Epstein Secrets

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

ey E. Epstein, Financial Trust. (rec'd in the night deposit box on 10/9/02 at 5:06 p.m.) (sac) (Entered: 10/16/2002) 10/09/2002 10 DECLARATION of Edward S. Feig by Jeffrey E. Epstein, Financial Trust in support Re: [7-1] motion for an order, puns. to Rules 1, 12 and 13 (a) of the FRCP, dismissing the Compla

he Amended 1999 Note. (Id. Ex. A at 8-9; Ex. B at 7-8; Ex. D at 10; Ex. E at 2-3.) Sometime in the spring of 2001, Epstein and FTC discovered that the AIG Investment was "suddenly and rapidly deteriorating." (Pls.' Mem. Of Law in Opp'n to Mot. To Dismiss, Epstein Decl. 1 20.) According to the plaintiffs, FTC's a

y H. Hodges, Esq. Maria Tankenson Hodge, Esq. Marshall H. Fishman, Esq. Kramer Levin Naftalis & Frankel LLP 919 Third Avenue, New York, NY 10022 Edward S. Feig, Esq. Arent, Fox, Klintner, Plotkin & Kahan, PLLC 1675 Broadway, 25th Floor New York, NY 10019-5874 Mrs. Jackson Brittany Nelson EFTA01726508

) 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

y H. Hodges, Esq. Maria Tankenson Hodge, Esq. Marshall H. Fishman, Esq. Kramer Levin Naftalis & Frankel LLP 919 Third Avenue, New York, NY 10022 Edward S. Feig, Esq. Arent, Fox, Klintner, Plotkin & Kahan, PLLC 1675 Broadway, 25th Floor New York, NY 10019-5874 Mrs. Jackson Brittany Nelson Case No. 08-80