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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
should be acted upon; and (5) that the plaintiff acted ("8] upon it to his damage."' Financial Trust Co., 268 F. Supp.2d at 575 (quoting Shapiro v. UJB Fin. Corp., 964 F.2d 272, 284 (3d Cir. 1992)). The defendants base their argument that plaintiffs have failed to state a claim upon which relief can be grant
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
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 damage." Shapiro v. UJB Fin. Corp., 964 F.2d 272, 284 (3d Cir.1992). Although the rule does not require a recitation of "every material detail" of the alleged fraud, it does require,
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
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 damage." Shapiro v. UJB Fin. Corp., 964 F.2d 272, 284 (3d Cir. 1992). Although the rule does not require a recitation of EFTA01726537 Financial Trust Co., Inc. v. Citibank, N.A. C
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
it should be acted upon; and (5) that the plaintiff acted upon it to his damage.'" Financial Trust Co., 268 F. Supp.2d at 575 (quoting Shapirio v. UJB Fin. Corp., 964 F.2d 272, 284 (3d Cir. 1992)). The defendants base their argument that plaintiffs have failed to state a claim upon which relief can be grant
Entities connected to both the United States District Court and UJB Fin. Corp.

Jeffrey Epstein
PERSONthe Southern District
LOCATION
United States
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
George W. Bush
PERSONGerald Lefcourt
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATION
Julie K. Brown
PERSONMaria Farmer
PERSON
United States District Court
ORGANIZATION
Prince Charles
PERSON
New York City
LOCATIONthe State of New York
LOCATION
Michael Jackson
PERSON
Les Wexner
PERSON
Financial Trust Company
ORGANIZATION
JPMorgan Chase
ORGANIZATION
John F. Kennedy
PERSON