authenticating hundreds of millions of dollars of non-existent receivables, was so patently deficient that the audit amounted to no audit at all. Berenfeld materially participated, conspired, substantially assisted, encouraged, and Page 24 of 2210 CONRAD & SCHERER, LLP, 633 SOUTH FEDERAL HIGHWAY, FORT

omplaint 6. Additionally, Gibraltar Private Bank & Trust (hereinafter, "Gibraltar Bank") and Berenfeld Spritzer Shechter Sheer, LLP (hereinafter, "Berenfeld"), both played instrumental roles in perpetuating the conspiracy to defraud and their conduct and omissions materially contributed to Plaintiffs' l

Y OCCUPY WOULD NOT HAVE BEEN COMPLETED WITHOUT HER... OUR GROWTH WOULD BE IN REVERSE."; D. Berenfeld 311. Plaintiffs have discovered relative to Berenfeld that: a. Berenfeld's audited financial statements for the affiliated Banyon entities confirmed finance receivables of $517,404,505.00 due from RRA

HAN I COULD EVER EXPLAIN...OUR OFFICES THAT WE CURRENTLY OCCUPY WOULD NOT HAVE BEEN COMPLETED WITHOUT HER... OUR GROWTH WOULD BE IN REVERSE."; D. Berenfeld 311. Plaintiffs have discovered relative to Berenfeld that: a. Berenfeld's audited financial statements for the affiliated Banyon entities confirm