. in late November, TD Bank fired Spinosa; B. Levin, Preve and Banyon 309. Plaintiffs have discovered, relative to Levin, Preve, and Banyon, that: a. an $8,000,000.00 wire transfer conf