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

Epstein came up with the idea of financing these bids through Towers' acquisition of two ailing Illinois insurance companies, Associated Life and United Fire. `He was hired by us to work on the securities side of the insurance companies and Towers Financial, supposedly to make a profit for us and for the

tten gains, obtained from his participation in a Defendant Epstein is sued herein in his individual capacity as well

L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN Defendant(s) Civil Action No. 18.7580

L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN Defendant(s) Civil Action No. 18.7580

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 of themselves and all ot

ch Rose Schirripa & Cheverie, LLP ("HRSC"), bring this Complaint against the Defendants, The Financial Trust Company ("TFTC"), Jeffrey E. Epstein ("Epstein"),' XYZ Corp., and ABC, Inc., as follows: INTRODUCTION I. This is an action to recover damages on behalf of Plaintiffs and members of the propose

e stocks were purchased with fupds borrowed by using insurance company bonds as collateral. Hoffenberg concealed his activities from Associated and United Fire by: routing all securities trade confirmations, periodic account statements and other communications from brokerage firms to Towers, rather than t

Page 12 The Talented Mr. Epstein; Lately, Jeffrey Epstein's high-ying style has been drawing oohs and aahs: the bachelor nancier lives in New York's largest private residence, claim

Page 12 The Talented Mr. Epstein; Lately, Jeffrey Epstein's high-ying style has been drawing oohs and aahs: the bachelor nancier lives in New York's largest private residence, claims to take only billionaire

Page 12 The Talented Mr. Epstein; Lately, Jeffrey Epstein's high-ying style has been drawing oohs

Page 12 The Talented Mr. Epstein; Lately, Jeffrey Epstein's high-ying style has be

Page 12 The Talented Mr. Epstein; Lately, Jeffrey Epstein's high-ying style has be

Epstein came up with the idea of financing these bids through Towers's acquisition of two ailing Illinois insurance companies, Associated Life and United Fire. "He was hired by us to work on the securities side of the insurance companies and Towers Financial, supposedly to make a profit for us and for the

et Jeff Epstein United Air Fleet Jeff Epstein Jeffrey Epstein Robert Biegen Sonnenschein Carlin Nath

9,695.54 25,OOO.OO 1O,88O.OO 2O,OOO.OO 25,OOO.OO 5,OOO.OO 31,21O.OO Wellesley United Air Fleet Jeff Epstein United Air Fleet Jeff Epstein Jeffrey Epstein Robert Biegen Sonnenschein Carlin Nath & Rosenthal 7O72 O3/O7/88 11,38O.13 American Express 747O O3/1O/88 2O,OOO.OO United Air Fleet 745O

ited Air Fleet 100110 11/13/87 25,000.00 Jeff Epstein 100108 11/20/87 25,000.00 Corporate Risk 100

mpanies funds. 32. Hoffenberg caused Associated and United Fire to issue or deliver insurance policies at a time when he knew that Associated and United Fire were insolvent or impaired in violation of Section 144.1 of the Illinois Insurance Code. (I11. Rev. Stat. Ch. 73 I 756.1 (1987). -8- Ron 'd NY I

n Am, TFC's attempted take-over of Emery was a dismal failure, resulting in massive trading losses to TFC. 31. In the wake of these losses to TFC, Epstein manipulated the price of Emery stock to minimize the losses when the share price began to fall. In order to do so, Epstein opened and maintained a

sing insurance company bonds as collateral. 34. Defendant Epstein and Hoffenberg concealed their unsavory activitie

davit, annexed hereto, Epstein misappropriated the proceeds for not only his personal use, but also to start his own company, Defendant TFTC. 33. United Fire and Associated lost over one million dollars ($1,000,000) on the purchase of Emery securities, due to the fact that the stock was purchased with fun

PAGE BREAK --- Case 1:19-cv-03377 Document 1-8 Filed 04/16/19 Page 2 of 16 http://www.vanityfair.com/news/2003/03/jeffrey-epstein-200303 Society The Talented Mr. Epstein Lately, Jeffrey Epstein’s high-flying style has been drawing oohs and aahs: the bachelor financier lives in New York’s largest private residence, cl

7 Document 1-8 Filed 04/16/19 Page 2 of 16 http://www.vanityfair.com/news/2003/03/jeffrey-epstein-200303 Society The Talented Mr. Epstein Lately, Jeffrey Epstein’s high-flying style has been drawing oohs and aahs: the bachelor financier lives in New York’s largest private residence, claims to take only billionai

ies celebrities including Bill Clinton and Kevin Spacey on his Boeing 727. But pierce his air of mystery and the picture changes. Vicky Ward explores Epstein’s investment career, his ties to retail magnate Leslie Wexner, and his complicated past. by e Vicky Ward June 27, 2011 12:00 am On Manhattan’s Up

/03/jeffrey-epstein-200303 Society The Talented Mr. Epstein Lately, Jeffrey Epstein’s high-flying style has

argets. Meanwhile, in order to throw the insurance regulators off, the $1.8 million was reported as being safely invested in a money-market account. United Fire’s former chief financial officer Daniel Payton confirms part of Hoffenberg’s account. He says he recalls making one or two telephone calls to Epstein (