Epstein Secrets

d Procedural History In their second amended complaint, Jeffrey E. Epstein and Financial Trust Company, Inc. ["FTC"] allege that Citibank, N.A. and Citigroup, Inc. [collectively "Citibank"] misrepresented facts and fraudulently r**4371 induced them to borrow $ 10 million to invest in a venture managed by AIG G

by the person to whom it was made; (4) the intention that it should be acted upon; and (5) that the plaintiff acted upon it to his damages." in re Rockefeller Ctr. Props. Secs. Litig., 311 F.3d 198, 215 (3d Cir. 2002). Courts should apply Rule 9(b) with some flexibility and should not require plaintiffs to pl

d in plaintiffs favor, and accordingly, bond will be waived. FINANCIAL TRUST COMPANY, INC. and Jeffrey E. Epstein, Plaintiffs, CITIBANK, N.A. and Citigroup, Inc. d/b/a "Citigroup," Defendants. No. CIV.2002-108. District Court, Virgin Islands, D. St. Thomas and St. John. June 19, 2003. Borrowers brought a

e 12(b)(6) motion, I ac- cept all allegations in the complaint as true, and draw all reasonable inferences in favor of the non-moving party. In re Rockefeller Ctr. Props., Int, 311 F.3d 198, 215 (3d Cir.2002). "The inquiry is not whether plaintiffs will ultimately prevail in a trial on the merits, but whethe

, Jeffrey E. Epstein ("Epstein") and Financial Trust Company, Inc. ("FTC"] [collectively "plaintiffs"] allege that Citibank, N.A. ("Citibank") and Citigroup, Inc. ["Citigroup"] [collectively "defendants"] misrepresented facts and fraudulently induced them to borrow $10 million to invest in a venture managed b

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)

Financial Trust Co. v. Citibank Civil No. 02-108 Memorandum Opinion Page 2 Financial Trust Company, Inc. ["FTC"] allege that Citibank, N.A. and Citigroup, Inc. [collectively "Citibank") misrepresented facts and fraudulently induced them to borrow $ 10 million to invest in a venture managed by AIG Global In

d 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). However, the Third Circuit Court of Appeals has held that the "require