This document is a memorandum of law submitted by Defendants The Financial Trust Company and Jeffrey E. Epstein in support of their motion to dismiss the complaint filed by Plaintiffs Marvin Gerber and Kalma Koenig. The Defendants argue that the Plaintiffs' claims are time-barred and fail to state a claim. The memorandum outlines the history of litigation related to Steven Hoffenberg's Ponzi scheme and argues that the Plaintiffs' claims are based on alleged misconduct that ended decades ago. The Defendants also argue that the Plaintiffs' claims lack the particularity required by Rule 9(b) and fail to meet the general pleading standards.
documents/EFTA00802452.pdf
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