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

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 THEIR MOTION TO DISMISS PLAINTIFF

T OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO FED. R. CIV. P. 41(a) PLEASE TAKE N

on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO FED. R. CIV. P. 41(a) PLEASE TAKE NOTICE, that MARVIN GERBER AND

used the monies he misappropriated and earned from his illegal trading activities and used them as start-up capital for his corporations, including The Financial Trust Company. 19. Epstein conceived many ways we could cover up our dubious activities. Some of the actions we took included routing all securities trades conf

IN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Plaines) v. fNE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN Defendant(s) Civil Action No. 18.7580 SUMMONS IN A CIVIL ACTION To: (Defendant's name and address) The Financial Trust Co

F NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Index No. I : I8-C V-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO FED. R. CIV. P. 41(a) PLEASE TAKE N

behalf of themselves and all others similarly situated, Index No. I : I8-C V-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO FED. R. CIV. P. 41(a) PLEASE TAKE NOTICE, that MARVIN GERBER AND

T OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO FED. R. CIV. P. 41(a) PLEASE TAKE N

on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO FED. R. CIV. P. 41(a) PLEASE TAKE NOTICE, that MARVIN GERBER AND

T OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO FED. R. CIV. P. 41(a) PLEASE TAKE N

on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO FED. R. CIV. P. 41(a) PLEASE TAKE NOTICE, that MARVIN GERBER AND

T OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO FED. R. CIV. P. 41(a) PLEASE TAKE N

on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO FED. R. CIV. P. 41(a) PLEASE TAKE NOTICE, that MARVIN GERBER AND

COURT SOUTHERN DISTRICT OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. Case No. INITIAL COMPLAINT ECF CASE Marvin Gerber and Kalma Koenig (collectiv

ERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. Case No. INITIAL COMPLAINT ECF CASE Marvin Gerber and Kalma Koenig (collectively "Plaintiffs"), on behalf

T OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO FED. IL CIV. P. 41(a) PLEASE TAKE N

on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PURSUANT TO FED. IL CIV. P. 41(a) PLEASE TAKE NOTICE, that MARVIN GERBER AND