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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%"
ontacted Davison and other employees of Citibank, and requested Citibank's help in coordinating the replacement of the MG fund's manager. (Id 121; Schantz Decl. 1 5.) In May 2001, Davison informed the plaintiffs that, in order to remove MG as the fund manager, FTC would need sixty- six and two-thirds perc
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 [hisj investment, with a possible return of as much as 30%" a
ntacted Davison and other employees of Citibank, and requested Citibank's help in coordinating the replacement of the AIG fund's manager. (Id. ¶ 21; Schantz Decl. ¶ 5.) In May 2001, Davison informed the plaintiffs that, in order to remove AIG as the fund manager, FTC would need sixty-six and two-thirds percen
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
tacted Davison and other employees of Citibank, and requested Citibank's help in coordinating the replacement of the AIG fund's manager. (Id. 1 21; Schantz Decl. 1 5.) In May 2001, Davison informed the plaintiffs that, in order to remove AIG as the fund manager, FTC would need sixty-six and two-thirds perce
Entities connected to both Davison and Schantz Decl

Jeffrey Epstein
PERSON
New York
LOCATION
Julie K. Brown
PERSON
Prince Charles
PERSON
Michael Jackson
PERSONthe Southern District
LOCATION
U.S. Virgin Islands
LOCATIONthe AIG Investment
ORGANIZATIONMaria Farmer
PERSON
Financial Trust Company
ORGANIZATIONRockefeller Ctr
ORGANIZATIONMaria Tankenson Hodge
PERSON
JPMorgan Chase
ORGANIZATIONUJB Fin. Corp.
ORGANIZATIONGregory H. Hodges
PERSONShapiro
PERSONCitigroup, Inc.
ORGANIZATIONDayle Davison
PERSONMarshall H. Fishman
PERSONthe State of New York
LOCATION