Epstein Secrets

r. 1975)). The parole evidence rule serves to protect a party to a written contract from infirmity of memory, perjury, or the death of witnesses. Adler, 721 F.Supp. at 476. 1181 We have examined the November 1984 contract and find it to be a complete integration of the parties' agreement. See con

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

d 33:15 along 40:17 assurances 12:5 Biscayne 1:14 39:1340:4,5,6 adjourned 44:16 already 22:5 attached 43:4 Bob 3:1819:7 cases 3:2 6:97:3,11 Adler 1:17 always 30:16 attack 33:17 Boehringer 1:20 8:13,22 9:3,5,5,15 admit 20:3,18 25:11 Amendment 6:24 attention 15:1,22 bond 25:22 10:3,11 12

g to work" and "eligible for re-employment" at The Florida Science Foundation. Please be advised that the only W-2 that Mr. Epstein provided is from Financial Trust Company, Inc., which shows that Mr. Epstein was employed in the U.S. Virgin Islands at a salary of $180,785.62, not $250,000. Mr. Epstein provided to you no docu

founder of The Florida Science Foundation and Mr. Indyke is its Vice President. More importantly, Mr. Epstein is also the founder and President of the Financial Trust Company, his for-profit corporation. Mr. Indyke is Mr. Epstein's subordinate at that entity as well. One of Mr. Epstein's attorneys has suggested that Mr.

521 17:9 Adam 1:13 3:4 29:13 add 29:5 35:7 42:21 addenda 36:16 Adderly 3:17 additional 29:22 address 29:15 addressed 33:15 adjourned 44:16 Adler 1:17 admit 20:3,18 25:11 3223 36:8 admits 23:20 admitted 23:17 24:9 41:19 ado 23:13 advantage 20:24 adverse 18.18 advice 12:7 affidavit 432

g to work" and "eligible for re-employment" at The Florida Science Foundation. Please be advised that the only W-2 that Mr. Epstein provided is from Financial Trust Company, Inc., which shows that Mr. Epstein was employed in the U.S. Virgin Islands at a salary of $180,785.62, not $250,000. Mr. Epstein provided to you no docu

founder of The Florida Science Foundation and Mr. Indyke is its Vice President. More importantly, Mr. Epstein is also the founder and President of the Financial Trust Company, his for-profit corporation. Mr. Indyke is Mr. Epstein's subordinate at that entity as well. One of Mr. Epstein's attorneys has suggested that Mr.