Epstein Secrets

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

should be acted upon; and (5) that the plaintiff acted ("8] upon it to his damage."' Financial Trust Co., 268 F. Supp.2d at 575 (quoting Shapiro 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

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

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

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

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