Epstein Secrets

ssions ("OFM") of the United States Department of State (the "State Department") against defendants Jeffrey E. Epstein ("Epstein"), Ivan S. Fisher ("Fisher"), Ellyn Bank, Debra Elisa Cohen, Diane Fisher d/b/a The Fisher Group, Fisher & Soifer a/Ida Fisher & Sophir, D. Gerzog, Robert Heilbrun, Suzanne

sion of the Premises to the Government. 3. Defendant Fisher is a resident of the State of New York and is an unapproved subtenant of the Premises. Fisher has availed himself of the use and benefits of the Premises and has failed to surrender possession of the Premises to the Government. Defendant Elly

& SOPHIR, D. GERZOG, ROBERT HEILBRUN, : SUZANNE McDERMOTT, CHRISTOPHER H. MARTIN, JESSIE SIEGEL a/Ida : JESSE SIEGEL, SIEGEL, MARTIN & HEILBRUN, RON SOFFER, CARMEN TALSIG, : JOHN DOES 1 through 10 and X CORPORATIONS 1 through 10, : Defendants. : x The United States of America, by its attorney, Mary

766 EFTA _00229415 EFTA01324981 Department of State (the "State Department") against defendants Jeffrey E. Epstein ("Epstein"), Ivan S. Fisher ("Fisher"), Ellyn Bank, Debra Elisa Cohen, Diane Fisher d/b/a The Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, Lawrence D. Gerzog, Robert Heilbrun,

ion of the Premises to the Government. 5. Defendant Fisher is a resident of the State of New York and is an unapproved subtenant of the Premises. Fisher has availed himself of the use and benefits of the Premises and has failed to surrender possession of the Premises to the Government. 6. Defendan

HIR, LAWRENCE D. GERZOG, ROBERT HEILBRUN, SUZANNE McDERMOTT, CHRISTOPHER H. MARTIN, JESSIE SIEGEL a/k/a JESSE SIEGEL, SIEGEL, MARTIN & HEILBRUN, RON SOFFER, CARMEN TALSIG, JOHN DOES 1 through 10 and X CORPORATIONS 1 through 10, Defendants. : 96 Civ. 8307 (DC) SECOND AMENDED COMPLAINT The United St

y judgment on its second cause of action in the second amended complaint for an order ejecting defendants Diane Fisher a/k/a The Fisher Group ("Ms. Fisher") and Ron Soffer ("Soffer")' from the premises known as 34 East 69th Street, New York, New York (the "premises"). On February 2, 1998, the Governme

Administration for attorney registration purposes (see id., Exhs. E-F). The Government has not consented to the occupancy of the premises by any of Fisher's subtenants, including the present respondents (Massey Dec. ¶ 2 & n.1). Accordingly, the present SONY_GM_02742791 EFTA _00229440 EFTA01325006

--------- ----X GOVERNMENTS MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR PARTIAL SUMMARY JUDGMENT EJECTING DIANE FISHER d/b/a THE FISHER GROUP AND RON SOFFER FROM THE PREMISES Preliminary Statement Plaintiff United States of America (the "Government") respecffully submits this memorandum of law in supp