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naged by MG. (Compl. 1112, 24; Epstein Decl. 118-10; Davison Aft 11 1, 102-18.) According to the plaintiffs, during the negotiations of this deal Davison represented to Epstein that he was "virtually assured of receiving an 18-20% return on [his] investment, with a possible return of as much as 80%"
B's relationship with MG was dis- lished that there exists no private right of action for claims that are within the purview of the [Martin] Act.); Granite Partners, L.P. Bear, Stearns, & Co., Inc., 17 F.Supp.2d 275, 291 (S.D.N.Y.1998) (same); Deutsch I Inte- grated Barter Ina Inc. 700 F.Supp. 194 (S.D.N.Y.I98
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 [the "Mass Mutual Fund']. On June 15, 2000, Epstein borrowed a
Sept. 10, 2002) Cult is well established that there exists no private right of action for claims that are within the purview of the [Martin] Act.); Granite Partners, L.P. v. Bear, Steams, & Co., Inc., 17 F.Supp.2d 275, 291 (S.D.N.Y. 1998) (same); Deutsch v. Integrated Barter Ina Inc. 700 F.Supp. 194 (S.D.N.Y.19
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
pt. 10, 2002) ("(Ilt is well established that there exists no private right of action for claims that are within the purview of the (Martin] Act.); Granite Partners, L.P. v. Bear, Stearns, & Co., Inc., 17 F. Supp. 2d 275, 291 (S.D.N.Y. 1998) (same); Deutsch v. Integrated Barter Int'l, Inc. 700 F. Supp. 194 (S.D
Entities connected to both Davison and Granite Partners

Jeffrey Epstein
PERSON
Julie K. Brown
PERSON
New York
LOCATION
Prince Charles
PERSON
Michael Jackson
PERSON
U.S. Virgin Islands
LOCATIONthe AIG Investment
ORGANIZATIONthe Southern District
LOCATIONMaria Farmer
PERSONRockefeller Ctr
ORGANIZATION
Financial Trust Company
ORGANIZATIONGregory H. Hodges
PERSON
the United States District Court
ORGANIZATIONDeutsch
PERSONUJB Fin. Corp.
ORGANIZATIONMaria Tankenson Hodge
PERSONDayle Davison
PERSONShapiro
PERSONCitigroup, Inc.
ORGANIZATIONBurlington
LOCATION