Epstein Secrets

PRIVILEGED AND CONFIDENTIAL; ATTORNEY WORK PRODUCT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X MARVIN GERBER AND KALMA KOENIG, : on behalf of themselves and all others similarly : situated, Plaintiffs,

pectfully submit this Memorandum of Law in Support of their Motion to Dismiss Plaintiffs Marvin Gerber ("Gerber") and Kalma Koenig's (together with Gerber, the "Plaintiffs") time-barred and otherwise deficient Complaint [ECF 7] in its entirety and with prejudice pursuant to Fed. R. Civ. P. 9(b) and 12(

lants, v. JAN JONES INTERNATIONAL, INC. a/k/a ICON BY JAN JONES, Defendant-Appellee. In re EDWARD MORSE and CAROL MORSE, Petitioners. Appeal from the United States District Court for the Southern District of Florida (Under Seal- Civ-Mana), Kenneth A. Marra, Judge. PETITIONERS' MOTION FOR EMERGENCY WRIT OF MANDAMUS Petitioner

in the integrity of the confidentiality order issued in this matter by the Court below, as well as having heard directly from Judge Marra and Judge Gerber, we find as follows: Findings of Fact 1. The Court below entered orders on March 25, 2009 and April 23, 2009, specifying that certain specific ac

ants, r. JAN JONES INTERNATIONAL, INC. afirla ICON BY JAN JONES, Defendant-Appellee. In re EDWARD MORSE and CAROL MORSE, Petitioners. Appeal from the United States District Court for the Southern District of Florida (Under Seal- Civ-Marra), Kenneth A. Marra, Judge. PETITIONERS' MOTION FOR EMERGENCY WRIT OF MANDAMUS Petitione

in the integrity of the confidentiality order issued in this matter by the Court below, as well as having hoard directly from Judge Marra and Judge Gerber, we find as follows: Finding! of Fact L. The Court below entered orders on March-25, 2009 and April 23, 2009. specifying that certain specific ac

ES INTERNATIONAL, INC. a/k/a ICON BY JAN JONES, Defendant- Appellee. In re EDWARD MORSE and CAROL MORSE, Petitioners. August 13, 2009. Appeal from the United States District Court for the Southern District of Florida (Under Seal-Civ-Marra), Kenneth A. Marra, Judge. On Petition for Writ of Mandamus. Before Susan H. Black, Cir

in the integrity of the confidentiality order issued in this matter by the Court below, as well as having hoard directly from Judge Marra and Judge Gerber, we find as follows: Findings of Fact I. The Court below entered orders on March-25, 2009 and April 23, 2009, specifying that certain specific ac