Scott Saidel, kimberly rothstein, stacie weisman, patrick daoud criminal information
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Transcript of Scott Saidel, kimberly rothstein, stacie weisman, patrick daoud criminal information
UM TED STATES DISTRJCT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO,
18 U.S.C. j 37118 U.S.C. j 981(a)(1)(C)
UNITED STATES OF AM ERICA
V.
KIM BERLY W ENDELL ROTHSTEIN,
STACIE W EISG N, and
SCOTT F. SAIDEL,
Defendants.
/
INFORM ATION
The United States Attorney charges that, at al1 times relevant to this Indictment:
GENERAL ALLEGATIONS
Rothstein, Rosenfeldt and Adler, P.A. (hereinafter ç1R'RA'') was a 1aw 517)1 with
offices located at 401 East Las Olas Boulevard, Fort Lauderdale, Florida in the Southern District
of Florida and elsewhere. The law 51714 employed approximately seventy (70) attomeys and one
hundred and f1+ (150) staffmembers and engaged in the practice of law involving a wide range
of specialties, including labor, employment, comorate, commercial and personal injury law.
2. Former Fort Lauderdale attorney Scott W . Rothstein was the Chief Executive
Officer and Chairman of RRA .
3.
money from investors by fraud in cormection with an investment scheme commonly known as a
RRA was utilized by Scott W . Rothstein and co-conspirators to tmlawfully obtain
Ponzi scheme, in which new investors' funds are utilized to pay previous investors in the absence
12-60204-CR-ROSENBAUM/SNOW
Sep 6, 2012
ATCase 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 1 of 23
of any underlying security, legitimate investment vehicle or other commodity. The Ponzi scheme
involvedthe sale of pttrported contidential settlements in sexualharassment, discrimination and/or
whistle-blower cases. The potential investors were told by Scott W . Rothstein and other co-
conspirators that pools of confdential settlements were available for purchase. The purported
settlements were allegedly available in blocks ranging from hundreds of thousands to millions of
dollars and could be purchased at a discount and repaid to the investors at face value over time.
ln reality, the settlements did not exist and all defendant and plaintiffnames were fabricated.
4. Scott W . Rothstein used the funds obtained from the Ponzi scheme to purchase tens
of millions of dollars of real estate, vehicles, vessels, business interests, luxury watches, jewelry
and sports memorabilia for himself, his wife, defendant KIM BERLY W ENDELL ROTHSTEW,
and others.
Scott W . Rothstein was sentenced to 50 years' imprisonment after pleading guilty to
Conspiracy to Violate the Racketeering Intluenced and Com zpt Organizations Act, M oney
Laundtring and W ire Fraud charges, and ordered to pay over $300 million in restitution. In early
Novembtr 2009, as part of his plea agrtement, Scott W . Rothstein agreed to forfeit to the
govenmwnt all assets acquired with funds derived through the aforesaid Ponzi scheme. On
November 9, 2009, agents of tht lntemal Revenue Service, Criminal lnvestigations, went to the
Rothstein residence, where deftndant KIM BERLY W ENDELL ROTHSTEm assisted the agents
in retrieving what was believed to be a11 of the available cash, jtwelry and luxury watches which
had previously been purchased by Scott W . Rothstein with proceeds derived from the Ponzi
scheme.
2
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 2 of 23
6. In fact, before, during and after the aforesaid seizure by federal agents on November
9, 2009, defendants KIM BERLY W ENDELL ROTHSTEW , STACIE W EISM AN, and SCOTT
F. SAIDEL, and others, knowingly took action to conceal certain items of jewelry, valued in
excess of one million dollars (hereinafter referred to as çsthe Missing Jewelry''), for the purpose of
preventing the govenzment from exercising its authority to take such property into its lawful
custodyandcontrol. Thereaher, defendantsKlM BEltlaY W ENDEl,lw ROTHSTEIN and STACIE
W EISM AN, and others, sold and attempted to sell aportion of the M issing Jewelry to and through
various persons, including Eddy M arin and Patrick Daoud. Included among the M issing Jewelry
was a 12.08 carat fancy intense yellow diamond ring (hereinaRer referred to as çlthe 12.08 Carat
Dinmond'').
On November 10, 2009, an Involuntary Petition for Relief was filed against RRA in
United States Bankruptcy Court for the Southem District of Florida. On November 20, 2009, the
Office of the United States Tnzstee filed a Notice Appointing Herbert Stettin (hereinaher referred
to as 'lstettin'') as Trustee of RRA. On November 25, 2009, RRA consented to the Involuntary
Petition for Relief On November 25, 2009, the Court entered an order ratifying the appointment
of Stettin as Trustee in Southern District of Florida Bankruptcy Court Case No. 09-34791-8KC-
RBR. On November 30, 2009, the Court entered an Order for Relief on the filing of a Petition for
Bankruptcy.
8.
was aFlorida corporation with its principal place of business inBroward County, Florida. Between
SPD Group, Inc., d/b/a J. R. Dunn Jewelers (hereinaoer referred to as CCJ. R. Durm'')
November 2005 and October 2009, J. R. Dunn sold to Scott W. Rothstein certain items ofjewelry,
including items constituting part of the M issing Jewelry.
3
In cormection with the aforesaid
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 3 of 23
bankruptcy proceedings, Stettin instituted adversary legal proceedings against J. R. Dunn in
Southern Distrid of Florida Bankruptcy Court Adv. Case No. 1 1-2363-BKC-RBR (htreinafter
referred to as Stthe Dunn Bankruptcy Adversary Adion''), seeking to recover certain funds from
J. R. Dunn which had been paid by Scott W. Rothstein for certain items of jewdry, including the
12.08 Carat Diamond and other items constituting part of the M issing Jewelry. ln connection with
those legal proceedings, depositions under oath were taken of various witnesses, including Eddy
M arin and Patrick Daoud. ln Junt 2012, the deposition of Scott W . Rothstein was scheduled to
be taken in connection with the Dunn Bankruptcy Adversary Action.
9. In connection with the proceedings instituted against it by Stettin, J. R. Dunn,
through its counsel, attempted to locate the current whereabouts of certain items ofjewelry which
it had sold to Scott W . Rothstein, including tht 12.08 Carat Diamond and other items constituting
part of the M issing Jewelry.
10. Daoud's, Inc., dfb/a Daoud's Fine Jewelry, was a Florida corporation with its
principal place of business in Broward County, Florida. Patrick Daoud was the President of
Daoud's Inc.
1 1 .
State of Florida who maintained a trust account at W achovia Bank, N.A., now known as W ells
Defendant SCOTT F. SAIDEL was an attorney authorized to practice law in the
Fargo Bank, N.A.
12. Title 3 1, United States Code, Section 53 13(a), and the regulations thereunder,
require domestic fnancial institutions, such as banks and check cashing agencies, to report to the
Intem al Revenue Service anyone depositing, withdrawing or otherwise receiving more than
$10,000 in United States currency.
4
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 4 of 23
COUNT I
1. The General Allegations section of this Indictment is incorporated by reference as
though fully set forth herein.
2. From in or about November 2009 and continuing through on or about June 22,
2012, in Broward County,in the Southem Distrid of Florida, and elsewhere, the defendants,
KIM BERLY W ENDELL ROTHSTEIN,
STACIE W EISM AN, and
SCOTT F. SAIDEL,
knowingly andwillfully combined, conspired, confederated, and agreedwith one another and with
other persons known and unknown to the United States Attomey to committhe following offenses
against the United States:
(a) to knowingly conduct a fnancial transaction which involved the proceeds of specified
unlawful activity, that is, mail fraud and wire fraud, in violation of Title 18, United States Code,
Sections 134 1 and 1343, knowing that the property involved in the snancial transaction
represented the proceeds of some form of unlawful adivity and knowing that the transaction was
designed in whole or in part to conceal and disguise the namre, the location, the source, the
ownership, and the control of proceeds of tht aforesaid speciied unlawful activity, in violation of
Title 18, United States Code, Sedion 1956(a)(1)(B)(i);
(b) to corruptly conceal an object with the intent to impair that object's availability for use
in an oftkial proceeding, and to othtrwise obstrud, influence, and impedt an oftkial proceeding,
and attempt to do so, in violation of Title 18, United States Code, Section 1512(c); and
5
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 5 of 23
(c) to corruptly persuade another person, that is, Scott W . Rothstein, with intent to
intluence the testimony of Seott W . Rothstein in an oftkial proceeding, in violation of Title 18,
United States Code, Section 1512(b)(1).
PURPOSE AND OBJECT OF THE CONSPIM CY
The pumose and objed of tht conspiracy was to: (a) obtain money from the salt
of the M issing Jewelry for the use and beneft of members of tht conspiracy, including paying
dtbts accrued by members of the conspiracy, through the transfer of the criminally derived
proceeds in such a manner as to disguise the true nature, the location, the source, the ownership,
and the control of said proceeds; (b) conceal the details regarding the disposition, the true
location, and the possession of the 12.08 Carat Diamond that was part of the M issing Jewelry and
had previously bten sold to Scott W . Rothstein by J. R. Dunn, the recovery of which was being
sought by J. R. Dunn in connection with actions instimted against it in an oo cial proceeding, that
is, the Dunn Bankruptcy Adversary Action; and (c) persuade Scott W . Rothstein to falsely testify
under oath concem ing the disposition of the 12.08 Carat Diamond that was part of the M issing
Jewelry and had previously been sold to Scott W . Rothstein by J. R. Dunn, the recovery of which
was being sought by J. R. Dlmn in cormection with actions instituted against it in connection with
the bankruptcy proceedings, including the Durm Bankruptcy Adversary Action.
M ANNER AND M EANS OF THE CONSPIRACY
M oney Laundering
It was part of the conspiracy thatdefendants KIM BERLY W ENDELL4.
ROTHSTEIN, STACIE W EISM AN, and SCOTT F. SAIDEL would agree to sell certain items
of tht M issing Jewelry through Eddy M arin, Patrick Daoud and others.
6
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 6 of 23
It was further part of the conspiracy that Eddy M arin would dispose of a portion
of the M issing Jewelry and remit proceeds in U.S. currency to defendant STACIE W EISM AN.
6. It was further part of the conspiracy that defendant STACIE W EISM AN would sell
the 12.08 carat Diamond to Patrick Daoud, who would remit the proceeds in U.S. currency to
defendant STACIE W EISM AN.
lt was further part of the conspiracy that defendant STACIE W EISM AN would
provide U.S. currency received from Eddy M arin and Patrick Daoud derived from the sale of the
M issing Jewelry to defendants KIM BERLY W ENDELL ROTHSTEIN and SCOTT F. SAIDEL.
8. lt was further part of the conspiracy that, when defendant SCOTT F. SAIDEL
would rtceive from defendant STACIE W EISM AN U.S. currency derived from the sale of the
M issing Jewelry, some of the U.S. currency would be deposited into a 1aw finn trust account at
W achovia Bank, N.A. in increments of less than $10,000, thereby avoiding W achovia Bank, N.A.
from reporting the deposit of U.S. currency to the U.S. Department of the Treasury.
It was further part of the conspiracy that defendant STACIE W EISM AN would
deposit into her personal bank accounts U.S. currency which constituted proceeds derived from
tht salt of the M issing Jewtlry.
It was further part of the conspiracy that defendant SCOTT F. SAIDEL would
receive checks from defendant STACIE W EISM AN which constituted proceeds derivrd from the
sale of the M issing Jewelry and those checks would be deposited into a law firm trust account at
W achovia Bank, N.A.
It was further part of the conspiracy that defendant SCOTT F. SAIDEL advised
defendants KIM BERLY W ENDELL ROTHSTEIN and STACIE W EISM AN that he would
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 7 of 23
deposit proceeds received from the sale of the M issing Jewelry into his law 51414 tnzst account in
order to avoid the scnztiny of Stettin and/or the Internal Revenue Service.
12. lt was further part of the conspiracy that defendant SCOTT F. SAIDEL would
transfer funds by check or wire from the law 51711 trust account at W achovia Bank, N.A. to other
persons and entities to whom/whichdefendant SCOTTF. SAIDEL and/ordefendantKlM BEc Y
W ENDELL ROTHSTEm had incurred indebtedness.
B.
lt was part of the conspiracy that defendant STACIE W EISM AN would exhibit the
Obstruction of Justice
12.08 Carat Diamond to Eddy Marin in an attempt to have Eddy M arin sell it on her behalf and
on behalf of defendant KIM BERLY W ENDELL ROTHSTEm .
It was further part of the conspiracy that Eddy M arin would photograph the 12.08
Carat Diamond and transmit the image to various persons in an attempt to sell it.
It was further part of the conspiracy that defendant STACIE W EISM AN would
thereafter sell the 12.08 Carat Diamond to Patrick Daoud for $175,000.00.
lt was further part of the conspiracy that Eddy M arin, when deposed in connection
with the Dunn Bankruptcy Adversary Action, would falsely testify under oath that he never was
shown the 12.08 Carat Diamond by defendant STACIE W EISM AN.
lt was further part of the conspiracy that Eddy M arin, when deposed in connection
with the Dunn Bankruptcy Adversary Action, would falsely testify under oath that he was shown
the 12,08 Carat Diamond by Robert Fuchs, who was deceased and therefore could not contradict
the false testimony of Eddy M arin.
8
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 8 of 23
1 8 . lt was further part of the conspiracy that Patrick Daoud, when deposed in
cormection with the Dunn Bankruptcy Adversary Action, would falsely testify under oath that he
never received the 12.08 Carat Diamond from defendant STACIE W EISM AN.
1 9. lt was further part of the conspiracy that Patrick Daoud, when deposed in
connection with the Durm Bankruptcy Adversary Action, would falsely testify under oath that a
person other than defendant STACIE W EISM AN brought the 12.08 Carat Dimnond to him.
20. lt was further part of the conspiracy that Patrick Daoud, when deposed in
connection with the Dunn Bankruptcy Adversary Action, would falsely testify under oath that he
never retained possession of the 12.08 Carat Diamond.
It was further part of the conspiracy that defendant Patrick Daoud, after having
falsely testified under oath in the Dulm Bankruptcy Adversary Action that he never received the
12.08 Carat Diamond from STACIE W EISM AN, did thereafter return the 12.08 Carat Diamond
to STACIE W EISM AN.
W itness Tampering
lt was part of the conspiracy thatdefendants KIM BERLY W ENDELL
ROTHSTEIN, STACIE W EISM AN, and SCOTT F. SAIDEL would obtain U.S. currency as
proceeds from the sale of the 12.08 Carat Diamond.
It was further part of the conspiracy that, in order to conceal the true disposition of
the 12.08 Carat Diamond,defendants KIMBERLY W ENDELL ROTHSTEIN, STACIE
W EISM AN, and SCOTT F. SAIDEL would persuade Scott W . Rothstein to testify falsely when
Scott W . Rothstein was deposed in colmection with the Dunn Bankruptcy Adversary Action
scheduled in June 2012.
9
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24. lt was further part of the conspiracy that, aher Eddy M arin had been deposed and
had falsely testified that Robert Fuchs was the person who had shown him the 12.08 Carat
Diamond, defendants STACIE W EISM AN and SCOTT F. SAIDEL sought to have Scott W .
Rothstein tailor Scott W . Rothstein's anticipated deposition testimony to concur with Eddy
M arin's prior false testimony by stating that, prior to his incarceration, Scott W . Rothstein sold the
12.08 Carat Diamond to Robert Fuchs, in an effort to corruptly explain how Robert Fuchs came
into possession of the 12.08 Carat Diamond and to falsely corroborate Eddy M arin.
25. It was further part of the conspiracy that the identity of Robert Fuchs was chosen
specitkally because he was deceased and therefore could not contradict the false testimony of
Scott W . Rothstein or Eddy M arin.
26. It was further part of the conspiracy that defendant KIM BERLY W ENDELL
ROTHSTEm would be instructed by defendants STACIE W EISM AN and SCOTT F. SAIDEL
to meet with Scott W . Rothstein and advise Scott W . Rothstein as to those false facts to which he
should testify in connection with the Dunn Bankruptcy Adversary Action.
OVERT ACTS
27. In furtherance of the conspiracy and to achieve the objective thereof, at least one
of the co-conspirators committed or caused to be committed, in the Southem District of Florida,
and elsewhere, at least one of the following overt ads, among others:
(a) In oraboutNovemberzoog, defendantKlMBEltl,Y WENDELL ROTHSTEIN
gave to defendant STACIE W EISM AN a portion of the M issing Jewelry.
(b) ln or about December 2009, defendant STACIE W EISM AN gave to Eddy
M arin a portion of the M issing Jewelry for the purpose of having him dispose of same.
1 0
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 10 of 23
(c) On Febnzary 18, 2010, defendantKlc Eltt,Y WENDELL ROTHSTEIN was
deposed in connection with the RRA bankruptcy proceeding, at which time she falsely testified
that all of the M issing Jewelry had been turned over to the govelmment.
(d) In or about April 2010, defendant STACIE WEISM AN gave to Patrick Daoud
the 12.08 Carat Diamond for the purpose of having it graded by the Gemological Institute of
America.
(e) On or about June 9, 2012, defendants KIMBERLY W ENDELL ROTHSTEIN,
STACIE W EISM AN, and SCOTT F. SAIDEL met with one another to discuss the anticipated
deposition of Scott W . Rothstein and the matters to which Scott W . Rothstein should testify
falsely.
All in violation of Title 18, United States Code, Section 371.
FORFEITURE
(18 U.S.C. j 981(a)(1)(C))
1. The allegations of Count 1 of this lnformation are re-alleged and by this reference fully
incom orated herein for the purpose of alleging forfeiture to the United States of America of property
in which the defendants have an interest pursuant to Rule 32.24a) of the Federal Rules of Criminal
Procedure.
Upon conviction of Title 18, United States Code, Section 371, the defendants shall
forfeit to the United States any property, real or personal, which constitutes or is derived from
proceeds traceable to the violation pursuant to Title 18, United States Code, Section 981(a)(1)(C),
as made applicable by Title 28, United States Code, Section 2461(c).
11
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 11 of 23
The property subject to forfeiture shall include, but is not be limited to, the
following'.
RIN GS
a. One ladies platinum and 18 kt yellow gold fancy colored
diamond ring containing one Cut Cornered Rectangular M odifiedBrilliant center diamond, prong set. Estimated weight 12.08 ct
b. One ladies 12 kt white gold diamond, amethyst and pearlring containing one rose cut center diamond
c. One ladies platinum and diamond engagement ring
containing one radiant cut center diamond prong set. Estimatedweight 12.38 ct. Also containing two shield cut diamonds, prong set
one on each side of the center, with an estimated 1.40 ct totalweight. The ring also contains approximately three hundred roundfull cut diamonds bead set around the complete ring and shank at an
estimated total weight 3.00 ct
d. One ladies platinum and diamond eternity wedding bandcontaining 18 genuine emerald cut diamonds
e. One ladies platinum diamond and ruby bypass style
cocktail ring containing sixty-fve round mixed cut diamonds thatare pavé set with an estimated 4.50 ct total weight. Also
containing seventy-three baguette cut rubies that are invisible set
with an estimated 6.00 ct total weight. The ring has tluted side
and weighs 12.5 dwt complete, tested platinum
W ATCHES
tl One men's 18 kt gold Rolex Datejust watch with a roundgreen Rolex dial. Serial 9321541
g. One ladies 18 kt white gold and diamond Gerald Genta
Octo Limited Collection watch with round pave dial of black and
white diamonds
h. One ladies 18 kt gold and diamond Rolex M astem ieceCollection watch with mother of pearl dial Serial # P908321 and
M odel # 74989
12
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 12 of 23
i. One ladies stainless steel Chopard Happy Sport watch
with a round blue color dial
j. One 18 kt rose gold and diamond Harry Winston PremierChronograph quartz watch with a round black pavé diamond dial,Arabic markers, three sub dials, sapphire crystal, diamond crown
and snap down case back
k. One unisex platinum and diamond Pierre Kllnz automatic
watch with a square silver color pavé dial, one sub dial, sapphire
crystal and screw down case back with exhibition window
1. One ladies 18 kt white gold and diamond rotating spider
web cover Piaget watch with a round pavé diamond dialsurrounded by black onyx
m. One ladies 18 kt white gold and diamond Rolex President
watch with a round pavé dial and blue roman numerical markers,sapphire crystal, screw down crown and case back
n. One ladies 18 kt white gold and diamond Piaget LimelightLove Letter quarts watch with a V shape mother of pearl dial and
twelve diamond markers and sapphire crystal
o. One 18 kt yellow gold diamond and sapphire RolexDaytona Cosmograph leopard print watch with a round leopard
print dial, three sub dials, diamond markers, sapphire crystal,three screw down crowns and screw on case back
BRACELETS
p. One ladies 18 kt white gold and diamond large cuffbracelet with a concave wave pattern
q. One ladies 18 kt two tone gold fancy colored diamondbracelet containing sixteen yellow color pear shape diamonds
NECKLACESr. One ladies platinum and 18 kt yellow gold fancy colored
diamond chandelier style necklace containing one pear shape
center diamond
13
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 13 of 23
s. One 18 kt white gold diamond and pearl necklacecontaining 16 baroque Tahitian black pearls.
t. One ladies 18 kt white gold diamond and Tahitian blackpearl necklace
u. One ladies 18 kt two tone gold and fancy colored dinmond
necklace
EARRINGS
V. One pair of ladies 18 kt white gold diamond amethyst andpearl earrings containing two round rose cut center diamonds
prong set
w. One pair of ladies platinum diamond and ruby domedshape button earrings;
x. One pair of ladies platinum diamond and pearl eanings containing twoxound black/gray Tahitian pearls surrounded by twenty-four round full cutdiamonds
y. One pair of ladies 18 kt and platinum and pearl droptlower style eanings containing two round full cut centerdiamonds
z. One pair of platinum and 18 kt yellow gold fancy coloreddiamond drop earrings containing two oval shape yellow color
diamonds, bezel set
COINS
aa. Twent- six l-ounce round South African Krugerrand goldcoins
bb. Seven l-ounce gold 50 dollar Canadian M aple Leaf coins
CC.
dd. Six United States l-ounce 50 dollar Double Eagle coins
ee. Four United States 20 dollar Liberty Head gold coins
Four l-ounce gold 100 dollar Australian Kangaroo coins
Six United States Saint Gaudens 20 dollar gold coins
14
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 14 of 23
gg. Five United States 10 dollar Liberty Head gold coins
hh. One l-ounce .999 Fine Gold Chinese Panda coin
JJ .
ll.
Four United States 5 dollar Liberty Head coins
United States 10 dollar Gold Double Eagle Bullion coin
One quarter-ounce South African Krugerrand Bullion coin
Two Gold British Sovereigns
M ISCELLANEOUS
mm. Fihy l-ounce gold bars
nn. One lot consisting of eight sterling silver and enamelassorted David Oscarson fountain and rollerball pens and oneouter pen casing
oo. $12,600 in United States Currency seized on July 2, 2012
PP.2012
qq. $2,500 in U.S. currency in the custody of the Internal Revenue Service,Criminal lnvestigation
$20,700 in United States Currency stized on July 1 1,
çf.
SS.
t1. the contents of Wachovia Bank, N.A. tn/d/b/a W ells Fargo Bank, N.A.)trust account number 91 17668848 in the name of 'I'he Law Office of Scott Saidel,
LLC
Four David Oscar fountain and rollerball pens seized on August 21, 2012
One pair of two mother of pearl, diamond and sapphire cufilinks
M ONEY 'UDGM ENT
uu. a money judgment equal in value to any property traceable to suchproperty and/or any property, real or personal, that constitutes or is derived,directly or indirectly, from gross proceeds traceable to the commission of any
violations of Title 18, United States Code, Section 1512 alleged in this
Information.
15
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 15 of 23
All pursuant to Title 18, United States Code, Section 98l(a)(1)(C), as made applicable by
Title 28, United States Code, Section 2461, and the procedures outlined at Title 21, United States
Code, Section 853.
W IFRED . FERRER
UNITED STATES ATTORNEY
œ >A F. SCH ARTZ
A SISTANT UNITED STATES ATTORNEY
' .
N
JE FRE N. KA AN
ASSISTANT UNITED STATES ATTORNEY
LA NCE D. VECCHIOASSfSTANT UNITED STATES ATTORNEY
16
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 16 of 23
UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA
VS.
KIMBERLY W ENDELL ROTHSTEIN,STACIE W EISMAN, andSCOTT F. SAIDEL,
Defendants.l
Court Divislon: (select one)
Miami Key W estx FTL W PB FTP
I do hereby certify that:
Superseding Case Information:
New Defendantts..lNumber of New Defendants
Total number of counts
CASE NO.
CERTIFICATE OF TRIAL ATTORNEYA
Yes -- No -
I have carefully considered the allegations pf the indictm#nt the number 9f defendants the number ofprobable witnesses and the Iegal complexlties of the IndlctMent/lnformatlon attached hereto.
I am qware that the information supplied gn thij ptatement will be relied upon yb the Ju id es of thisCourt ln Setting theirçalendars and scnedullng crlmlnal trlals underthe mandate of me Speeuy Trial Act,Title 28 U.S.C. Sectlon 3161 .
Iqterpreter: (Yes gr Nj MnLlst Ianguage and/or dlalecThis case will take n days for the parties to try.
Please check appropriate category and Npe of offense Iisted below:5.
6. Has this case been previously filed in this District Court? (Yes or No) Nnlf yes:Judge: Case No.(Attach copy Mf dispositive grdejHas a complalnt been filed In thls matter? (Yes or No) Mnlf yeq:Maglstrate Case No.
Related Misc#llaneous numbers:Defendantls) ln federal custody as ofDefendantls) In state custody as ofRule 20 from the District of
Is this a potential death penalty case? (Yes or No)
(Check only one)
0 to 5 days6 to 10 days1 1 to 20 days21 to 60 days61 days and over
(Check only one)
P'ttyMjnorMlsdem.Felony
Does this case or gi inate from a matterpending in the Nodhern Region of the U.S. Attorney's Office priorG03? Yes Y Noto October 14, 2
Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office priorDO7? Yes Y Noto September 1, 2
LA RENCE .D LaVECCHIOA ISTANT UNITED STATES ATTORNEYFlorida Bar Nox/court No. 0305405
*penalty Sheetts) attached REV 4/8/08
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 17 of 23
UNITED STATES DISTRICT COURT
SO UTHERN DISTRICT O F FLORIDA
PENALTY SHEET
K IM BERLY W ENDELL ROTH STEINDefendant's Nam e:
Case No:
Count #: 1
Conspiracy to Com m it M oney Launderine. to O bstruct Justice. and to Tam per W ith a
W itness
18 U.S.C. # 371
# M axppenalty: 5 years' imprisonment
Count #:
*M ax. Penalty:
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 18 of 23
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT O F FLORIDA
PENALTY SHEET
Defendant's Nam e: STACIE W EISM AN
Case No:
Count #: 1
Conspiracy to Com m it M oney Laundering. to O bstruct Justice. and to Tam per W ith a
W itness
18 U.S.C. j 371
# M ax.penalty: 5 years' imprisonm ent
Count #:
*M ax. Penalty:
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 19 of 23
UNITED STATES DISTRICT CO URT
SCOTT F. SAIDELSOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Nam e: SCOTT F. SAIDEL
Case No;
Count #: 1
Conspiracy to Com m it M oney Laundering. to O bstruct Justice. and to Tam per W ith a
W itness
18 U.S.C. # 371
# M ax.penalty: 5 years' imprisonment
Count #:
*M ax. Penalty:
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 20 of 23
AO 455 (Rev. 01/09) Waiver of an lndictment
UNITED STATES DISTRICT COURTfor the
Southern District of Florida
United States of America
V.
KIMBERLY W ENDELL ROTHSTEIN
)) Case No.)))
W AIVER OF AN INDICTM ENT
l understand that 1 have been accused of one or more offenses punishable by imprisonment for more than oneyear. I was advised in open court of my rights and the nature of the proposed charges against me.
After receiving this advice, 1 waive my right to prosecution by indictment and consent to prosecution by
information.
Date :
De#ndant 's signature
Signature ofde#ndant 's attorney
Printed name ofdefendant 's attorney
Jadge 's slknature
Judge 's printed name and title
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 21 of 23
AO 455 (Rev. 01/09) Waiver of an lndictment
U NITED STATES DISTRICT COURTfor the
Southern District of Florida
United States of America
V.
STACIE W EISMAN
)) Case No.)))
W AIVER OF AN INDICTM ENT
l understand that l have been accused of one or more offenses punishable by imprisonment for more than one
year. I was advised in open court of my rights and the nature of the proposed charges against me.
After receiving this advice, l waive my right to prosecution by indictment and consent to prosecution by
infonnation,
Ilate:
Defendant 's signatare
Signature ofdefendant 's attorney
Printed name ofdefendant 's attorney
Judge 's signature
Judge 's printed name and title
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 22 of 23
AO 455 (Rtv. 01/09) Waiver of an Indictment
UNITED STATES D ISTY CT COURTfor the
Southern District of Florida
United States of America
V.
SCOU F. SAIDEL
Case No.
W AIVER OF AN INDICTM ENT
1 understand that I have been accused of one or more offenses punishable by imprisonment for more than one
year. l was advised in open court of my rights and the nature of the proposed charges against me.
After receiving this advice, I waive my right to prosecution by indictment and consent to prosecution by
information.
De#ndant 's signature
Signature ofdefendant 's attorney
Printed name ofdefendant 's Jtlorney
Judge 's signature
Judge 's printed name and title
Case 0:12-cr-60204-RSR Document 1 Entered on FLSD Docket 09/06/2012 Page 23 of 23