Epstein Secrets

ate a claim of a fiduciary duty." Abercrombie v. Andrew Coll., 438 F. Supp. 2d 243, 275 (S.D.N.Y. 2006) (

pectfully submit this Memorandum of Law in Support of their Motion to Dismiss Plaintiffs Marvin Gerber ("Gerber") and Kalma Koenig's (together with Gerber, the "Plaintiffs") time-barred and otherwise deficient Complaint [ECF 7] in its entirety and with prejudice pursuant to Fed. R. Civ. P. 9(b) and 12(

against ROTHSTEIN, David Boden, Debra Villegas, Andrew Barnett, TD Bank, N.A., Frank EFTA00795595 Eps

aintain the integrity of the con tiality order issued in this matter by the Court below, as well as having heard directly fr udge Marra and Judge Gerber, we find as follows: Findinos of Fact —The Court below entered orders on March 25, 2009 and April 23, 2009, specifyi. e that certain specific acts

ce for the Southern District of New York One St. Andrew's Plaza, New York. New York 10007 Desk: EFTA001

ubstance of the briefing, with an eye toward circulating it to OAG early next week so he has visibility on who and what to expect. I connected with Gerber and Blais about it, if you guys wanted to compare notes on how theirs will be styled. Thanks—and sorry for the (further) intrusion) I Counsel to th

against ROTHSTEIN, David Boden, Debra Villegas, Andrew Barnett, TD Bank, N.A., Frank EFTA00729411 Eps

in the integrity of the confidentiality order issued in this matter by the Court below, as well as having heard directly from Judge Marra and Judge Gerber, we find as follows: Findings of Fact 1. The Court below entered orders on March 25, 2009 and April 23, 2009, specifying that certain specific ac