Epstein Secrets

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

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%"

per 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.3d at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted the making of fraudulent misrepresentations ... regardi

plaintiffs, however, shall have THIRTY DAYS within which to file an amended complaint with respect to these counts. FOOTNOTES 1. Sometime in 2000, Davison informed Epstein about a second, similar investment fund to be managed by Mass Mutual [the "Mass Mutual Fund']. On June 15, 2000, Epstein borrowed a

per 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.3d at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted the making of fraudulent misrepresentations ... regardi

plaintiffs, however, shall have THIRTY DAYS within which to file an amended complaint with respect to these counts. FOOTNOTES 1. Sometime in 2000, Davison informed Epstein about a second, similar investment fund to be managed by Mass Mutual CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0087

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

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