Ootg (4600 Electronically Filed 10/02/2013 11:09:05 AM ET Case No.: 09.062943(19) Amended Complaint 38. The scheme was predicated on the Principal Conspirators self-professed pipeline of pre-suit, confidential settlement agreements as the "preeminent sexual harassment and labor employment law firm in the country." Investors were told that the Principal Conspirators had an extensive in-house private investigative team, including former F.B.I. and C.I.A. agelts, whose singular task was to obtain compromising evidence against high-profile putative defendants. Rothstein's story was that the evidence and surveillance acquired, often supporting civil causes of action ranging from sexual harassment to mass tort cover-ups to ;chistle-blower claims, was at presented to the putative defendant who was then offered an opportun o avoid litigation and the negative publicity associated therewith by agreeing to4eilfe the matter voluntarily by and through a confidential settlement with the putative plaintiff. ') 39. Once the putative defendant agreed, the confidential settlement always included two main ingredients: (1) that struct generally a three to nine month to ts to a putative plaintiff be made over time, and (2) that the putative defendant would fund the entire settlement up front to be held in RRA's TD Bank trust account and disbursed to the putative plaintiff in accordance with the terms of the confidential settlement agreement. The Pitch k C informed investors that the putative plaintiffs did not want to wait for Roth. IS the structured monthly payouts and would agree to assign their rights to the structured payout for a lump-sum payment typically at a discount in the range of 20-40% of the settlements' facevalue. _Rothstein always had a plethora of plausible explanations as to why a putative plaintiff wanted their money now and simply could not wait for the structured monthly payments. Page 13 of 289 EFTA02773532