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ents, the documents "bespeak caution" to the investor and the investor cannot later premise a fraud claim on the events of which he has been warned. Kline v. First W. Gov't Sec., 24 F.3d 480, 489 (3d Cir. 1994). The defendants' claim that the Preliminary Offering Circular [the "pitch book"], which was
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
, the documents "bespeak caution" to the investor and the investor cannot later premise a fraud claim on the events of which he has been warned. Kline I First Western Gov't Sec., Inc., 24 F.3d 480, 482 (3d Cir.1994). The defendants' claim that the Preliminary Offering Circular (the "pitch bookl,
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%"
ts, the documents "bespeak caution" to the investor and the investor cannot later premise a fraud claim on the events of which he has been warned. Kline v. First Western Gov't Sec., Inc., 24 F.3d 480, 4289 (3d Cir. 1994). The defendants' claim that the Preliminary Offering Circular [the "pitch book"
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
Entities connected to both Kline and Davison

Jeffrey Epstein
PERSON
George Mitchell
PERSON
Alfredo Rodriguez
PERSON
Marc Rich
PERSON
John F. Kennedy
PERSON
George W. Bush
PERSON
Prince Charles
PERSON
Ghislaine Maxwell
PERSONDangene
PERSON
Eric Trump
PERSON
Prince Andrew
PERSON
United States
LOCATION
Wilbur Ross
PERSON
New York
LOCATION
Michael Jackson
PERSON
Julie K. Brown
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Richard Kahn
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Woody Allen
PERSON