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

rder, the proceedings should be stayed pending the adjudication of the first-filed action. (sac) (Entered: 10/16/2002) 10/09/2002 13 AFFIDAVIT of Dayle Davison by Citibank, N.A. in opposition to [7-1] motion for an order, pun. to Rules 1, 12 and 13(a) of the FRCP, dismissing the Complaint, [7-2] motion for

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

(Count V). The 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 t

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,

that defendants were acting in plaintiffs' best interests. For example, it is alleged that in conversations between April 29, 1999 and May 2, 1999, Dayle Davison, a Vice President of Citibank in the Private Banking Division, called Epstein to introduce him to an "exceptional investment opportunity." (Compl.