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

tity Status: INACTIVE Selected Entity Address Information DOS Process (Address to which DOS will mail process if accepted on behalf of the entity) GOLD & WACHTEL, ESQS 10 EAST 53RD STREET NEW YORK, NEW YORK, 10022 Registered Agent NONE NOTE: New York State does not issue organizational identification numb

NITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK (Foley Square - NYC) Citibank, NA v. Epstein, et al PLAINTIFF: Citibank, NA DEFENDANT: Financial Trust Company, Inc; Epstein, Jeffrey E DOCKET CASE NUMBER: 1:02cv5332 FILING DATE: 7/11/2002 JURISDICTION: Diversity JUDGE: Stein, Sidney H NATURE OF SUIT: 190 Ot

S ALL WARRANTIES, EXPRESSOR IMPLIED, REGARDING THIS DATA. NEW YORK DEPARTMENT OF STATE Company Name: J. EPSTEIN & COMPANY, INC. Process Address: GOLD & WACHTEL, ESQS 10 EAST 53RD STREET NEW YORK, NY 10022 Type: DOMESTIC BUSINESS Status: INACTIVE Status Comment: DISSOLUTION Filing Date: 4/4/2001 Durati

NITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK (Foley Square - NYC) Citibank, NA v. Epstein, et al PLAINTIFF: Citibank, NA DEFENDANT: Financial Trust Company, Inc; Epstein, Jeffrey E DOCKET CASE NUMBER: 1:02cv5332 FILING DATE: 7/11/2002 JURISDICTION: Diversity JUDGE: Stein, Sidney H NATURE OF SUIT: 190 Ot

S ALL WARRANTIES, EXPRESSOR IMPLIED, REGARDING THIS DATA. NEW YORK DEPARTMENT OF STATE Company Name: J. EPSTEIN & COMPANY, INC. Process Address: GOLD & WACHTEL, ESQS 10 EAST 53RD STREET NEW YORK, NY 10022 Type: DOMESTIC BUSINESS Status: INACTIVE Status Comment: DISSOLUTION Filing Date: 4/4/2001 Durati

we discussed, I have attached hereto the subpoenas to J. Epstein Virgin Islands Foundation, Inc., J. Epstein & Company Inc., Epstein Interests, and Financial Trust Company, Inc. I understand that you are representing these entities for the purpose of accepting service, but the entities may retain different counsel at a late

ration: Duration: Status: Status Attained Date: Corporation Type: Business Type: Where Filed: COMPANY INFORMATION J. EPSTEIN & COMPANY, INC. GOLD & WACHTEL, ESQS FILING INFORMATION 11/18/1988 NEW YORK PERPETUAL INACTIVE 04/04/2001 PROFIT DOMESTIC BUSINESS CORPORATION DEPARTMENT OF STATE/DIVISION