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

remedy at law. Rather, damages for fraud and conversion constitute an adequate remedy at law; and Plaintiffs assert they are entitled to both. See Lucero v. Matallana, 2009 N.Y. slip op. 32023(U), 14 (Sup. Ct.) ("Plaintiff's claim for unjust enrichment, however, is not viable. Unjust enrichment is eq

i-Trafficking Plan The Daily Beast (07/28, Briquelet) reported that the U.S. Virgin Islands is using proceeds from legal settlements related to the Jeffrey Epstein case to fund anti-trafficking initiatives, funded by the sale of Epstein's island and payouts from litigation, and if it wins its suit against JPMor

gin Islands is using proceeds from legal settlements related to the Jeffrey Epstein case to fund anti-trafficking initiatives, funded by the sale of Epstein's island and payouts from litigation, and if it wins its suit against JPMorgan, damages will also support these efforts. According to the article,

g proceeds from legal settlements related to the Jeffrey Epstein case to fund anti-trafficking initiatives

ndividuals as part of the U.S. effort to address the issue of missing and murdered indigenous women and relatives (MMIWR). According to the article, Lucero's proactive approach is not the norm in U.S. and tribal law enforcement due to jurisdictional challenges and resource limitations. Federal law enfo

i-Trafficking Plan The Daily Beast (07/28, Briquelet) reported that the U.S. Virgin Islands is using proceeds from legal settlements related to the Jeffrey Epstein case to fund anti-trafficking initiatives, funded by the sale of Epstein's island and payouts from litigation, and if it wins its suit against JPMor

in Islands is using proceeds from legal settlements related to the Jeffrey Epstein case to fund anti-trafficking initiatives, funded by the sale of Epstein's island and payouts from litigation, and if it wins its suit against JPMorgan, damages will also support these efforts. According to the article, t

g proceeds from legal settlements related to the Jeffrey Epstein case to fund anti-trafficking initiatives

ndividuals as part of the U.S. effort to address the issue of missing and murdered indigenous women and relatives (MMIWR). According to the article, Lucero's proactive approach is not the norm in U.S. and tribal law enforcement due to jurisdictional challenges and resource limitations. Federal law enfo

55 OZONE = 16 Daily AQI Color = Yellow Reference: AlrNow.gov NATIONAL WEATHER SERVICE Partly cloudy with a high of 91. SIGNIFICANT NEWS EVENTS Epstein 'Client List' Doesn't Exist, Justice Department Says, Walking Back Theory AG Bondi Had Promoted The Associated Press (07/07, Tucker, Richer) reporte

ivate Jet flight logs and people associated with Epstein. "Yes, she was saying the entirety of all of the paperwork, all of the paper in relation to Jeffrey Epstein's crimes. That's what the attorney general was referring to. And I'll let her speak for that," White House press secretary Karoline Leavitt said Monda

er, Richer) reported that the DOJ has stated that Jeffrey Epstein did not maintain a "client list" of indiv

arr), Axlos (07/07, Habeshian), Daily Mail (07/07, Torres), Forbes (07/07, Roeloffs, Ogburn), Hindustan Times (07/07, Kukreti), KRGV (ABC•5) (07/07, Lucero), Los Angeles Times (07/07, Gonzalez), Michigan Advance (07/07, Garcia), Newsmax (07/07, Mack), New York Post (07/07, Taer), New York Times (07/07,

55 OZONE = 16 Daily AQI Color = Yellow Reference: AirNow.gov NATIONAL WEATHFR SERVICE Partly cloudy with a high of 91. SIGNIFICANT NEWS EVENTS Epstein 'Client List' Doesn't Exist, Justice Department Says, Walking Back Theory AG Bondi Had Promoted The Associated Press (07/07, Tucker, Richer) reporte

ivate Jet flight logs and people associated with Epstein. "Yes, she was saying the entirety of all of the paperwork, all of the paper in relation to Jeffrey Epstein's crimes. That's what the attorney general was referring to. And I'll let her speak for that," White House press secretary Karoline Leavitt said Monda

er, Richer) reported that the DOJ has stated that Jeffrey Epstein did not maintain a "client list" of indiv

arr), Axlos (07/07, Habeshian), Daily Mail (07/07, Torres), Forbes (07/07, Roeloffs, Ogburn), Hindustan Times (07/07, Kukreti), KRGV (ABC•5) (07/07, Lucero), Los Angeles Times (07/07, Gonzalez), Michigan Advance (07/07, Garcia), Newsmax (07/07, Mack), New York Post (07/07, Taer), New York Times (07/07,

Nearly 30,000 Jobs, Far Fewer Than Planned • U.S. Physician Groups Sue Kennedy Over Vaccine Policy WASHINGTON SCHEDULE EFTA01655248 IN THE NEWS Epstein 'Client List' Doesn't Exist, Justice Department Says, Walking Back Theory AG Bondi Had Promoted The Associated Press (07/07, Tucker, Richer) reporte

ivate jet flight logs and people associated with Epstein. "Yes, she was saying the entirety of all of the paperwork, all of the paper in relation to Jeffrey Epstein's crimes. That's what the attorney general was referring to. And I'll let her speak for that," White House press secretary Karoline Leavitt said Mond

er, Richer) reported that the DOJ has stated that Jeffrey Epstein did not maintain a "client list" of indi

arr), Axios (07/07, Habeshian), Daily Mail (07/07, Torres), Forbes (07/07, Roeloffs, Ogburn), Hindustan Times (07/07, Kukreti), KRGV (ABC-5) (07/07, Lucero), Los Angeles Times (07/07, Gonzalez), Michigan Advance (07/07, Garcia), Newsmax (07/07, Mack), New York Post (07/07, Taer), New York Times (07/07,