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econd amended complaint (the "Fisher counterclaim"), is granted in all respects. The Soffer ejectment motion is granted as against deft Ron Soffer. Defls Jeffrey E. Epstein, Ivan S. Fisher, Ellyn Bank, Debra Elisa Cohen, Dianeataga?/a The Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, D. Gerzog, Robert Heilbum,
the house to the tenant we have selected should Mr. Epstein decide not to reoccupy the premises under the ne
on of the budding pursuant to the Foreign Missions Act, 22 U.S.C. § 4301 of seq. 0FM leased the building to defen- dant Jeffrey E. Epstein in 1992. Epstein sublet the building to defendant Ivan S. Fish- er in 1996, purportedly without the Govern- ment's consent. Fisher, in turn, sublet a portion of the
n personally liable because Epstein did not sign the con- tract as an agent or as a corporate officer. Epstein signed the contract as follows: /s/ Jeffery Epstein 1AG. Under New York law, a signature in a representative capacity would have been "Jeffrey Epstein for I.A.G." or "I.A.G., by Jeffrey Epstein". 2
atters extrinsic to the complaint. we will treat defendant Epstein's motion to dismiss as a motion for summary judg
RDERED. UNITED STATES of America, Plaintiff, I Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elis
RDERED. UNITED STATES of America, Plaintiff, I Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elise
tates that its packaging design was chosen because the design was pretty, so- phisticated, and showed off the novelty value of the deodorant stone. Rosenblatt dep. at 520-522. FT also states that FT colored the package blue because it liked that color, not because blue was a common color used in cosmeti
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
em a fiduciary duty. ... Such derivative allegations are legally insufficient to state a claim for breach of fiduciary duty against [defendant]."); Rosenblatt v. Christie, Manson & Woods Ltd., No. 04 Civ. 4205 (PKC), 2005 U.S. Dist. LEXIS 23816, at *29 (S.D.N.Y. Oct. 14, 2005) ("Nor can a fiduciary relatio
tinued to mingle in the same gilded circles, attending the same parties in Florida and New York, sharing meals and flying together at least once on [Jeffrey] Epstein's private plane." The Post says "during those years, Trump socialized with Epstein, particularly after Epstein purchased a mansion in Palm Beach, Fla
reports that Virginia Giuffre, "who has accused...Epstein of years-long abuse that began when she was a tee
n with attorneys, Giuffre said she saw former President Bill Clinton on the island. According to this document, she told lawyers, 'I remember asking Jeffrey what's Bill Clinton doing here kind of thing. And he laughed it off and said, 'well, he owes me a favor.' He never told me what favors they were.'
ocuments-in-ghislaine-maxwell-lawsuit- related-to-jeffrey-epstein-11596180451> (7/31, Paul, O'Brien, Subscription P
se government." Bloomberg <https://www.bloomberg.com/news/articles/2020-07-31/chinese-researcher-denied-u-s-bail-in-case- over-military-ties> (7/31, Rosenblatt, 4.73M) reported Lexi Negin, the public defender representing Tang, "said in an email that she's disappointed by the decision." Negin said,"We will
e late Wednesday rejected an attempt by lawyers for Ghislaine Maxwell, the British socialite accused of being a sex trafficker and alleged madam for Jeffrey Epstein, to block the unsealing and release of potentially embarrassing documents from a settled defamation suit." The Herald adds, "Hours before the start
decision to order the unsealing and release of documents in a 2015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's
behalf of retired FBI supervisory special agent Jeffrey Danik." FBI Memo Highlights Mystery Sources Tied
d Get 27 Months In Prison. Bloomberg <https://www.bnnbloomberg.ca/forrner-google-engineer-should-get-27-months-in-prison-u-s-says- 1.1472184> (7/28, Rosenblatt, 4.73M) reports federal prosecutors told a judge that "Anthony Levandowski, the autonomous-driving engineer who agreed to plead guilty to stealing t
late Wednesday rejected an attempt by lawyers for Ghislaine Maxwell, the British socialite accused of being a sex trafficker and alleged madam for Jeffrey Epstein, to block the unsealing and release of potentially embarrassing documents from a settled defamation suit." The Herald adds, "Hours before the start
decision to order the unsealing and release of documents in a 2015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's
n behalf of retired FBI supervisory special agent Jeffrey Danik." FBI Memo Highlights Mystery Sources Tied
determines they have enough space to safely hold him." Federal Prosecutors: Former Uber Engineer Should Get 27 Months In Prison. Bloomberg (7/28, Rosenblatt, 4.73M) reports federal prosecutors told a judge that "Anthony Levandowski, the autonomous-driving engineer who agreed to plead guilty to stealing t
tinued to mingle in the same gilded circles, attending the same parties in Florida and New York, sharing meals and flying together at least once on [Jeffrey] Epstein's private plane." The Post says "during those years, Trump socialized with Epstein, particularly after Epstein purchased a mansion in Palm Beach, Fla
reports that Virginia Giuffre, "who has accused...Epstein of years-long abuse that began when she was a tee
with attorneys, Giuffre said she saw former President Bill Clinton on the island. According to this document, she told lawyers, 'I remember asking Jeffrey what's Bill Clinton doing here kind of thing. And he laughed it off and said, 'well, he owes me a favor.' He never told me what favors they were.' I
ed their active Chinese military duty status in their US visa applications in an orchestrated program by the Chinese government." Bloomberg (7/31, Rosenblatt, 4.73M) reported Lexi Negin, the public defender representing Tang, "said in an email that she's disappointed by the decision." Negin said,"We will
cobs, 14.2M) also reports that "who has accused...Epstein of years-long abuse that began when she was a tee
tinued to mingle in the same gilded circles, attending the same parties in Florida and New York, sharing meals and flying together at least once on [Jeffrey] Epstein's private plane." The Post says "during those years, Trump socialized with Epstein, particularly after Epstein purchased a mansion in Palm Beach, Fla
rsation with attorneys, said she saw former President Bill Clinton on the island. According to this document, she told lawyers, `I remember asking Jeffrey what's Bill Clinton doing here kind of thing. And he laughed it off and said, `well, he owes me a favor.' He never told me what favors they were.' I
ed their active Chinese military duty status in their US visa applications in an orchestrated program by the Chinese government." Bloomberg (7/31, Rosenblatt, 4.73M) reported Lexi Negin, the public defender representing Tang, "said in an email that she's disappointed by the decision." Negin said,"We will
late Wednesday rejected an attempt by lawyers for Ghislaine Maxwell, the British socialite accused of being a sex trafficker and alleged madam for Jeffrey Epstein, to block the unsealing and release of potentially embarrassing documents from a settled defamation suit." The Herald adds, "Hours before the start
er EFTA01658262 the unsealing and release of documents in a 2015 civil lawsuit that included a deposition given by Maxwell in the case brought by Epstein accuser Virginia Giuffre. Less than three hours later, Preska denied it, citing `eleventh-hour request for reconsideration.' She allowed Maxwell's
n behalf of retired FBI supervisory special agent Jeffrey Danik." FBI Memo Highlights Mystery Sources Tied
determines they have enough space to safely hold him." Federal Prosecutors: Former Uber Engineer Should Get 27 Months In Prison. Bloomberg (7/28, Rosenblatt, 4.73M) reports federal prosecutors told a judge that "Anthony Levandowski, the autonomous-driving engineer who agreed to plead guilty to stealing t
t future for solar technology EFTA00681638 By Jeffrey Barken/JNS.org The Israeli start-up SolarPaint's
Rosenblatt touched down at Ben Gurion Airport in Tel Aviv April 5 and powered on his cell phone, he got the surprise of his mobile technology life. Rosenblatt received a text message from his cell phone carrier, Verizon, reading, 'Welcome to Palestine." Attempting to explain the situation, Verizon spokes
Entities connected to both Jeffrey Epstein and Rosenblatt

Richard Kahn
PERSONDarren Indyke
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Boris Nikolic
PERSON
Woody Allen
PERSON
John F. Kennedy
PERSON
Eric Trump
PERSON
George Mitchell
PERSON
Alan Dershowitz
PERSONDaphne Wallace
PERSON
Madison
LOCATION
George W. Bush
PERSON
Donald Trump
PERSON
United States
LOCATION
Lawrence Krauss
PERSON
Condoleezza Rice
PERSON
Glenn Dubin
PERSON
Stephen Hawking
PERSON