Epstein Secrets

M again wrote to Epstein reiterating that the exercise of his right of first refusal was premature, and explaining that the prior arrangement with Gaines was not a binding contract, but rather merely an "expression of interest: Then, on May 16, 1996, OFM officials visited the Premises and discovere

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

t and will get back with you. Thanks again. From: Sloane, Carmen Sent: Wednesday, September 23, 2009 5:19 PM To: Barbara Bums Cc: Baker, Rosalyn; Gaines, Willie Subject: Jeffrey Epstein «P154Scanner20090923170423.pdf>> Mrs. Bums, FYI - This is Mr. Epstein response to Attorney Horowitz declaration.

sI 145 Government of the U.S. limn Islands Economic Development Commission Application for Economic Developmen enefits to Name, f Applicant: Financial Trust Company, Inc. FOR.OFFiCIAI, USE ONLY Dates Racekck Amptcd as Complctc: 1 TYPE OF APPLICATION: NEW EXTENSION SMALL MANUFACTURFR MODIFICATION fl TRANSFER ri

mptcd as Complctc: 1 TYPE OF APPLICATION: NEW EXTENSION SMALL MANUFACTURFR MODIFICATION fl TRANSFER rij EFTA01625830 1. CONTACT INFORMATION EIN Financial Trust Company. Inc. A.) Name of Applicant' B.) Mailing Addresr 6100 Red Hook Quarter, 8.3, St. Thomas, VI 00802 C.) Plant/Facility Location: Island St. Thoma

ll get back with you. Thanks again. From: Sloane, Carmen [mailto Sent: Wednesday, September 23, 2009 5:19 PM To: Barbara Bums Cc: Baker, Rosalyn; Gaines, Willie Subject: Jeffrey Epstein «P154Scanner20090923170423.pdf>> Mrs. Bums, FYI - This is Mr. Epstein response to Attorney Horowitz declaration.

sI 145 Government of the U.S. limn Islands Economic Development Commission Application for Economic Developmen enefits to Name, f Applicant: Financial Trust Company, Inc. FOR.OFFiCIAI, USE ONLY Dates Racekck Amptcd as Complctc: 1 TYPE OF APPLICATION: NEW EXTENSION SMALL MANUFACTURFR MODIFICATION fl TRANSFER ri