Epstein Secrets

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 PLAINTIFFS' COMPLAINT TROUTMAN S

E (S) -i- EFTA00802453 TABLE OF AUTHORITIES Page(s) CASES EFTA00802454 Defendants The Financial Trust Company ("F=") and Jeffrey E. Epstein ("Epstein," and together with FTC, the "Defendants") respectfully submit this Memorandum of Law in Support of their Motion to Dismiss Plaintiffs Marvin Gerbe

knew, since at least 1997, about Hoffenberg and Defendant Epstein's alleged misconduct. This is when, according to

s for Defendants The Financial Trust Company and Jeffrey E. Epstein EFTA00802452 TABLE OF CONTENTS PAGE

s for Defendants The Financial Trust Company and Jeffrey E. Epstein EFTA00802452 TABLE OF CONTENTS PAGE (

Honor is familiar with, Mr. Jeffrey Epstein ... Mr. Epstein, I'm told, and Mr. Kramer may want to address th

fails miserably to meet this standard. Under Rule 9(b), Plaintiffs must do more than make conclusory allegations that Defendants made misstatements. Mercado v. Playa Realty Corp., No. CV 03-3427 (JO), 2005 WL 1594306, at *13 (E.D.N.Y. July 7, 2005). Plaintiffs' claims merely contend, in very general ter

lth/Source or Fundst Provide Evidence of Corporate Assets (e.g. balance sheet or equivalent summary of assets/liabities): This company Is funded by Jeffrey Epstein's personal wealth Estimated gross receipts p.a.($): 1,000,000.00 Estnoted net profit pa. (S): 1,000,000.00 SDNY_GM_00040035 https://dbforeepb.my.

a Otha please *scribe Wier roles aid/or ndicate tatlonshlp between -tanks) 1 O 121 Zorro anent, LC 9 O O O O O O O O O 2 ID O Jeffrey pstein O O O O El CI O O O O 3 • O Darren ndyko O • • O El ID I:1 O O • 4 O O O • O O El O O O O • 5 O O O O

st be established for EACH INDIVIDUAL PARTY in Section 2. Account Ownership Summa 3A. Individual Details (for all parties) Indolduars Name: 'dire/ Epstein • 00000783289 Date of Birth: 1/20/1953 Country of Residence: USV1 Country of °Wend*: USA Address of primary residence: title Saint hires Sain

n about revocabilty,settbr and benefickarles,etc.: Jeffrey Epstein is the sole manager and owner of this entity. Signors on this account wall be: Jeffrey Easter Darren Indyke Signors co the house acct are: Jeffrey Epstein Darren Indyke Please mdkate how (warship of the legal entity is reflected: D Special

d: Andrew F Gallivan 'Signature) Andrew F Gallivan Regional Office Director ,Signature) NIL Business Risk: (Signature) AM Compliance: Ralat4 Mercado Voonsun Chung (Signature) Rafael Mercado Yoonsun Chung 3/13/2017 3/13/2017 LATAM/INTERNATIONAL APPROVALS Client Facing Professional (O P) (S

From: To: "K riacou Jonathan" , merwin dela cruz , Jojo Fontanilla Cc: "Mercado, Jesus" "Pa an Javier" Eva Andersson Subject: Re: Jeffrey's Art Date: Thu, 26 Mar 2015 14:04:06 +0000 Excellent. Merwin and Jojo will bring to you. They are on this email. Can you please give the exact ad

From: To: "K riacou Jonathan" , merwin dela cruz , Jojo Fontanilla Cc: "Mercado, Jesus" "Pa an Javier" Eva Andersson Subject: Re: Jeffrey's Art Date: Thu, 26 Mar 2015 14:04:06 +0000 Excellent. Merwin and Jojo will bring to y

ce of the most pinpointed time, they'll be able to receive the artwork. > Just let us know. > • Thanks! > Jonathan • Original Message > From: Mercado, Jesus > Sent: Thursday, March 26, 2015 9:32 AM > To: Pagan, Javier > Cc: Eva Andersson; ; Kyriacou, Jonathan > Subject: RE: Jeffrey's Art > Im

From: To: "K riacou Jonathan' , Jojo Fontanilla Cc: "Mercado, Jesus" "Pa an Javier" >, Eva Andersson Subject: Re: Jeffrey's Art Date: Thu, 26 Mar 2015 14:29:42 +0000 Hi Jonathon...the sooner we can get the address and a contact number the better! We would prefer to ge

From: To: "K riacou Jonathan' , Jojo Fontanilla Cc: "Mercado, Jesus" "Pa an Javier" >, Eva Andersson Subject: Re: Jeffrey's Art Date: Thu, 26 Mar 2015 14:29:42 +0000 Hi Jonathon...the sooner we can get the

ce of the most pinpointed time, they'll be able to receive the artwork. > Just let us know. > • Thanks! > Jonathan • Original Message > From: Mercado, Jesus > Sent: Thursday, March 26, 2015 9:32 AM > To: Pagan, Javier > Cc: Eva Andersson; ; Kyriacou, Jonathan > Subject: RE: Jeffrey's Art > Im

From: To: "Kyriacou, Jonathan" Cc: "Mercado, Jesus' Subject: Re: Jeffrey's Art Date: Thu, 26 Mar 2015 14:54:42 +0000 Javier" Jonathan , Just leave it in the Dubin breast center if it gets complicated!!!! Sent from my

From: To: "Kyriacou, Jonathan" Cc: "Mercado, Jesus' Subject: Re: Jeffrey's Art Date: Thu, 26 Mar 2015 14:54:42 +0000 Javier" Jonathan , Just leave it in the Dubin breast center if it get

ce of the most pinpointed time, they'll be able to receive the artwork. > Just let us know. > • Thanks! > Jonathan • Original Message > From: Mercado, Jesus > Sent: Thursday, March 26, 2015 9:32 AM > To: Pagan, Javier > Cc: Eva Andersson; ; Kyriacou, Jonathan > Subject: RE: Jeffrey's Art > Im

From: Eva Dubin To:' Cc: "K riacou Jonathan" , Jojo Fontanilla , "Mercado, Jesus" , "Pagan, Javier" Subject: Re: Jeffrey's Art Date: Thu, 26 Mar 2015 16:14:06 +0000 Thank you!!! Sent from my iPhone > On Mar 26, 2015, at 12:13 PM, ‹ > wrote: > 3 paintings has been

From: Eva Dubin To:' Cc: "K riacou Jonathan" , Jojo Fontanilla , "Mercado, Jesus" , "Pagan, Javier" Subject: Re: Jeffrey's Art Date: Thu, 26 Mar 2015 16:14:06 +0000 Thank you!!! Sent from my iPhone > On Mar 26, 2015,

y'll be able to receive the artwork. >>>> Just let us know. >>>> >>>> Thanks! >>>> >>» Jonathan >>>> >>>> >>>> Original Message >>>> From: Mercado, Jesus >>>> Sent: Thursday, March 26, 2015 9:32 AM >>>> To: Pagan, Javier >>>> >>>> Cc: Eva Andersson; Subject: RE: Jeffrey's Art ; Kyriacou,

From: "Pagan, Javier" To: "K riacou Jonathan" , "Mercado, Jesus" Cc: ' " ale ' Subject: Re: Jeffrey's Art Date: Thu, 26 Mar 2015 16:00:40 +0000 Jon, They just arrived and want me to take it. Who is coming down for the paintings. ? Original Me

From: "Pagan, Javier" To: "K riacou Jonathan" , "Mercado, Jesus" Cc: ' " ale ' Subject: Re: Jeffrey's Art Date: Thu, 26 Mar 2015 16:00:40 +0000 Jon, They just arrived and want me to take it. Who is c

dvanced notice of the most pinpointed time, they'll be able to receive the artwork. Just let us know. Thanks! Jonathan Original Message From: Mercado, Jesus Sent: Thursday, March 26, 2015 9:32 AM To: Pagan, Javier Cc: Eva Andersson; ; Kyriacou, Jonathan Subject: RE: Jeffrey's Art Importance:

From: To: "Kyriacou, Jonathan" Cc: , Jo Fontanilla "Pa an Javier" , Eva Andersson Subject: Re: Jeffrey's Art Date: Thu, 26 Mar 2015 15:00:08 +0000 Ok. We will be there between 11:30 and 12 Thank you Merwin Dela Cruz > On Mar 26, 2015, at 10:55 AM,

me, they'll be able to receive the artwork. >>> Just let us know. >>> >>> Thanks! >>> >>> Jonathan >>> >>> >>> Original Message >>> From: Mercado, Jesus >>> Sent: Thursday, March 26, 2015 9:32 AM >>> To: Pagan, Javier >>> Cc: Eva Andersson; ; Kyriacou, Jonathan >>> Subject: RE: Jeffrey's A

From: Cc: "K riacou, Jonathan" ercado, Jesus" Javier" •, Eva Andersson Subject: Re: Jeffrey's Art Date: Thu, 26 Mar 2015 16:14:14 +0000 Jo 'o Fontanilla ,"Pagan, Great. thank you to everyone for your help On Mar 26, 2015, at 12:13 PM,

hey'll be able to receive the artwork. >>>> Just let us know. >>>> >>>> Thanks! >>>> >>» Jonathan >>>> >>>> >>>> Original Message »» From: Mercado, Jesus >>>> Sent: Thursday, March 26, 2015 9:32 AM >>>> To: Pagan, Javier >>>> >>>> Cc: Eva Andersson; Subject: RE: Jeffrey's Art ; Kyriacou,

From: Merwin Dela cruz <a> To: ==. > Cc: "K riacou, Jonathan" Eva Andersson , "Mercado, Jesus" "Pagan, Javier" Subject: Re: Jeffrey's Art Date: Wed, 25 Mar 2015 20:30:36 +0000 There are 3 paintings biggest is 73x65 inches and smallest is 56x58 inches. Please let me know if you

From: Merwin Dela cruz <a> To: ==. > Cc: "K riacou, Jonathan" Eva Andersson , "Mercado, Jesus" "Pagan, Javier" Subject: Re: Jeffrey's Art Date: Wed, 25 Mar 2015 20:30:36 +0000 There are 3 paintings biggest is 73x65 inches and smalle