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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
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
6 mentions1 same-page
Page ?Same page
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
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
6 mentions1 same-page
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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 T►ust 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
en 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, Defendants. Case No. INITIAL COMPLA
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. Case No. INITIAL COMPLAI
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
Sponsored
5 mentions1 same-page
Page ?Same page
selves 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 KALMA KOENIG, on behalf
ANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PUR
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DIS
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISM
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
5 mentions1 same-page
Page ?Same page
hemselves 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 KALMA KOENIG, on behalf
ANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PUR
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DIS
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISM
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
5 mentions1 same-page
Page ?Same page
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DIS
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISM
hemselves 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 KALMA KOENIG, on behalf
ANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PUR
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
Sponsored
5 mentions1 same-page
Page ?Same page
hemselves 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 KALMA KOENIG, on behalf
ANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PUR
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DIS
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISM
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
5 mentions1 same-page
Page ?Same page
hemselves 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 KALMA KOENIG, on behalf
ANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PUR
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DIS
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISM
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
5 mentions1 same-page
Page ?Same page
hemselves 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 KALMA KOENIG, on behalf
ANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISMISSAL PUR
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DIS
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. NOTICE OF VOLUNTARY DISM
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
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Mutual Connections (19)
Entities connected to both Jeffrey Epstein and ABC, INC.
the Southern District
LOCATION2,140 w/ Jeffrey·6 w/ ABC,
New York
LOCATION1,992 w/ Jeffrey·2 w/ ABC,
Financial Trust Company
ORGANIZATION1,281 w/ Jeffrey·9 w/ ABC,
Hillary Clinton
PERSON687 w/ Jeffrey·7 w/ ABC,
Southern District of New York
ORGANIZATION686 w/ Jeffrey·2 w/ ABC,
the United States District Court
ORGANIZATION526 w/ Jeffrey·2 w/ ABC,
Steven Hoffenberg
PERSON256 w/ Jeffrey·3 w/ ABC,
FED R.QP
ORGANIZATION34 w/ Jeffrey·2 w/ ABC,
Towers Financial
ORGANIZATION27 w/ Jeffrey·3 w/ ABC,
MG
MARVIN GERBER
PERSON9 w/ Jeffrey·9 w/ ABC,
HN
Hillary M. Nappi
PERSON7 w/ Jeffrey·7 w/ ABC,
Associated Life
ORGANIZATION12 w/ Jeffrey·2 w/ ABC,
XYZ Corp.
ORGANIZATION12 w/ Jeffrey·2 w/ ABC,
DR
Daniel B. Rehns
PERSON7 w/ Jeffrey·7 w/ ABC,
HACH ROSE SCHIRRIPA & CHEVERIE LLP
ORGANIZATION7 w/ Jeffrey·7 w/ ABC,
RS
Robert Sweet
PERSON10 w/ Jeffrey·2 w/ ABC,
FS
Frank R. Schirripa
PERSON5 w/ Jeffrey·5 w/ ABC,
United Fire
ORGANIZATION6 w/ Jeffrey·2 w/ ABC,
KK
Kalma Koenig
PERSON4 w/ Jeffrey·2 w/ ABC,