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01, in an effort to dissuade Epstein from seeking to remove AIG as the manager of the AIG Investment, John Purcell, a Citibank representative, told Jeffrey Schantz, a lawyer for Epstein, that Citibank was acting in Epstein's interests and that Epstein should trust Citibank rather than talk about actions which
n to introduce him to an "exceptional investment opportunity." (Compl. P 13.) In follow-up telephone conversations during that same two week period, Davison and her associates r 5] made additional specific representations about the AIG Investment, without disclosing Citibank and AIG's relationship. Davi
his right of first refusal and renew the lease. Epstein contends that in a telephone confer- ence between Richard Massey of OFM and EFTA00187393 Jeffrey Schantz, Epstein's transaction coun- sel, on April 19, 1996, OFM orally consented to Epstein's request to sublet the Premises to Fisher. The same day, Epst
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%"
tibank Civil No. 02-108 Memorandum Opinion Page 5 remove AIG as the manager of the AIG Investment, John Purcell, a Citibank representative, told Jeffrey Schantz, a lawyer for Epstein, that Citibank was acting in Epstein's interests and that Epstein should trust Citibank rather than talk about actions which
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
Entities connected to both Jeffrey Schantz and Davison

Jeffrey Epstein
PERSON
George W. Bush
PERSON
New York
LOCATION
Prince Charles
PERSON
United States
LOCATION
Michael Jackson
PERSON
Wilbur Ross
PERSON
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
Julie K. Brown
PERSON
Ralph Lauren
PERSON
U.S. Virgin Islands
LOCATION
Eric Trump
PERSONMaria Farmer
PERSON
Joe Biden
PERSON
George Mitchell
PERSON
Michael Cohen
PERSON
Phoenix
LOCATION