Epstein Secrets

N.A. Clle as 261 F.Supp.24 561 ID.VIren Wend. 2003) of time, constitute irreparable harm. De- ng/1y, 309 F.3d at 178, quoting, inter alio, Elrod. Burns, 427 U.S. 347, 373, 96 S.Ct. 2673, 49 L.Ed2d 547 (1976). IX. Balance of Hann to Plaintiff Venus Harm to Defendants (331 Defendants will suffer• l

r the plain- tiffs to amend their pleadings. I. FACTUAL AND PROCEDURAL BACKGROUND In their amended complaint, Jeffrey E. Epstein ("Epsteinn and Financial Trust Company, Inc. ("Fr) (collectively "plain- tiffs") allege that Citibank, N.A. ("Citi- bank") and Citigroup, Inc. ("Citigroup"I [collectively "defendants"] misrepre

itch book" referenced in the amended complaint is the document that plaintiffs rely on is a disputed fact that precludes a Rule 12(bX6) dismissal. Financial Trust Co., 268 F.Supp.2d at 572. Nothing in any of the briefs have convinced me that the parties do not dispute which pitch book Epstein received, what disc

ed to meet Federal Rule of Civil Proce- dure 9(b)'s heightened pleading standard. I did, however, grant the plaintiffs leave to amend the complaint Financial Trust Co.' Citibank, 268 F.Supp.2d 661 (D.Vir- gin Islands 2003). H. LEGAL ANALYSIS A. Federal Rule of Civil Procedure 9(b) (1-31 In order to state a viable

whose members have included Frank Sinatra, George Burns and Johnny Carson, has served as a bastion for a

. Epstein reportedly made all the investment calls. Since the 1990s, the company has been incorporated in the U.S. Virgin Islands and is now called Financial Trust Co. A person answering the phone at the Saint Thomas-based company hung up after a request for comment was made. The main client was Wexner, the founde

up that he ran out of his apartment, according to Vanity Fair. Later he set up a money management firm called J. Epstein & Co. It eventually became the Financial Trust Company, based in the Virgin Islands. EFTA00076644 But there was an expensive footnote about him and Bear Stearns. When two big Bear Stearns hedge funds

whose members have included Frank Sinatra, George Burns and Johnny Carson, has served as a bastion for a

. Epstein reportedly made all the investment calls. Since the 1990s, the company has been incorporated in the U.S. Virgin Islands and is now called Financial Trust Co. A person answering the phone at the Saint Thomas-based company hung up after a request for comment was made. The main client was Wexner, the founde

up that he ran out of his apartment, according to Vanity Fair. Later he set up a money management firm called J. Epstein & Co. It eventually became the Financial Trust Company, based in the Virgin Islands. But there was an expensive footnote about him and Bear Stearns. When two big Bear Stearns hedge funds collapsed in 20

ED. ATTY W. BERGER BY SPEAKER PHONE. ATTY FOR B. BURNS. PAST ATTY BY SPEAKER PHONE/WRITTEN ORDER TO FOL

sI 145 Government of the U.S. limn Islands Economic Development Commission Application for Economic Developmen enefits to Name, f Applicant: Financial Trust Company, Inc. FOR.OFFiCIAI, USE ONLY Dates Racekck Amptcd as Complctc: 1 TYPE OF APPLICATION: NEW EXTENSION SMALL MANUFACTURFR MODIFICATION fl TRANSFER ri

mptcd as Complctc: 1 TYPE OF APPLICATION: NEW EXTENSION SMALL MANUFACTURFR MODIFICATION fl TRANSFER rij EFTA01625830 1. CONTACT INFORMATION EIN Financial Trust Company. Inc. A.) Name of Applicant' B.) Mailing Addresr 6100 Red Hook Quarter, 8.3, St. Thomas, VI 00802 C.) Plant/Facility Location: Island St. Thoma

DIRECT DIAL FAX &Mu San 3800 1201 11660 AwAue Burns, WASHINGTON 05101.3000 Re: D.B. Zwim Special Op

agraph 7 of the Settlement Agreement and Release dated April 8, 2009 ("Agreement") among D.B. Zwirn Special Opportunities Fund, L.P., Jeepers, Inc., Financial Trust Company, Inc., and Jeffrey Epstein, this notice constitutes "Jeepers' Cancellation Declaration." The result hereof is that the Agreement is null and void and the

E. DEFT AGREED. CS. ASST STATE ATTORNEY BARBARA BURNS CALLED - SHE ADVISED THAT SHE WAS TOLD THAT THE

ITTEN MONTHLY REPORT RECEIVED FOR CURRENT MONTH. DEFT SUBMITTED PROOF OF EMPLOYMENT - CERTIFICATE OF INCORPORATION FOR THE C.O.U.Q. FOUNDATION AND FINANCIAL TRUST COMPANY, INC. SUBMITTED OLD CC SCHEDULE AND NEW SCHEDULE APPROVED. CS. 07/28/09 1535 TP EXTRA COMM CONTROL CALLED DEFT - INSTRUCTED HE IS NOT TO HAVE ANY F4=

ED. ATTY W. BERGER BY SPEAKER PHONE. ATTY FOR B. BURNS. PAST ATTY BY SPEAKER PHONE/WRITTEN ORDER TO FOL

sI 145 Government of the U.S. limn Islands Economic Development Commission Application for Economic Developmen enefits to Name, f Applicant: Financial Trust Company, Inc. FOR.OFFiCIAI, USE ONLY Dates Racekck Amptcd as Complctc: 1 TYPE OF APPLICATION: NEW EXTENSION SMALL MANUFACTURFR MODIFICATION fl TRANSFER ri

S. 08/20/09 0945 TC ASST STATE ATTORNEY BARBARA BURNS CALLED - SHE ADVISED THAT SHE WAS TOLD THAT THE

ITTEN MONTHLY REPORT RECEIVED FOR CURRENT MONTH. DEFT SUBMITTED PROOF OF EMPLOYMENT - CERTIFICATE OF INCORPORATION FOR THE C.O.U.Q. FOUNDATION AND FINANCIAL TRUST COMPANY, INC. SUBMITTED OLD CC SCHEDULE AND NEW SCHEDULE APPROVED. CS. 07/28/09 1535 TP EXTRA COMM CONTROL CALLED DEFT - INSTRUCTED HE IS NOT TO HAVE ANY F4=