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

he person to whom it was made; (4) the intention that it should be acted upon; and (5) that the plaintiff acted upon it to his damage." Shapiro I UJB Fin. Corp., 964 F.2d 272, 284 (3d Cir.1992). Although the rule does not require a recitation of "every material detail" of the alleged fraud, it does require

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

the person to whom it was made; (4) the intention that it should be acted upon; and (5) that the plaintiff acted upon it to his damage." Shapiro v. UJB Fin. Corp., 964 F.2d 272, 284 (3d Cir. 1992). Although the rule does not require a recitation of EFTA01726537 Financial Trust Co., Inc. v. Citibank, N.A. C

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,

it should be acted upon; and (5) that the plaintiff acted upon it to his damage.'" Financial Trust Co., 268 F. Supp.2d at 575 (quoting Shapirio v. UJB Fin. Corp., 964 F.2d 272, 284 (3d Cir. 1992)). The defendants base their argument that plaintiffs have failed to state a claim upon which relief can be grant