Epstein Secrets

n to introduce him to an "exceptional investment opportunity." (Compl. P 13.) In 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. Davi

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 Coat Factory Sec. Litig., 114 F.3d 1410, at ["**438] 1422). However, the ["4] Third Circuit Court of Appeals has held that the "requirements of Rule 9(b) may be sat

plaintiffs, however, shall have THIRTY DAYS within which to file an amended complaint 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-0087

d 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) a specific false representation of material fact; (2) knowledge by the per

plaintiffs seek rescission of the promissory note and punitive damages (Counts VI and VII). (Am. Compl. III 45-68.) In April 1999, Dayle Davison ["Davison"], Vice President of Citibank in New York and Epstein's private banker, and other Citibank employees telephoned Epstein while he was in the Virgin

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) a specific false representation of material fact; (2) knowledge by the pe