Epstein Secrets

laced. In the Amended 1999 Note, the parties stipu- lated only that IOUs note shall be governed by, and construed in accordance with, the laws of the State of New York, including matters of construction, validity and per- formance, without giving effect to princi- ples of conflicts of law .... (Mem. Of Law in Supp

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%"

placed. In the Amended 1999 Note, the parties stipulated only that [t]his note shall be governed by, and construed in accordance with, the laws of the State of New York, including matters of construction, validity and performance, without giving effect to principles of conflicts of law . . . . (Mem. Of Law in Sup

plaintiffs seek rescission of the promissory note and punitive damages (Counts VI and VII). (Am. Compl. III 45-68.) In April 1999, Dayle Davison ["Davison"], Vice President of Citibank in New York and Epstein's private banker, and other Citibank employees telephoned Epstein while he was in the Virgin

s of the State of Ohio and resided at One Whitsibarn Road, New Albany, Ohio 43054. 3. Defendant, Jeffrey B. irstein, is a resident and citizen of the State of New York. Jeffrey E. Epstein, was at all arti ispieze 4 fitel ttotlittli Case No. 08-80736-CV-MARRA 4mq ORMli UW040)0704 EFTA00228084 relevant times,

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