Epstein Secrets

r the plain- tiffs to amend their pleadings. I. FACTUAL AND PROCEDURAL BACKGROUND In their amended complaint, Jeffrey E. Epstein ("Epsteinn and Financial Trust Company, Inc. ("Fr) (collectively "plain- tiffs") allege that Citibank, N.A. ("Citi- bank") and Citigroup, Inc. ("Citigroup"I [collectively "defendants"] misrepre

itch book" referenced in the amended complaint is the document that plaintiffs rely on is a disputed fact that precludes a Rule 12(bX6) dismissal. Financial Trust Co., 268 F.Supp.2d at 572. Nothing in any of the briefs have convinced me that the parties do not dispute which pitch book Epstein received, what disc

ed to meet Federal Rule of Civil Proce- dure 9(b)'s heightened pleading standard. I did, however, grant the plaintiffs leave to amend the complaint Financial Trust Co.' Citibank, 268 F.Supp.2d 661 (D.Vir- gin Islands 2003). H. LEGAL ANALYSIS A. Federal Rule of Civil Procedure 9(b) (1-31 In order to state a viable

ically implausible antitrust claims must come forward with more persuasive evidence to support them EFTA00187401 Page I of 2 VVestiaw. Page 1 Maria Tankenson Hodge Current Firm Information Unknown hodgfranOislands.vi Position: Member Education: University of California at Berkeley, Boalt Hall School of Law,

me: Customer Remarks: Language: English Marital Status: Birth Data: ID Number: ID Number. Horne Owners: Birth Date: Exp. Date: Employer: Financial Trust Employee Sims: Occupation: ACCOUntaril Address: 6500 Red Rook Quaeters, Suite 113 City: ST Tlainal State: Employer Phone: Emproymont Matt

M1D4AEL MAGRAS; RANDOLPH RAYMO Subject: FT REAL ESTATE INC Good Morning Heidi, Reference our teiephone conversabon this morning Jeanne Brennan of Financial Trust Company, Inc submitted documents to establish a new account in he above name. The following documents are missing. Certificate of Incorporation. Certificate of

Hook Quarter. Sate B-3. American Yacht Harbor, St. Thomas, Virgin Jet* --.1 Ca ""— - re C. The name of the raidem agent of this corporation is Maria Tankenson Hodge, c .r- O1 Taarneberg, St. Thomas, Virgin Islands. % R1 g; a re) CO ARTICLE THREE Purposes and Powers Wubout limiting in any manna the scope

On November 27, 2002, I issued an order restraining Citibank and Citigroup from pursuing their New York lawsuit pending decisions on these motions. Financial Trust Co., Inc. v. Citibank, N.A., Order, Civ. No. 2002-108 (D.V.I. Nov. 27, 2002). In light of subsequent events, however, I sua sponte vacated this prohibition.

73, 879-80 (3d Cir. 1995). Considering the totality of the circumstances surrounding this case, I make the following findings. First, Epstein and Financial Trust have selected this forum, and they are residents of the Virgin Islands with strong ties to this community. Epstein owns a seventy-acre island, and

NCIAL TRUST COMPANY, INC. AND JEFFREY E. EPSTEIN, Plaintiffs, v. CITIBANK, N.A. AND CITIGROUP, INC. d/b/a "CITIGROUP," Defendants. ATTORNEYS: Maria Tankenson Hodge, Esq. Hodge & Francois St. Thomas, U.S.V.I., For the plaintiffs, Gregory H. Hodges, Esq. Dudley, Topper and Feuerzeig, LLP St. Thomas, U.S.V.I.

damages. Plaintiffs have thus alleged enough information to survive a Rule 12(b)(6) motion on Case No. 08-80736-CV-MARRA P-000727 EFTA00228107 k Financial Trust Co. v. Citibank Civil No. 02-108 Memorandum Opinion Page 9 their fraud claims. C. The Mass .Mutual Investment Claims Although it is unclear from t

erentiate the counts between the Mass Mutual and AIG funds as defendant attempts to do. Case No. 08-80736-CV-MARRA P-000729 EFTA00228109 I .• Financial Trust Co. Inc. I. Citibank Civ. No. 2002-108 Memorandum Opinion Page 11 ENTERED this 30th day of December, 2004. FOR THE COURT: /s/ Thomas K. Moore Distri

) ) Plaintiffs, v. ) ) ) Civ. No. 2002-108 ) CITIBANK, N.A. AND CITIGROUP, d/b/a "CITIGROUP," INC. ) ) ) Defendants. ) ) ATTORNEYS: Maria Tankenson Hodge, Esq. Hodge & Francois St. Thomas, U.S.V.I., For the plaintiffs, Gregory H. Hodges, Esq. Dudley, Topper and Feuerzeig, LLP St. Thomas, U.S.V.I.

MMISSION ItXPIRSSJUNi27. 2004 EFTA00304833 Fenn 8869 (September 2000) Oepanment of the treinuT/ Interne ReNnue &ewe EMI 1 a Name of parent Financial Trust Company, Inc. Qualified Subchapter S Subsidiary Election (Under section 1361(b)(3) of the Internal Revenue Code) Parent S Corporation Making the Election b Nu

at the board of directors of the Corporation on June 23, 2005, did unanimously consent to the adoption of the following resolution: RESOLVED, that Maria Tankenson Hodge, 1340 Taameberg, St. Thomas, Virgin Islands, (340) 774-6845, be and hereby is duly appointed to serve as resident agent for service of legal proces

Compact Relating to Probation and Parole. Mr. Epstein is and has been a full-time resident of the Virgin Islands for over 10 years. His business, Financial Trust Company, Inc., located at Red Hook Quarter, has been an outstanding and active participant in the Virgin Islands community over that period. Mr. Epstein and his

uestions about this request, or if there is anything I can do to assist in completion of your review. Thank you for your attention. Respectfully, Maria Tankenson Hodge EFTA00722271

Dear Ms. Swan: My client, Jeffrey Epstein, is and has been a full-time resident of the Virgin Islands for over 10 years. His business, Financial Trust Company, Inc., located at Red Hook Quarter, has been an outstanding and active member of the Virgin Islands community. Through his business and his residence on

gly, we respectfully request your assistance with a confirmatory letter at your earliest convenience. Thank you for your attention. Respectfully, Maria Tankenson Hodge EFTA00727987

iled to meet Federal Rule of Civil Procedure 9(b)'s heightened pleading standard. I did, however, grant the plaintiffs leave to amend the complaint. Financial Trust Co. v. Citibank, 268 F. Supp.2d 561 (D.V.I. 2003). For internal use only SDNY_GM_00064428 CONFIDENTIAL - PURSUANT TO FED. R.CON(F IDENTIAL DB-SDNY-00

o whom it was made; (4) the intention that it should be acted upon; and (5) that the plaintiff acted upon it to his damage. COUNSEL: ri] ATTORNEYS: Maria Tankenson Hodge, Esq., Hodge & Francois, St. Thomas, U.S.V.I., For the plaintiffs. Gregory H. Hodges, Esq., Dudley, Topper and Feuerzeig, LLP, St. Thomas, U.S.V.I

Division of Corporation and Trademarks, 5049 Kongens Cade, St. Ate AL, r '-6487.) . • • : • • Certified Correct Treasurer EFTA00310724 FINANCIAL TRUST COMPANY, INC. 6100 RED HOOK QUARTERS, 6-3 ST. THOMAS, VI 00802 FIRENHANK PUERTO 81C0 ST. THOMAS, VI00802 101.728612216 3750 50600 • Taxes:50601 • Franchise

s of designated office 6100 Red Hook Ouarter B3 St. Thomas U.S. Virgin Islands 00802 (c) Name of Agent for service of process in the Virgin Islands Maria Tankenson Hodge (d) Physical address of Agent 1340 Taruneberg St. Thomas U.S. Virgin Islands 00802 3) Mailing address of Principal office 6100 Red Hook Ouaner B3

e to get more clarity on the lawsuit below. Many thanks, Daniel FINANCIAL TRUST CO., INC. v. CITIBANK N.A. ryo 0W2002-108 268 F Supp 2d 561 (2003) FINANCIAL TRUST COMPANY, INC. and Jeffrey E. Epstein, Plaintiffs, v. CITIBANK, N.A. and Citigroup, Inc. d/b/a "Citigroup," Defendants. District Court, Virgin Islands, D. St. Tho

, v. CITIBANK, N.A. and Citigroup, Inc. d/b/a "Citigroup," Defendants. District Court, Virgin Islands, D. St. Thomas and St 'kiln. June 19, 2003. Maria Tankenson Hodge, Hodge S Francois, St. Thomas, VI, for the plaintiffs. Gregory H. Hodges. Dudley, Topper and Feuerzeig, LW, St Thomas. VI, for the defendants. MEMO