Epstein Secrets

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

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. Davison also during that period represented that Citibank had "done their due diligence" and w

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,

F.34 at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted the mak- ing of fraudulent misrepresentations ... regarding the AIG Investment" that the defendants knew were materially mislead- ing "because of their failure to state or disclose the additional or qualifying infor- mation re

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.

he Amended 1999 Note. (Id. Ex. A at 8-9; Ex. B at 7-8; Ex. D at 10; Ex. E at 2-3.) Sometime in the spring of 2001, Epstein and FTC discovered that the AIG Investment was "suddenly and rapidly deteriorating." (Pls.' Mem. Of Law in Opp'n to Mot. To Dismiss, Epstein Decl. 1 20.) According to the plaintiffs, FTC's a

) ) 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.

) 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 also during that period represented that Citibank had "done their due diligence" and