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

14 F.3d at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted the making of fraudulent misrepresentations ... regarding the AIG Investment" that the defendants knew were materially misleading "because of their failure to state or disclose the additional or qualifying information regardi

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

14 F.3d at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted the making of fraudulent misrepresentations ... regarding the AIG Investment" that the defendants knew were materially misleading "because of their failure to state or disclose the additional or qualifying information regardi

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

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