Epstein Secrets

AL TRUST COMPANY, INC. AND JEFFREY E. EPSTEIN, Plaintiffs, v. CITIBANK, N.A. AND CITIGROUP, INC. d/b/a "CITIGROUP," Defendants. Civ. No. 2002-108 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF THE VIRGIN ISLANDS, DIVISION OF ST. THOMAS AND ST. JOHN 351 F. Supp. 2d 329; 2004 U.S. Dist. LEXIS 26378; 46 V.I. 435 December

by the person to whom it was made; (4) the intention that it should be acted upon; and (5) that the plaintiff acted upon it to his damages." in re Rockefeller Ctr. Props. Secs. Litig., 311 F.3d 198, 215 (3d Cir. 2002). Courts should apply Rule 9(b) with some flexibility and should not require plaintiffs to pl

deny Citibank's and Citigroup's motions to dismiss for lack of personal jurisdiction, to dismiss for improper venue, and to transfer this matter to the United States District Court for the Southern District of New York. I find that the amended complaint adequately states claims of breach of fiduciary duty and negligent misrepr

that would accompany 'the first paragraph of any newspaper story—that is, the 'who, what, when, where and how' of the events at issue." In re Rockefeller Ctr. Props.. Inc.. 311 F.3d at 217 (quoting In re Burlington, 114 F.3d at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted

deny Citibank's and Ciligroup's motions to dismiss for lack of personal jurisdiction, to dismiss for improper venue, and to transfer this matter to the United States District Court for the Southern District of New York. I find that the amended complaint adequately states claims of breach of fiduciary duty and negligent misrepr

round that would accompany 'the first paragraph of any newspaper story—that is, the 'who, what, when, where and how' of the events at issue." In re Rockefeller Ctr. Props.. Inc.. 311 F.3d at 217 (quoting In re Burlington, 114 F.3d at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted

rk Anticipating that I might find that jurisdiction and venue are proper in this Court, the defendants have requested that I transfer this case to the United States District Court for the Southern District of New York. They aver that this claim actually arose in New York and that the clauses in the agreements EFTA01726523

an increased measure of protection for their reputations, and reduce[] the number of frivolous suits brought solely to extract settlements." In re Rockefeller Ctr. Props., Inc., 311 F.3d at 215 (quoting In re Burlington Coat Factory Sec. Litig., 114 F.3d at 1418). "Rule 9(b) requires a plaintiff to plead (1)

D STATES ATTORNEY 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 TEL( FAX Case No. 08-80736-CV-MARRA P-000676 EFTA00228056 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-8068-LRJ IN RE: SEARCH WARRANT APPLICATION MOTION TO FILE DOCUMENTS UNDER SEAL The United States of America, by

d that would accompany 'the first paragraph of any newspaper story' - that is the 'who, what, when, where and how' of the events at issue.'" In re Rockefeller Ctr. Props., Inc., 311 F.3d at 217 (quoting In re Burlington, 114 F.3d at 1422). However, the Third Circuit Court of Appeals has held that the "require