heir damages. 9. Furthermore, as alleged in detail infra, the Principal Conspirators' inner-circle of facilitators (TD Bank, Spinosa, Kerstetter, Caretsky, Gibraltar Bank, Berenfeld, Weintraub, Berkowitz, Leitstein, Levin, Preve, Banyon entities, Szafranski, Onyx, Villegas, Boden, Barnett, Stay, Plati

tant branch manager with Commerce Bank,17 was the source for the following documents obtained by Szafranski: a. October 29, 2008, letter signed by Caretsky enclosing three trust/escrow account statements for RRA: 16 In fact, this was a decidedly false assurance, as we now know that, at the time the Mem

udulent conduct alleged herein while willfully ignoring and/or failing to exercise reasonable care.5 48. Defendant, ROSANNE CARETSKY (hereinafter, "Caretsky"), is an individual residing in Broward County, Florida, and, at all times relevant hereto, was acting within the scope of her employment as an ass