Epstein Secrets

parties could come to a mutually agreeable date for the deposition. Plaintiff still, nearly three months later, has yet to agree to a date in which Shanks can be deposed, but has instead unilaterally designated September 9th and 10th in Philadelphia as the time and place for Defendants' depositions. D

naged by MG. (Compl. 1112, 24; Epstein Decl. 118-10; Davison Aft 11 1, 102-18.) According to the plaintiffs, during the negotiations of this deal Davison represented to Epstein that he was "virtually assured of receiving an 18-20% return on [his] investment, with a possible return of as much as 80%"

chology: Human Learning and Memory, 4, 19-31. • Reprinted in: Gross, R.D. (1990) Key Studies in Psychology. London: Hodder & Stoughton Publishers. Shanks, D. (1997). Human Memory: A reader. London: Arnold (NY: St. Martin's Press). p. 91-107. Balota, D.A. & Marsh, E. J. (2004) Cognitive Psychology: Key

dam: Elsevier), p 997-1032 2004 Loftus, E. F. (2004) Dispatch from the (un) civil memory wars. Lancet, 364, 20-21. Bernstein, D. M., Godfrey, R., Davison, A., & Loftus, E. F. (2004) Conditions affecting the revelation effect for autobiographical memory. Memory & Cognition. 32, 455-462. Loftus, E.F. (

ecause a substantial part of the events giving rise to this claim occurred in the Eastern District of Pennsylvania. Ili. pAcTs 8. In early 2000, Shanks was contacted by Maxwell, who represented to Shanks that she was acting on behalf of Epstein and/or the Wexners, to inquire whether Shanks would cc

o introduce him to an "exceptional investment opportunity." (Compl. 9f 13.) In follow-up telephone conversations during that same two week period, Davison and her associates made additional specific representations about the AIG Investment, without disclosing Citibank and AIG's relationship. Davison a