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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
volved in the deal. (Compl. P 14.) In August 2001, in an effort to dissuade Epstein from seeking to remove AIG as the manager of the AIG Investment, John Purcell, a Citibank representative, told Jeffrey Schantz, a lawyer for Epstein, that Citibank was acting in Epstein's interests and that Epstein should tru
, 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,
lved in the deal. (Comp1.1 14.) In August 2001, in an effort to dissuade Epstein from seeking to remove AIG as the manager of the AIG Investment, John Purcell, a Citibank representative, told Jeffrey Schantz, a lawyer for Ep- stein, that Citibank was acting in Ep- stein's interests and that Epstein should
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"
00723 EFTA00228103 Financial Trust Co. v. Citibank Civil No. 02-108 Memorandum Opinion Page 5 remove AIG as the manager of the AIG Investment, John Purcell, a Citibank representative, told Jeffrey Schantz, a lawyer for Epstein, that Citibank was acting in Epstein's interests and that Epstein should tr
Entities connected to both Kline and John Purcell

Jeffrey Epstein
PERSON
John F. Kennedy
PERSON
Ghislaine Maxwell
PERSON
Prince Charles
PERSON
George W. Bush
PERSON
United States
LOCATIONMaria Farmer
PERSON
Philadelphia
LOCATION
Michael Jackson
PERSON
New York City
LOCATION
New York
LOCATIONUJB Fin. Corp.
ORGANIZATIONDayle Davison
PERSONDubinsky
PERSONRockefeller Ctr
ORGANIZATIONthe AIG Investment
ORGANIZATION
Julie K. Brown
PERSONJordache
ORGANIZATIONJeffrey Schantz
PERSON
Financial Trust Company
ORGANIZATION