EFTA00726708Set 9
2010-01-27167p47,179w
Third Amended Complaint
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 ... their conduct and omissions materially contributed to
Plaintiffs' losses. Had either Gibraltar Bank or Berenfeld acted in accordance with industry
standards and/or their own internal governance policies and procedures, Rothstein ... averted.
7. Based on the allegations below, Plaintiffs aver that at all materials times Gibraltar
Bank was complicit in the Principal Conspirators' Ponzi scheme, had actual knowledge of
Rothstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00726708.pdf
EFTA00610929Set 9
36p8,050w
Ponzi" scheme.
3. Gibraltar Private Bank and Trust (hereinafter referred to as Gibraltar Bank) was a
commercial bank with seven (7) branch offices, including a branch office in Fort Lauderdale ... Florida. Defendant ROTHSTEIN and RRA maintained at least four (4) bank accounts at Gibraltar
Bank, which were utilized during the course of the "Ponzi" scheme.
4. From in or about ... WIRE COMMUNICATION
4 December 2, 2008 Interstate wire transfer sent from TD Bank to
Gibraltar Bank
5 October 16, 2009 Interstate wire transfer sent to TD Bank from JP
Morgan
https://www.justice.gov/epstein/files/DataSet%209/EFTA00610929.pdf
EFTA00683125Set 9
36p8,058w
Ponzi" scheme.
3. Gibraltar Private Bank and Trust (hereinafter referred to as Gibraltar Bank) was a
commercial bank with seven (7) branch offices, including a branch office in Fort Lauderdale ... Florida. Defendant ROTHSTEIN and RRA maintained at least four (4) bank accounts at Gibraltar
Bank, which were utilized during the course of the "Ponzi" scheme.
4. From in or about ... WIRE COMMUNICATION
4 December 2, 2008 Interstate wire transfer sent from TD Bank to
Gibraltar Bank
5 October 16, 2009 Interstate wire transfer sent to TD Bank from JP
Morgan
https://www.justice.gov/epstein/files/DataSet%209/EFTA00683125.pdf
EFTA00795588Set 9
2009-11-20103p23,937w
Ponzi" scheme.
3. Gibraltar Private Bank and Trust (herei f€ to as Gibraltar Bank) was a
commercial bank with seven (7) branch offices, i ranch office in Fort Lauderdale,
Florida ... DATE WIRE COMMUNICATION \\ -
. , •
4 December 2, 2008 Interstate wire transfer sent from TD13ank to
Gibraltar Bank = - ,, N>,
5 October 16, 2009 Interstate wire transfer sent to TD13ank from JP
Morgan ... Account, in the n ft W. Rothstein, valued at
approximately $1,263,780;
(BA2) Gibraltar Bank account 50010085, 'n* p ximate amount of $484,900.68;
(BA3) Gibraltar Bank accoun
https://www.justice.gov/epstein/files/DataSet%209/EFTA00795588.pdf
EFTA00729404Set 9
2009-11-20103p24,512w
scheme.
which were utilized during the course of
fter referred to as Gibraltar Bank) was a
3. Gibraltar Private Bank and Trust (hereina
derdale,
offices, including a branch office ... COMMUNICATION
COUNT
TD Bank to
December 2, 2008 Interstate wire transfer sent from
4
Gibraltar Bank
TD Bank from JP
October 16, 2009 Interstate wire transfer sent to
5
Morgan ... name of Scott W. Rothstein, valued at
approximately $1,263,780;
(BA2) Gibraltar Bank account 50010085, in the approximate amount of $484,900.68;
(BA3) Gibraltar Bank account
https://www.justice.gov/epstein/files/DataSet%209/EFTA00729404.pdf
EFTA00596488Set 9
2009-11-2082p19,382w
maintained approximately thirty-eight
which were utilized during the course of the "Ponzi" scheme.
Gibraltar Bank) was a
3. Gibraltar Private Bank and Trust (hereinafter referred to as
h office ... COMMUNICATION
k to
4 December 2, 2008 Interstate wire transfer sent from TD Ban
Gibraltar Bank
k from JP
5 October 16, 2009 Interstate wire transfer sent ... name of Scott W. Rothstein, valued at
approximately $1,263,780;
(13A2) Gibraltar Bank account 50010085, in the approximate amount of $484,900.68;
(13A3) Gibraltar Bank account
https://www.justice.gov/epstein/files/DataSet%209/EFTA00596488.pdf
EFTA00641478Set 9
2003-04-019p1,737w
Ponzi" scheme,
detailed below.
4. Gibraltar Private Bank and Trust (hereinafter referred to as "Gibraltar Bank") was a
commercial bank with seven (7) branch offices, including a branch office ... Fort Lauderdale,
Florida. RRA maintained several bank accounts at Gibraltar Bank which were utilized during the
course of the "Ponzi" scheme, detailed below.
COUNT 1
(Money Laundering Conspiracy, 18 U.S.C ... transfer the criminally derived proceeds between and among the accounts at TD Bank and
Gibraltar Bank and other financial institutions in amounts in excess of $10,000 in order
https://www.justice.gov/epstein/files/DataSet%209/EFTA00641478.pdf
EFTA00596581Set 9
2010-06-0930p6,240w
approximately $1,263,780, in the actual amount of $1,270,302
.32;
(BA2) Gibraltar Bank account 50010085, in the approximate
amount of $484,900.68;
(BA3) Gibraltar Bank account ... approximate
amount of $53,448.51;
(BA4) Gibraltar Bank account 50011253, in the approximate amou
nt of $71,793.06;
(BA5) Gibraltar Bank account 50015214, in the approximate
amount
https://www.justice.gov/epstein/files/DataSet%209/EFTA00596581.pdf
EFTA00725165Set 9
2009-11-1019p4,453w
NAME OF SCOTT W. Rontsrm,
VALUED AT APPROXIMATELY $1,263,780;
(BA2) GIBRALTAR BANK ACCOUNT 5001008510,
IN THE NAME or WA WW 3 LLC, IN THE
APPROXIMATE AMOUNT ... GIBRALTAR BANK ACCOUNT 5001009310,
IN THE APPROXIMATE AMOUNT OF $53,448.51;
(BA4) GIBRALTAR BANK ACCOUNT 5001005310,
IN THE APPROXIMATE AMOUNT OF $71,793.06;
(BA5) GIBRALTAR BANK ACCOUNT
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725165.pdf