Epstein Secrets

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

that defendants were acting in plaintiffs' best interests. For example, it is alleged that in conversations between April 29, 1999 and May 2, 1999, Dayle Davison, a Vice President of Citibank in the Private Banking Division, called Epstein to introduce him to an "exceptional investment opportunity." (Compl. P

, 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,

rder, the proceedings should be stayed pending the adjudication of the first-filed action. (sac) (Entered: 10/16/2002) 10/09/2002 13 AFFIDAVIT of Dayle Davison by Citibank, N.A. in opposition to [7-1] motion for an order, pun. to Rules 1, 12 and 13(a) of the FRCP, dismissing the Complaint, [7-2] motion for

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"

that defendants were acting in plaintiffs' best interests. For example, it is alleged that in conversations between April 29, 1999 and May 2, 1999, Dayle Davison, a Vice President of Citibank in the Private Banking Division, called Epstein to introduce him to an "exceptional investment opportunity." (Compl.