Epstein Secrets

DISTRICT OF NEW YORK X MARVIN GERBER AND KALMA KOENIG, : on behalf of themselves and all others similarly : situated, Plaintiffs, -against- THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. X Index No. 1:18-cv-07580-JPO DEFENDANTS' MEMORANDUM OF LAW IN SUPPORT OF THEI

is one "where a plaintiff could show that it would have been impossible for a reasonably prudent person to learn about his or her cause of action." Pearl v. City of Long Beach, 296 F.3d 76, 85 (2d Cir. 2002) (internal quotation marks omitted). Lefebvre v. Morgan, 234 F. Supp. 3d 445, 459 (S.D.N.Y. 20

com" [email protected]> Cc: ' II Subject: Update Date: Thu, 30 Apr 2009 16:15:23 +0000 To JEE: Confirming the following I: Tom Melnink -Tom & FTC informed of changes to payroll. Tom wished to express his gratitude to you 2: Anna wished to thank you for the offer for the mattresses. I will arra

to thank you for the offer for the mattresses. I will arrange to get them to her next week 3: Confirmed with Sarah to contact Pinto in reference to Pearl inlay furniture. Janusz will place the pieces in PBI house back into storage. 3: Contacted Doug to arrange for delivery to PBI of security doors at

To: Cc: From: Sent Subject Update Thur 4/30/2009 4:15:23 PM To JEE: Confirming the following I: Tom Melnink -Tom & FTC informed of changes to payroll. Tom wished to express his gratitude to you 2: Anna wished to thank you for the offer for the mattresses. I will arr

wished to thank you for the offer for the mattresses. I will arrange to get them to her next week 3: Confirmed with' contact Pinto in reference to Pearl inlay furniture. Janusz will place the pieces in PBI house back into storage. 3: Contacted Doug to arrange for delivery to PBI of security doors at