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

v. Schulte Roth & Zable, 210 F. Supp. 2d 286, 289 (S.D.N.Y. 2001). 3 See Hoffenberg v. Hoffman & Pollok, 288 F. Supp. 2d 527, 540 (S.D.N.Y. 2003) (Sweet, J.) (emphasis added)). 4 See 200,000 Towers Inv'rs Restitution Victims v. United States, No. 3-cv-8563, 2013 WL 6673612, at •1 (S.D.N.Y. Dec. 18, 2013

most importantly, Professor Cassell has been working closely with Ms. as her attorney for nearly two years on issues related to her sexual abuse by Jeffrey Epstein and his co-conspirators -- including active work in legal research and other aspects of this case. Professor Cassell is a valuable part of Ms. lega

on issues related to her sexual abuse by Jeffrey Epstein and his co-conspirators -- including active work

wo years on issues related to her sexual abuse by Jeffrey Epstein and his co-conspirators -- including act

WL 508269, at *3 (S.D.N.Y. Feb. 27, 2009) (citing Ritchie, 2008 WL 4178152 at *14; Stratavest Ltd. v. Rogers, 903 F.Supp. 663, 668 (S.D.N.Y.1995) (Sweet, J.) ("it is too early at this point in the proceeding [i.e., during discovery] to determine [whether counsel's testimony would be necessary]"; McDonal

s federal civil actions in Florida. Compl. ¶ 8-21, 26-27. Ms. Maxwell was not a party to any of those litigations: not the criminal case against Mr. Epstein (Compl. ¶ 14), any non-prosecution agreement between Mr. Epstein and the U.S. Attorney's Office (Comp1.11 11-13), the litigation concerning the Cri

those litigations: not the criminal case against Mr. Epstein (Compl. ¶ 14), any non-prosecution agreement bet

which the challenged statements are not "reasonably susceptible of a defamatory meaning." Krepps v. Reiner, 588 F.Supp.2d 471, 483 (S.D.N.Y. 2008) (Sweet, J.) (citing Treppel v. Biovail Corp., No. 03 Civ. 3002 (PICL), 2005 WL 2086339, at *7 (S.D.N.Y. Aug. 30, 2005)). As courts in this district have recog