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

94, Hoffenberg was indicted on various fraud charges, in multiple jurisdictions, including the SDNY. (Comp!. ¶¶ 51-52). • On March 4, 1997, "Judge Robert Sweet issued a Sentencing Opinion ("Sentencing Opinion") which lays bare the fraudulent conduct that resulted in Hoffenberg's conviction and which was im

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

s 2 In United States of America v. Steven Hoffenberg, 94 Cr. 213 (RWS), 95 Cr. 321 (RWS), 1997 U.S. Dist. LEXIS 2394 (S.D.N.Y. Mar. 4, 1997), Judge Robert Sweet issued a Sentencing Opinion ("Sentencing Opinion") which lays bare the fraudulent conduct that resulted in Hoffenberg's conviction and which was im

VIA ECF Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Judge Koeltl: We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") and write to respon

Defendants") and write to respond to Bradley J. Edwards' letter of October 5, 2017. Mr. Edwards' contention that Plaintiff be allowed to depose Mr. Epstein on the ground that Defendants have been engaging in discovery from another matter before Judge Robert Sweet is baseless. Defendants have not engage

within seven (7) days. The Court then can dispose of the matter in its entirety. Respectfully submitted, Michael C. Miller Counsel for Defendants Jay Epstein and Lesley Groff Doc # DC-10491295 v.1 EFTA00583064

eet New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear

' contention that Plaintiff be allowed to depose Mr. Epstein on the ground that Defendants have been engaging

tion that Plaintiff be allowed to depose Mr. Epstein on the ground that Defendants have been engaging in discovery from another matter before Judge Robert Sweet is baseless. Defendants have not engaged in any discovery; rather, it is the Plaintiff who is seeking to engage in a one-sided and premature fishin

VIA ECF Hon. John O. 'Coal United States District Court United States Courthouse 500 Pearl Street New York, NY 10007.1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Judge Koeltl: Steptoe ......... ji b. We are counsel for Defendants Jeffit E stein and In the above-ref

York, NY 10007.1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Judge K

eet New York, NY 10007.1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear

erning the Ili on and documents Plaintiff produced as a non-party witness in an action captioned v. Mayen, 15 Civ. 7433 (RWS), pending before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the

10. Counsel for both sets of Defendants have scheduling conflicts on that date. Respectfully submitted, Michael C. Miller Counsel for Defendants Jeffrey Epstein and 1 A copy of the motion submitted to Judge Sweet is being submitted-sicaultaneeuelysfl to Your Honor-under-seal. poc # DC-104&4395 v 2 EFTA0

York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Judge K

eet New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear

ning the /l ion and documents Plaintiff produced as a non-party witness in an action captioned v. Maxwell, 15 Civ. 7433 (RWS), pending before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the

10. Counsel for both sets of Defendants have scheduling conflicts on that date. Respectfully submitted, Michael C. Miller Counsel for Defendants Jeffrey Epstein and ME Once the motion to modify the Protective Order is submitted to Judge Sweet, we will provide Your Honor with a courtesy copy. EFTA00584088

ichael C. Miller Counsel for Defendants Jeffrey Epstein and ME Once the motion to modify the Protective

eet New York, NY 10007-1312 Re: Jane Doe 43 v. Jeffrey E stein, et al. Civil Actio Dear Judge Koeltl: W

July 17, 2017 concerning the de l ion and documents Plaintiff roduced as a non-party witness in an action captioned v. Maxwell nding before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the

From: Kathy Ruemmler Sent: Tuesday, September 22, 2015 6:01 PM To: Jeffrey E. Case is assigned to Judge Robert Sweet. Senior Judge, Carter appointee. Fo=mer prosecutor and Skadden partner in the 1970s. Sent from my iPhone=?xml ver

Sent: Tuesday, September 22, 2015 6:01 PM To: Jeffrey E. Case is assigned to Judge Robert Sweet. Senior

Sent: Tuesday, September 22, 2015 6:01 PM To: Jeffrey E. Case is assigned to Judge Robert Sweet. Senior J

From: Kathy Ruemmler Sent: Tuesday, September 22, 2015 6:01 PM To: Jeffrey E. Case is assigned to Judge Robert Sweet. Senior Judge, Carter appointee. Fo=mer prosecutor and Skadden partner in the 1970s. Sent from my iPhone=?xml version=.0" encoding=TF-8"?> <IDOCTYP

From: Kathy Ruemmler Sent: Tuesday, September 22, 2015 6:01 PM To: Jeffrey E. Case is assigned to Judge Robert Sweet. Senior Judge, Carter appointee. Fo=mer prosecutor and Skadden partner in the 1970s. Sent from my iPhone=?xml ver

Sent: Tuesday, September 22, 2015 6:01 PM To: Jeffrey E. Case is assigned to Judge Robert Sweet. Senior

Sent: Tuesday, September 22, 2015 6:01 PM To: Jeffrey E. Case is assigned to Judge Robert Sweet. Senior J

From: Kathy Ruemmler Sent: Tuesday, September 22, 2015 6:01 PM To: Jeffrey E. Case is assigned to Judge Robert Sweet. Senior Judge, Carter appointee. Fo=mer prosecutor and Skadden partner in the 1970s. Sent from my iPhone=?xml version=.0" encoding=TF-8"?> <IDOCTYP

From: Kathy Ruemmler Sent: Tuesday, September 22, 2015 6:01 PM To: Jeffrey E. Case is assigned to Judge Robert Sweet. Senior Judge, Carter appointee. Fo=mer prosecutor and Skadden partner in the 1970s. Sent from my iPhone=?xml ver

Sent: Tuesday, September 22, 2015 6:01 PM To: Jeffrey E. Case is assigned to Judge Robert Sweet. Senior

Sent: Tuesday, September 22, 2015 6:01 PM To: Jeffrey E. Case is assigned to Judge Robert Sweet. Senior J

From: Kathy Ruemmler Sent: Tuesday, September 22, 2015 6:01 PM To: Jeffrey E. Case is assigned to Judge Robert Sweet. Senior Judge, Carter appointee. Fo=mer prosecutor and Skadden partner in the 1970s. Sent from my iPhone=?xml version=.0" encoding=TF-8"?> <IDOCTYP

scheme, from banks, financial institutions, and current investors. 2. While Hoffenberg was convicted as a result of his role in this Ponzi scheme, Epstein has remained an uncharged co-conspirator.2 All the while, Epstein knowingly and intentionally utilized funds he fraudulently diverted and obtained

s 2 In United Stales of America v. Sleven Hoffenberg, 94 Cr. 213 (RWS), 95 Cr. 321 (RWS), 1997 U.S. Dist. LEXIS 2394 (S.D.N.Y. Mar. 4, 1997), Judge Robert Sweet issued a Sentencing Opinion ("Sentencing Opinion") which lays bare the fraudulent conduct that resulted in Hoffenberg's conviction and which was im