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

(6). I. PRELIMINARY STATEMENT: MULTIPLE SDNY JUDGES WARNED THE PERSON DRIVING THIS ACTION AGAINST SUCH FRIVOLOUS LAWSUITS Judges Sweet, Berman and Castel warned Steven Hoffenberg ("Hoffenberg"), whom Plaintiffs identify as the "Non-Party Affiant" (Compl. 15) and whose affidavit forms the entire basi

ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa

f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

Y. 1655 Pike DeleePh.„,.. .ML lt Fst!ii!lefleach, IR. »CI 1 0 C) Par 1 sprat your tether rear*, taw fifty sullierdoller 2 leoseit arrest Jeffrey ipater says that pH, lir with 3 your aunt and tale ad bar bra liar trots le that I Cerrees7 S Us. 6 0. Iles ray have you bra lira with P

es the United States take any position regarding Defendant Epstein's performance of hi s obligations pursuant to th

have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push

thei't NW ass. sir. O. 00 yea know who Doff fey Slow NI A. N. Pie. 0. Clo yet hew who J'effroy Mnia 14/ A. 0. That.. the layer who flest and Spytein os ynr nYlf. tleht7 500•11 au In. Noun •Pmetted piet hally any M. LIN101.0i hey coriertetlere that ~et had with At. Soso 'Nordin.; Not Issue. y

9 A. I don't tnov. 20 O. You dart know. That's year lisover? 21 A. Yes. 22 0. Nov your parents filed the police report 23 regarding Mr. Castel*, right? 24 A. Yoe. 25 0. Nov pear parents are also lying. aren't e isor&Associates sevoirsetneen•ean. Page 116 they? 2 A. Yes. 9 to.

morning, Your Honor. Bennet Moskowitz; Troutman Sanders, here with my colleague Charles Glover, and we represent the co-executors of the Estate of Jeffrey E. Epstein as well as with certain exceptions various other defendants in the actions for which we're here today. To explain that a little further -- THE COUR

minally abused, sexually abused by Mr. EFTA00078908 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 15 Epstein. There was radio silence, complete radio silence on their end for week after week despite repeated entreaties from myself and others for us to have

d we represent the co-executors of the Estate of Jeffrey E. Epstein as well as with certain exceptions vario

d we represent the co-executors of the Estate of Jeffrey E. Epstein as well as with certain exceptions variou

settle claims and what assets are going to go to Mr. Epstein's brother. We've had zero disclosure about that.

rred to me for general pretrial supervision which will include decisions like that, it would be nice to have some uniformity. So I know that Judge Castel has already issued a couple of orders. MR. MOSKOWITZ: Your Honor, I have an update. I apologize to interrupt. I do have an update about this issue.

2020 22:36:04 +0000 Attachments: 0I -30-2020.pdf SDNY News Clips Thursday, January 30, 2020 EFTA00095957 Contents Public Corruption Avenatti Epstein Parnas Terrorism and International Narcotics Virgil Griffith White Plains Grogg Matters of Interest Weinstein Bolton Public Corruption Aven

child (and reported favorite) of Queen Elizabeth, he was attempting to get his life together after a disastrous interview about his friendship with Jeffrey Epstein made him headline news last November. For Andrew, that has meant a lot of driving around, attending some parties, not attending others, and sneaking

a disastrous interview about his friendship with Jeffrey Epstein made him headline news last November. Fo

losed in 2016. "There has been a renewed focus on Mr. Epstein's friends and associates which could potentially

efense had no basis to make the request, but the government would comply with production requirements under federal rules of civil procedure. Judge Castel did not make a firm ruling on the request, instead telling Klein, "If there's an application under [the rules], I would expect you and encourage you

SDNY News Clips, Thursday, January 30, 2020 SDNY News Clips Thursday, January 30, 2020 Contents Public Corruption 2 Avenatti 2 Epstein 4 Pamas 8 Terrorism and International Narcotics 9 Virgil Griffith 9 White Plains 10 Grogg 10 Matters of Interest 11 Weinstein 11 Bolt

child (and reported favorite) of Queen Elizabeth, he was attempting to get his life together after a disastrous interview about his friendship with Jeffrey Epstein made him headline news last November. For Andrew, that has meant a lot of driving around, attending some parties, not attending others, and sneakin

a disastrous interview about his friendship with Jeffrey Epstein made him headline news last November. Fo

losed in 2016. "There has been a renewed focus on Mr. Epstein's friends and associates which could potentially

efense had no basis to make the request, but the government would comply with production requirements under federal rules of civil procedure. Judge Castel did not make a firm ruling on the request, instead telling Klein, "If there's an application under [the rules], I would expect you and encourage you

ur dliteo$4.14., es wt aeons that oulmAlen. 91 A. MIS: Q. yes knew that Hr. loepolti recently filed a 'anon in Memel court on Yes beheil sprint Jeffrey Epstein warm fifty a11101: dollars/ Mt. 11014140: Seas adeetion. SS yen Neil the soar to that outside se oar Sleeves:sm. pal my answer. If M. is the .niy

r 0 )cn Set to Eptttn'e Pena cos had Dent told Jell tat you wore Leder IS. Tdati A. lb. Q. Potosi yo0 pot to Cpstele's forte lad sot ever told Jaffrey that yes wore code, let A. PO. t sear sate to the won before that. And yes only went to Jot( Austen°, torso that one tine Ono year. no. corral,.

don't you? 12 A. incorrect. 13 MR. IZOPOLOt 0403•Ctien. Arguna 14 BY IS. TAM 15 0. Sorry? 16 A. lecorrett. 17 O. The day you weot to Epstein's house you 10 lied to you: father about where yea wet* going/ isn't 19 that correct? 20 A. Correct. 21 O. You .dotted to the polies that y

t day? Who we) the other girl fn tea rot with yea 0 3 5 a 9 10 11 12 13 14 15 16 22 10 19 20 21 22 23 21 ?5 Page 3 «elect nth Jeffroy ante!.. Oar 2 A. Mitntis nod/ boa op ad Ouse.) 0. calf ant .-sailed yoo, did he) A. SO. O. Jeff never ono moseand you, did at A. So. Jo

Oblectin. Seel of founds:son. *sal and .n.wer.d. 9 Sn VIIMInti 1 avid loan PediablY aced 10 tat, Ye, 11 " M. Vitt: 12 0. Yin OnIn't can Mr. Castel& to WV that 13 you veto lyung about you: ago, right' 14 A. Corext. 15 0. you ding sat Yr tp•tela to sew that 16 you raw not le yet. sight'

ions with the New York City Probation Office were unusual. Mr. Hoffenberg was told he was not allowed to speak to certain individuals, including Mr. Jeffrey Epstein and that his ability to work was limited. 18. On November 15, 2013, Mr. Hoffenberg's probation officers filed sealed papers against Mr. Hoffenberg

g be permitted to engage in any occupation as long as it was not with Towers Financial and that he could speak with anyone he wished, including Mr. Epstein, from whom Mr. Hoffenberg believed he could possibly collect a large debt. In doing so, Judge Sweet removed the barriers to Mr. Hoffenberg working

ed to speak to certain individuals, including Mr. Jeffrey Epstein and that his ability to work was limited

he could speak with anyone he wished, including Mr. Epstein, from whom Mr. Hoffenberg believed he could poss

ted to the Court on December 3, 2013, pursuant to the Crime Victims' Rights Act 18 U.S.C. § 3771 (the "CVRA") ("the Petition"). In the Order, Judge Castel questioned whether M&F's representation of the Petitioners and Mr. Steven Hoffenberg is consistent with our professional responsibilities citing in

06 PALM BEACH POLICE DEPARTMENT Page: 48 Time: 9:27:55 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) who were taken to Epstein s house to provide massages. further stated she had been to the house approximately 4 or times Il the ast year. She accompanied with the victi

nything extra and they were not comfortable just to tell him and he would stop. stated received $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, the victim, as she stated she was I at she went to the house, she sat in the an

200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be t

prepared and the proper oils were taken out. left the room and waited downstairs for stated E stein entered the room wearing a towel and advised Epste n a masturbate every time s e prove e a massage. She stated Epstein continued to masturbate until he climaxed; once that occurred the massage was ove

Endorsements: • Date of Birth: Race: W Sex: F Height 5'5 DEERFIELD BEACH BROWARD 33442-8445 CDL Original Prey DL Number: State: PBatch: Castel': - Issued: 00/00/00 Issued: 00/00/00 Vis: 03P U Si 021' DL Exams Rule: 02F Drive: 00 Mtr: 00 00 CDL Exams Vis: 00 Gen 00 Air. 00 Duplicate Li

• In re: Jeffrey Epstein (USA() # 2018R01618) ( ): Along with the FBI, we are investigating allegations that, over the course of a decade or more, Jeffrey Epstein sexually abused dozens of minors, including minors who were transported to/from New York for the purpose of being sexually abused. In 2008, Epstein

Epstein sexually abused dozens of minors, including minors who were transported to/from New York for the purpose of being sexually abused. In 2008, Epstein resolved a then-pending federal investigation being run by the U.S. Attorney's Office for the Southern District of Florida with a Non-Prosecution A

32 EFTA00095022 33 EFTA00095023 • In re: Jeffrey Epstein (USA() # 2018R01618) ( ): Along with the

A00094992 B. Additional Significant Cases 3 EFTA00094993 4 EFTA00094994 C. Upcoming Trials 9/30/19 U.S. v. Hernandez (Bove/Houle/Richman) (Castel, J.) (USAO # 2008R02282): Drug-trafficking and firearms trial of a Honduran Congressman (and brother of the Honduran President). 10/21/19 U.S. v.