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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01353831: Memorandum and RICO (DS10)

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This document is a confidential private placement memorandum that discusses restrictions on the transferability of investment interests under the Partnership Agreement. The excerpt also references a settlement by Raymond James with multiple jurisdictions including Puerto Rico, the Virgin Islands, and the District of Columbia regarding allegations of failure to supervise.

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Excerpt 1
As described elsewhere in this **Memorandum**, the transferability of the Interests will be further restricted by the terms of the Partnership Agreement.
Excerpt 2
("Raymond James") settled with most of the states, Puerto **Rico**, the Virgin Islands, and the District of Columbia allegations that they failed to supervise

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