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

PRIVILEGED AND CONFIDENTIAL; ATTORNEY WORK PRODUCT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X MARVIN GERBER AND KALMA KOENIG, : on behalf of themselves and all others similarly : situated, Plaintiffs, -against- THE FINANCIAL TRUST COMPANY, XYZ CORPORAT

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

12 Filed 08/22/18 Page 1 of 1 AO 440 (Rev. 06/12) Sim /mons in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of New York MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Plaines) v. fNE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC.

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

Case 1:18-cv-07580 Document 1 Filed 08/20/18 Page 1 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC,

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

Case 1:18-cv-07580-JPO Document 19 Filed 10/05/18 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Index No. I : I8-C V-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPA

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

Case 1:18-cv-07580-JPO Document 19 Filed 10/05/18 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY,

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

Case 1:18-cv-07580-JPO Document 19 Filed 10/05/18 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY,

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

Case 1:18-cv-07580-JPO Document 19 Filed 10/05/18 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY,

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

Case 1:18-cv-07580-JPO Document 19 Filed 10/05/18 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY,

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

Case 1:18-cv-07580-JPO Document 19 Filed 10/05/18 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Index No. 1:18-CV-07580 Plaintiffs, v. THE FINANCIAL TRUST COMPANY,