Epstein Secrets

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

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

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

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,

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

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.

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

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

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

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,

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

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,

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

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,

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

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,

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

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,