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r story'—that is, the who, what, when, where and how' of the events at issue." In re Rockefeller Ctr. Props., inc., 311 F.3d at 217 (quoting in re Burlington, 114 F.34 at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted the mak- ing of fraudulent misrepresentations ... reg
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
tory' - that is the 'who, what, when, where and how' of the events at issue.'" In re Rockefeller Ctr. Props., Inc., 311 F.3d at 217 (quoting In re Burlington, 114 F.3d at 1422). However, the Third Circuit Court of Appeals has held that the "requirements of Rule 9(b) may be satisfied if the complaint desc
damages. Plaintiffs have thus alleged enough information to survive a Rule 12(b)(6) motion on Case No. 08-80736-CV-MARRA P-000727 EFTA00228107 k Financial Trust Co. v. Citibank Civil No. 02-108 Memorandum Opinion Page 9 their fraud claims. C. The Mass .Mutual Investment Claims Although it is unclear from t
erentiate the counts between the Mass Mutual and AIG funds as defendant attempts to do. Case No. 08-80736-CV-MARRA P-000729 EFTA00228109 I .• Financial Trust Co. Inc. I. Citibank Civ. No. 2002-108 Memorandum Opinion Page 11 ENTERED this 30th day of December, 2004. FOR THE COURT: /s/ Thomas K. Moore Distri
edia - No COLA cases Financial Infomatia Inc - No negative media - No court cases - No negative media -No court Ca - Negative media Is for from Burlington and in one of the negative media her age mismatches. from our KYC Is from New Mexico - Court cases are fa from Louisiana, INols Pemsylvania, Alban
into an enormous residence. Epstein later bought that property, n the wealthiest part of Manhattan. In 1996, Epstein changed the name of Ns firm to the Financial Trust Company and, for tax advantages, based e on the island of St Thanes in the U.S. Virgin Islands. In 2003, Epstein bid to acquire New Yak magazine. Other bid
Entities connected to both Burlington and Financial Trust Company

Jeffrey Epstein
PERSONDarren Indyke
PERSON
JPMorgan Chase
ORGANIZATION
U.S. Virgin Islands
LOCATION
Les Wexner
PERSON
Richard Kahn
PERSON
John Brennan
PERSON
Bear Stearns
ORGANIZATIONHarry Beller
PERSON
NEW YORK NY
LOCATION
Ghislaine Maxwell
PERSONSouthern Trust Company
ORGANIZATION
Newark
LOCATION
FedEx
ORGANIZATION
Alan Dershowitz
PERSON
George W. Bush
PERSON
United States
LOCATION
Puerto Rico
LOCATIONLeon Black
PERSON
Eric Holder
PERSON