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

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

the Amended 1999 Note. (Id. Ex. A at 8-9: Ex. B at 7-8: Ex. D at 10; Ex. Eat 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. ¶ 20.) According to the plaintiffs, FTC's 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

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

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