Epstein Secrets

on that it 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 r

n to introduce him to an "exceptional investment opportunity." (Compl. P 13.) In follow-up telephone conversations during that same two week period, Davison and her associates r 5] made additional specific representations about the AIG Investment, without disclosing Citibank and AIG's relationship. Davi

lsity 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 I 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

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%"

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,

plaintiffs, however, shall have THIRTY DAYS within which to file an amended complaint with respect to these counts. FOOTNOTES 1. Sometime in 2000, Davison informed Epstein about a second, similar investment fund to be managed by Mass Mutual CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0087

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 EFTA01726537 Financial Trust Co., Inc. v.

plaintiffs seek rescission of the promissory note and punitive damages (Counts VI and VII). (Am. Compl. III 45-68.) In April 1999, Dayle Davison ["Davison"], Vice President of Citibank in New York and Epstein's private banker, and other Citibank employees telephoned Epstein while he was in the Virgin