EFTA00596488Set 9
2009-11-2082p19,382w
dollars. ROTHSTEIN and others in RRA devised an elaborate plan
through which were sold purported confidential assignments of a structured pay-out
settlements, supposedly reached on behalf ... scheme, RRA's letterhead was
settlements. RFtA's trust
regarding investment opportunities in purported structured
rs or wire transfer of monies
account was used to deposit hundreds of millions ... flight log
sexual assaults took place and showed D3 (and possibly
and international figures.
purportedly containing names of celebrities, dignitaries,
ingly pursued flight data
35. For instance, the Litigation Team
https://www.justice.gov/epstein/files/DataSet%209/EFTA00596488.pdf
EFTA00610929Set 9
36p8,050w
false
statements, documents, and computer records to ( I ) loan money to purported borrowers based upon
fraudulent promissory notes and fictitious bridge loans, and (2) invest funds based upon anticipated ... outs from purported confidential settlement agreements which had been reached between and
among certain individuals and business entities. These settlement agreements were falsely presented
as having been reached between putative ... investors
to loan money based upon promissory notes and bridge loans to and from purported clients of RRA.
Defendant ROTHSTEIN falsely alleged that clients of RRA requested short-term financing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00610929.pdf
EFTA01092179Set 9
2009-08-29147p37,301w
used as the front to this elaborate Ponzi scheme,
serving as the purported law firm representing putative plaintiffs in connection with their pre-suit,
confidential settlements. RRA's trust accounts ... among other things, meeting with investors, verifying
account statements and providing investors with purported irrevocable "lock letters" securing
investor funds.
18. JENNIFER KERSTETTER (hereinafter, "Kerstetter"), is an individual residing ... among other things, meeting with investors, verifying
account statements, and providing investors with purported irrevocable "lock letters" securing
investor funds.
19. ROSEANNE CARETSKY (hereinafter, "Caretsky"), is an individual residing
https://www.justice.gov/epstein/files/DataSet%209/EFTA01092179.pdf
EFTA00808026Set 9
2009-12-0728p8,180w
legitimacy and success of the law firm, which enhanced the credibility of the purported
investment opportunity; RRA relied upon the Ponzi scheme to supplement and support the
8
EFTA00808033
Epstein ... unswoni letters, pleadings and other court filings,
hearing transcripts, an unauthenticated copy of what purports to be a plea agreement between
Scott Rothstein and the government,; unsigned drafts, unsigned answers ... from Plaintiff and others pursuant to search warrants in criminal
investigations of Plaintiff, a purported copy of a visitor log from the Palm Beach County
Sheriffs Office, flight logs
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808026.pdf
EFTA00600173Set 9
2008-01-017p1,830w
present employees, independent contractors, attorneys, partners, shareholders,
investigators, agents or other representatives and persons purporting to be affiliated with such
law firm.
10. "Searcy Denny" means the law firm ... employees, independent contractors, attorneys,
partners, shareholders, investigators, agents or other representatives of or persons purporting to
be affiliated with such law firm.
11. "Fanner Jaffe" means the law firm ... employees, independent contractors, attorneys,
partners, shareholders, investigators, agents or other representatives of or persons purporting to
be affiliated with such law firm.
12. "Person" means any individual natural person, partnership
https://www.justice.gov/epstein/files/DataSet%209/EFTA00600173.pdf
EFTA00612483Set 9
2015-10-2035p8,537w
alleged sexual assaults took place and showed D3 copies of a flight
log purportedly containing names of celebrities, dignitaries and international figures. Because of
these potentially explosive facts, putative defendant ... legitimacy and success of the law firm, which enhanced the credibility
of the purported investment opportunity; (d) Rothstein and other
co-conspirators utilized funds obtained through the Ponzi Scheme ... with that motion, Edwards filed papers
discussing my net worth and filed supplemental papers purporting to list
in great detail my vehicles, planes and other items of substantial value
https://www.justice.gov/epstein/files/DataSet%209/EFTA00612483.pdf
EFTA01079156Set 9
2016-02-0715p4,472w
Work to a third-party buyer, and Defendant,
who is attempting to enforce a purported prior agreement to buy the Work. Defendant has
threatened to seize the Work here ... wrote
a letter to Plaintiff in New York asserting that Defendant had a purported "Priority Claim" to the
Work. See Ex. B hereto. Subsequently, Defendant threatened, in conversations with Plaintiff ... turn received its money back from CPS.
8. Despite the inherent flaws in its purported claim to the Work, Defendant has made
multiple threats and other efforts to enforce
https://www.justice.gov/epstein/files/DataSet%209/EFTA01079156.pdf
EFTA00583952Set 9
2010-03-2330p9,571w
been
determined defrauded investors into purchasing fake settlements of fabricated cases purportedly
being litigated at RRA. [PROVIDE CITATION FROM NYT ARTICLE, WSJ ARTICLE, SUN-
SENTICAL ARTICLE AND EPSTEIN AFFIDAVIT ... amounts ranging from
hundreds of thousands of dollars to millions of dollars and could purportedly be purchased at a
discount and repaid to the investors at face value over time ... success of the law firm, which enhanced the apparent credibility of
the purported investment opportunities in the Ponzi Scheme; (d) Rothstein and other co-
conspirators utilized funds obtained through
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583952.pdf
EFTA00090451Set 9
2021-09-0312p2,350w
Authorities iii
RELEVANT PROCEDURAL HISTORY 1
I. The Government has Failed to Identify any Purported Co-Conspirator Statements 2
H. Ongoing Document Dumps Containing Thousands of Statements Does Not Satisfy ... Trial and Facilitates the
Presentation of False Testimony 4
IV. Preclusion of the Purported Statements is the only Appropriate Remedy 5
ii
EFTA00090452
TABLE OF AUTHORITIES
Cases
Taylor v. Illinois ... emphasis in original.)
On October II, 2021, the government identified three purported co-conspirators for
purposes of trial: Jeffrey Epstein, The
government, however, failed and refused to disclose
https://www.justice.gov/epstein/files/DataSet%209/EFTA00090451.pdf
EFTA01729573Set 10
2007-06-2519p8,205w
remedied by these statutes are far removed from the conduct in which Mr. Epstein
purportedly engaged.
We address each statute in turn, starting with those regulating monetary transactions.
18 U.S-C ... does not apply, and was never intended to apply, to Mr. Epstein's
purported misconduct. Mr. Epstein did not own or operate a "money transmitting business"
defined ... common is
that the defendant used thEinteme-Do communicate with a child or purported child (or a person
With influence over such a child or purported child), and with
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01729573.pdf
EFTA00613940Set 9
2009-03-0358p16,044w
Parties' 2009 Settlement Agreement 21
Investors Approve New Management of the Fund 22
Purported Termination of the Settlement Agreement 22
The Parties' Claims 23
Payment of Any Potential Monetary Award ... memorandum in support of their claims in this matter and in opposition to the purported
counterclaims of Respondent Jeepers, Inc. and Counter-Claimant Financial Trust
Company, Inc. ("FTC") (together, "Jeepers ... waiver" of the applicable terms of the Fund's operative documents that was
purportedly reached between Mr. Epstein and Daniel Zwirn, an executive at the Fund's
former manager
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613940.pdf
EFTA00068050Set 9
2019-07-1228p13,916w
Overcome the Presumption of Detention
The defendant's "slate of highly restrictive" measures which purportedly "amply suffice to
secure his release" are neither highly restrictive nor amply sufficient. Rather, they ... brother other
than that he lives half the year in the home he purportedly would pledge, and even less information
about Mr. Mitchell, other than that he is "Mr. Epstein ... Government could locate and apprehend the defendant, numerous courts have recognized that such
purported waivers are unenforceable and effectively meaningless because any defendant who signs
such a purported waiver
https://www.justice.gov/epstein/files/DataSet%209/EFTA00068050.pdf
EFTA01962678Set 10
2013-08-1921p9,692w
filed any
lawsuit, arbitration, complaint, or charge with respect to any claim this Agreement purports to
waive. Dr. Nikolic understands that nothing in this Agreement prevents him from filing ... agrees to cause the withdrawal or
dismissal with prejudice of any claim he has purported to waive under this Agreement. This
Section shall not apply to claims challenging the validity ... Nikolic is ever awarded or
recovers any amount as to a claim he has purported to waive in this Agreement, Dr. Nikolic
agrees that the amount of any award
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01962678.pdf
EFTA00310814Set 9
2007-06-2529p10,989w
remedied by these statutes are far removed from the conduct in which Mr. Epstein
purportedly engaged.
We address each statute in turn, starting with those regulating monetary transactions.
18 U.S.C ... does not apply, and was never intended to
apply, to Mr. Epstein's
purported misconduct. Mr. Epstein did not own or operate a
"money transmitting business" as
defined ... common is
that the defendant used the intemet to communicate with a child or purported child (or a person
with influence over such a child or purported child), and with
https://www.justice.gov/epstein/files/DataSet%209/EFTA00310814.pdf
EFTA00608380Set 9
2008-01-015p1,227w
present employees, independent contractors, attorneys, partners, shareholders, investigators,
agents or other representatives and persons purporting to be affiliated with such law firm.
10. "Searcy Denny" means the law firm ... employees, independent contractors, attorneys, partners,
shareholders, investigators, agents or other representatives of or persons purporting to be affiliated
with such law firm.
11. "Farmer Jaffe" means the law firm ... employees, independent contractors, attorneys, partners,
shareholders, investigators, agents or other representatives of or persons purporting to be affiliated
with such law firm.
12. "Person" means any individual natural person, partnership
https://www.justice.gov/epstein/files/DataSet%209/EFTA00608380.pdf
EFTA00076331Set 9
2019-07-1228p13,950w
Overcome the Presumption of Detention
The defendant's "slate of highly restrictive" measures which purportedly "amply suffice to
secure his release" are neither highly restrictive nor amply sufficient. Rather, they ... brother other
than that he lives half the year in the home he purportedly would pledge, and even less information
about Mr. Mitchell, other than that he is "Mr. Epstein ... Government could locate and apprehend the defendant, numerous courts have recognized that such
purported waivers are unenforceable and effectively meaningless because any defendant who signs
such a purported waiver
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076331.pdf