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falsity 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 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,
accused. (Mem. of Law in Supp. of Mot. to Dismiss at 32-35.) The plaintiffs counter that, although the amended complaint does not specify who within Ciligroup or Citibank recommended the AIG investment, the defendants are aware of which of their employees are implicated in this matter. Moreover, the plaint
falsity 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 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,
d with the requisite particularity, leave to amend the complaint is granted). III. CONCLUSION For the foregoing reasons, I will 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 Cou
as to every 349 FEDERAL SUPPLEMENT, 2d SERIES claim for relief over which the district courts have jurisdiction”” Jd. (citing 28 U.S.C. § 183000); Shapiro v. Republic of Bolivia, 930 F.2d 1018, 1020 (2d Cir.1991)). The court acknowledged that the foreign state’s contacts with the United States might be
Page: HOUSE_OVERSIGHT_017873 →96] Saudi American Bank is based in Rihadh, Saudi Arabia and was formed in 1980 pursuant to a royal decree to take over the then-existing branches of Citi- bank in Riyadh and Jeddah. Ashton Com- plaint 1603; Burnett Complaint 1140. It is the second largest bank in Saudi Arabia and has offices in the Unite
Page: HOUSE_OVERSIGHT_017899 →Entities connected to both Shapiro and Citibank

Jeffrey Epstein
PERSON
Donald Trump
PERSON
George W. Bush
PERSON
Joe Biden
PERSON
Prince Andrew
PERSON
Prince Charles
PERSON
Ghislaine Maxwell
PERSON
Bill Clinton
PERSON
Virginia Giuffre
PERSONLeon Black
PERSON
Julie K. Brown
PERSON
Department of Justice
ORGANIZATION
Bloomberg L.P.
ORGANIZATION
United States
LOCATION
New York
LOCATION
Samantha Power
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Stephen Hawking
PERSON
Bradley Edwards
PERSON