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

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, -against- THE FINANCIAL TRUST COMPANY, XYZ CORPORAT

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

Case 1:18-cv-07580-JPO Document 19 Filed 10/05/18 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT 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,

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

12 Filed 08/22/18 Page 1 of 1 AO 440 (Rev. 06/12) Sim /mons in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of New York MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Plaines) v. fNE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC.

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

Case 1:18-cv-07580-JPO Document 19 Filed 10/05/18 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF 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 COMPA

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

Case 1:18-cv-07580-JPO Document 19 Filed 10/05/18 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT 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,

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

Case 1:18-cv-07580-JPO Document 19 Filed 10/05/18 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT 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,

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

Case 1:18-cv-07580-JPO Document 19 Filed 10/05/18 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT 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,

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

Case 1:18-cv-07580 Document 1 Filed 08/20/18 Page 1 of 26 UNITED STATES DISTRICT 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,

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

Case 1:18-cv-07580-JPO Document 19 Filed 10/05/18 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT 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,