Epstein Secrets

int with respect to these counts. FOOTNOTES 1. Sometime in 2000, Davison informed Epstein about a second, similar investment fund to be managed by Mass Mutual [the "Mass Mutual Fund']. On June 15, 2000, Epstein borrowed an additional $10 million from Citibank, that Epstein agreed to invest in the Mass Mut

that would accompany 'the first paragraph of any newspaper story—that is, the 'who, what, when, where and how' of the events at issue." In re Rockefeller Ctr. Props.. Inc.. 311 F.3d at 217 (quoting In re Burlington, 114 F.3d at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted

int with respect to these counts. FOOTNOTES 1. Sometime in 2000, Davison informed Epstein about a second, similar investment fund to be managed by Mass Mutual CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0087598 CONFIDENTIAL SDNY_GM_00233782 EFTA01386064

round that would accompany 'the first paragraph of any newspaper story—that is, the 'who, what, when, where and how' of the events at issue." In re Rockefeller Ctr. Props.. Inc.. 311 F.3d at 217 (quoting In re Burlington, 114 F.3d at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted

y "a transparent attempt to launch a preemptive Sometime in 2000, Davison informed Epstein about a second, similar investment fund to be managed by Mass Mutual (the "Mass Mutual Fund"). On June 15, 2000, Epstein borrowed an additional $10 million from Citibank, that Epstein agreed to invest in the Mass Mut

an increased measure of protection for their reputations, and reduce[] the number of frivolous suits brought solely to extract settlements." In re Rockefeller Ctr. Props., Inc., 311 F.3d at 215 (quoting In re Burlington Coat Factory Sec. Litig., 114 F.3d at 1418). "Rule 9(b) requires a plaintiff to plead (1)