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

as Ex. E to the Moskowitz Decl. 6 A true and correct copy of the Order is attached as Ex. F to the Moskowitz Decl. 7 A true and correct copy of the Petition is attached as Ex. G to the Moskowitz Decl. 8 See Complaint, Hoffenberg v. Epstein, No. I: 1 &cv-03989-RJS (S.D.N.Y. May 27, 2016). -2- EFTA0080245

nformatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November 6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012. 86. Though often absent in the o

n reports the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 10. According to the Petition, the assets in the Virgin Islands thus far includes: a. $56.5 million in cash; EFTA00104217 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint

nformatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November 6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012. 86. Though often absent in the o

n reports the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 10. According to the Petition, the assets in the Virgin Islands thus far includes: a. $56.5 million in cash; EFTA00104292 Case 1:19-cv-08673-KPF-DCF Document 45-1 Filed 01/15/

Filed 09/01/20 Page 19 of 55 GVI v. Estate of Jeffrey Epstein GVI's First Amended Complaint Page 18 of 55 approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November 6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012. 89. Though often absent in the o

n reports the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 12. According to the Petition, the assets in the Virgin Islands thus far includes: a. $56.5 million in cash; b. $127 million in fixed income and equity investments; c. $195 mil

nformatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November 6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012. 86. Though often absent in the o

n reports the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 10. According to the Petition, the assets in the Virgin Islands thus far includes: a. $56.5 million in cash; EFTA00086803 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint

nformatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November 6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012. 86. Though often absent in the o

n reports the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 10. According to the Petition, the assets in the Virgin Islands thus far includes: a. $56.5 million in cash; EFTA00074773 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint

it organizations, all of which had accounts with JP Morgan: 2013 Butterfly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, and Southern Trust Company. 28.

reported the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 13. According to the Petition, the assets in the Virgin Islands thus far included: a. $56.5 million in cash; b. $127 million in fixed income and equity investments; c. $195 mil

it organizations, all of which had accounts with JP Morgan: 2013 Butterfly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, and Southern Trust Company. 28.

reported the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 13. According to the Petition, the assets in the Virgin Islands thus far included: a. $56.5 million in cash; b. $127 million in fixed income and equity investments; c. $195 mil