Epstein Secrets

ich to amend the EFTA00187476 576 263 FEDERAL SUPPLEMENT, 2d SERIES complaint to comport with Rule 9(b).2 See In n Burlington Coat Factory Sec. Lilly., 114 F.3d at 1434 (noting that ordinarily, when a complaint is dismissed under Rule 9(b) for failure to plead fraud with the requisite particula

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

MIS C. (USAFLS) From: Gerald Lefcourt [[email protected]] Sent: 007 11:56AM To: C. (USAFLS) Cc: Lilly anchez Subject: RE: Representation of Financial Trust Company, Inc., J. Epstein & Company, Inc., and other corporate entities , when we spoke las

ny, Inc., and other corporate entities , when we spoke last Thursday I agreed to accept service of a subpoena (without promising I would represent Financial Trust depending on what was being requested) that I think you said you would fax. This is just to let you know that I never received any fax to that end -

of July 2005, you have served as counsel to Financial Trust Company, Inc. in connection with litigation. Can you let me know if you still represent Financial Trust Company, Inc., and if you represent J. Epstein & Company, Inc., .1. Epstein Virgin Islands Foundation, Inc., and/or Epstein Interests? If you represent any or a

between his attorneys and your office, Epstein secretly withheld correspondence by several of his mostii ral owered attorneys — namely Ken Starr and Lilly. Sanchez. Epstein settled the case wit within days after this limited production, and we did not realize the absence of what must have been critic

g to work" and "eligible for re-employment" at The Florida Science Foundation. Please be advised that the only W-2 that Mr. Epstein provided is from Financial Trust Company, Inc., which shows that Mr. Epstein was employed in the U.S. Virgin Islands at a salary of $180,785.62, not $250,000. Mr. Epstein provided to you no docu

founder of The Florida Science Foundation and Mr. Indyke is its Vice President. More importantly, Mr. Epstein is also the founder and President of the Financial Trust Company, his for-profit corporation. Mr. Indyke is Mr. Epstein's subordinate at that entity as well. One of Mr. Epstein's attorneys has suggested that Mr.

al #18. 2/6/2007 Grand Jury Testimony of E. Nesbitt Kuyrkendall 2/12/2007 A. Marie Villafafia Lilly Ann Sanchez Emails between Villafatia and Lilly Ann Sanchez regarding employee representation with Lourie and Villafatia handwritten notes 2/14/2007 Subpoena to Colonial Bank (return date 3/6/07

ald Lefcourt Production response to 5/31/07 subpoenas to J. Epstein Virgin Islands Foundation, Inc., J. Epstein & Co., Inc., Epstein Interests, and Financial Trust Company, Inc. 6/13/2007 Subpoena to Majestic Theatre (return date 6/06/07) 6/13/2007 Subpoena to Broward Center for the Performing Arts (return date 6/26/07)

ntation of Epstein 12 8/4/2006 Victim Notification Letters 13 WI1/2006 Victim Notification Letters 14 1/17/07- 2/1/07 Correspondence between Lilly Ann Sanchez, Gerald Lelcourt, Andrew Laurie, A. Marie Villafrina, and John McMillan regarding 2/1/2007 Meeting 15 11/13/06- 1/22/07 Subpoenas to

ald Lefcourt Production response to 5/31/07 subpoenas to J. Epstein Virgin Islands Foundation, Inc., J. Epstein & Co., Inc., Epstein Interests, and Financial Trust Company, Inc. 6/13/2007 Subpoena to Majestic Theatre (return date 6/06/07) 6/13/2007 Subpoena to Broward Center for the Performing Arts (return date 6/26/07)