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TRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, : Plaintiff, : 96 Civ. 8307 (DC) - against - : SECOND AMENDED COMPLAINT JEFFREY E. EPSTEIN, IVAN S. FISHER, : ELLYN BANK, DEBRA ELISA COHEN, DIANE FISHER d/b/a THE FISHER GROUP, : FISHER & SOFFER Ala FISHER & SOPHIR, LAWRENCE D. GERZOG,
of the Office of Foreign Missions ("OFM") of the United States Department of State (the "State Department") against defendants Jeffrey E. Epstein ("Epstein"), Ivan S. Fisher ("Fisher"), Ellyn Bank, Debra Elisa Cohen, Diane Fisher d/b/a The Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, Lawrence D.
which is the trustee-landlord for the Premises. Defendant Epstein is a resident of the State of New York and has be
307 (DC) - against - : SECOND AMENDED COMPLAINT JEFFREY E. EPSTEIN, IVAN S. FISHER, : ELLYN BANK, DEBRA EL
307 (DC) - against - : SECOND AMENDED COMPLAINT JEFFREY E. EPSTEIN, IVAN S. FISHER, : ELLYN BANK, DEBRA ELI
s Subtenants") to occupy the Premises. The Government did not consent to any occupancy of the Premises by Fisher's Subtenants. Moreover, even under the Unpermitted Sublease, the validity of which the Government disputes, Epstein did not consent to the use and occupancy of the Premises by Fisher's Subtenants. Fisher's S
nant or assignee, Epstein entered into a sublease for the Premises with Fisher on or about May 7, 1996 (the "Unpermitted Sublease"). A true copy of the Unpermitted Sublease (minus attachments referenced in the table of contents thereto) is attached as Exhibit D and is incorporated herein by reference. On or about May 1
TRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, : Plaintiff, : 96 Civ. 8307 (DC) - against - : SECOND AMENDED COMPLAINT JEFFREY E. EPSTEIN, IVAN S. FISHER, : ELLYN BANK, DEBRA ELISA COHEN, DIANE FISHER d/b/a THE FISHER GROUP, : FISHER & SOFFER Ala FISHER & SOPHIR, D. GERZOG, ROBERT H
of the Office of Foreign Missions ("OFM") of the United States Department of State (the "State Department") against defendants Jeffrey E. Epstein ("Epstein"), Ivan S. Fisher ("Fisher"), Ellyn Bank, Debra Elisa Cohen, Diane Fisher d/b/a The Fisher Group, Fisher & Soifer a/Ida Fisher & Sophir, D. Gerzog
h is the trustee-landlord for the Premises. 2. Defendant Epstein is a resident of the State of New York and has be
307 (DC) - against - : SECOND AMENDED COMPLAINT JEFFREY E. EPSTEIN, IVAN S. FISHER, : ELLYN BANK, DEBRA EL
307 (DC) - against - : SECOND AMENDED COMPLAINT JEFFREY E. EPSTEIN, IVAN S. FISHER, : ELLYN BANK, DEBRA ELI
tenants") to occupy the Premises. 13. The Government did not consent to any occupancy of the Premises by Fisher's Subtenants. Moreover, even under the Unpermitted Sublease, the validity of which the Government disputes, Epstein did not consent to the use and occupancy of the Premises by Fisher's Subtenants. 14. Fish
nant or assignee, Epstein entered into a sublease for the Premises with Fisher on or about May 7, 1996 (the "Unpermitted Sublease"). A true copy of the Unpermitted Sublease (minus attachments referenced in the table of contents thereto) is attached as Exhibit D and is incorporated herein by reference. 6. On or about M
loor New York, New York 10007 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, Plaintiff, - against - JEFFREY E. EPSTEIN, IVAN S. FISHER, ELLYN BANK, DEBRA ELISA COHEN, DIANE FISHER d/b/a THE FISHER GROUP, : FISHER & SOFFER a/k/a FISHER & SOPHIR, LAWRENCE D. GERZOG,
United States SONY_GM_02742766 EFTA _00229415 EFTA01324981 Department of State (the "State Department") against defendants Jeffrey E. Epstein ("Epstein"), Ivan S. Fisher ("Fisher"), Ellyn Bank, Debra Elisa Cohen, Diane Fisher d/b/a The Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, Lawrence D.
h is the trustee-landlord for the Premises. 4. Defendant Epstein is a resident of the State of New York and has b
ITED STATES OF AMERICA, Plaintiff, - against - JEFFREY E. EPSTEIN, IVAN S. FISHER, ELLYN BANK, DEBRA ELIS
ITED STATES OF AMERICA, Plaintiff, - against - JEFFREY E. EPSTEIN, IVAN S. FISHER, ELLYN BANK, DEBRA ELISA
enants") to occupy the Premises. 49. The Government did not consent to any occupancy of the Premises by Fisher's Subtenants. Moreover, even under the Unpermitted Sublease, the validity of which the Government disputes, Epstein did not consent to the use and occupancy of the Premises by Fisher's Subtenants. 50. Fish
Entities connected to both Jeffrey Epstein and the Unpermitted Sublease

United States
LOCATION
Lawrence Krauss
PERSON
FedEx
ORGANIZATIONSouthern District
LOCATION
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
New York
LOCATION
U.S. Treasury
ORGANIZATIONFisher
PERSON
Jesse
PERSON
McDermott
PERSONRon Soffer
PERSON
Office of Foreign Assets Control
ORGANIZATIONEllyn Bank
ORGANIZATIONthe United States Department of State
LOCATIONSubtenants
PERSONGerzog
ORGANIZATIONthe Office of Foreign Missions
ORGANIZATIONHeilbrun
PERSONIEEPA
ORGANIZATION