Epstein Secrets

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. Davison also during that period represented that Citibank had "done their due diligence" and w

misrepresentation for these statements; rather, it requires only that the plaintiff identify the facts not communicated. See Golden Trade, S.R.L. v Jordache, 143 F.R.D. 504 (S.D.N.Y. 1992); Cottman Transmission Sys. Inc. v. Dubinsky, 95 F.R.D. 351, 353 (E.D. Pa. 1982) ("Conduct which never occurred cann

F.34 at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted the mak- ing of fraudulent misrepresentations ... regarding the AIG Investment" that the defendants knew were materially mislead- ing "because of their failure to state or disclose the additional or qualifying infor- mation re

ep- resentation for these statements; rather, it requires only that the plaintiff identify the facts not communicated. See Golden Trade, S.r.L. I Jordache, 143 F.R.D. 504 (S.D.N.Y.1992); Coltman Transmission Sys Inc. Dubinsky, 95 F.R.D. 351, 353 (E.D.Pa.1982) ("Conduct which never oc- curred cannot

) In follow-up telephone conversations during that same two week period, Davison and her associates made additional specific representations about the AIG Investment, without disclosing Citibank and AIG's relationship. Davison also during that period represented that Citibank had "done their due diligence" and

misrepresentation for these statements; rather, it requires only that the plaintiff identify the facts not communicated. See Golden Trade, S.R.L. v Jordache, 143 F.R.D. 504 (S.D.N.Y. 1992); Cottman Transmission Sys. Inc. v. Dubinsky, 95 F.R.D. 351, 353 (E.D. Pa. 1982)("Conduct which never occurred canno