Epstein Secrets

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

that defendants were acting in plaintiffs' best interests. For example, it is alleged that in conversations between April 29, 1999 and May 2, 1999, Dayle Davison, a Vice President of Citibank in the Private Banking Division, called Epstein to introduce him to an "exceptional investment opportunity." (Compl. P

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

rder, the proceedings should be stayed pending the adjudication of the first-filed action. (sac) (Entered: 10/16/2002) 10/09/2002 13 AFFIDAVIT of Dayle Davison by Citibank, N.A. in opposition to [7-1] motion for an order, pun. to Rules 1, 12 and 13(a) of the FRCP, dismissing the Complaint, [7-2] motion for

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

that defendants were acting in plaintiffs' best interests. For example, it is alleged that in conversations between April 29, 1999 and May 2, 1999, Dayle Davison, a Vice President of Citibank in the Private Banking Division, called Epstein to introduce him to an "exceptional investment opportunity." (Compl.