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FOR PUBLICATION FOR UPLOAD IN THE DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN FINANCIAL TRUST COMPANY, INC. AND JEFFREY E. EPSTEIN, Plaintiffs, v. CITIBANK, N.A. AND CITIGROUP, INC. d/b/a "CITIGROUP," Defendants. ATTORNEYS: Maria Tankenson Hodge, Esq. Hodge & Francois St
ill grant leave for the plaintiffs to amend their pleadings. I. FACTUAL AND PROCEDURAL BACKGROUND In their amended complaint, Jeffrey E. Epstein ("Epstein") and Financial Trust Company, Inc. ("FTC"] [collectively "plaintiffs"] allege that Citibank, N.A. ("Citibank") and Citigroup, Inc. ["Citigroup"]
AND ST. JOHN FINANCIAL TRUST COMPANY, INC. AND JEFFREY E. EPSTEIN, Plaintiffs, v. CITIBANK, N.A. AND CI
AND ST. JOHN FINANCIAL TRUST COMPANY, INC. AND JEFFREY E. EPSTEIN, Plaintiffs, v. CITIBANK, N.A. AND CIT
y "a transparent attempt to launch a preemptive Sometime in 2000, Davison informed Epstein about a second, similar investment fund to be managed by Mass Mutual (the "Mass Mutual Fund"). On June 15, 2000, Epstein borrowed an additional $10 million from Citibank, that Epstein agreed to invest in the Mass Mut
From: To: Jeffrey E. < Subject: FW: Mass Mutual policy Date: Tue, 09 May 2017 20:19:07 +0000 Attachments: Help can you can go with me on Monday pleaseeeeeeeeeeeeeeee read
From: To: Jeffrey E. < Subject: FW: Mass Mutual policy Date: Tu
ue, 09 May 2017 20:19:07 +0000 Attachments: Help can you can go with me on Monday pleaseeeeeeeeeeeeeeee read away xoxo Attached is a copy of your Mass Mutual policy along with the "plain English" explanation that John had forwarded to you. I will forward you the new proposed coverage in a separate email
From: Faith Kates • To: jeffrey E. <[email protected]> Subject: RE: FW: Mass Mutual policy Date: Tue, 09 May 2017 20:39:44 +0000 > When are you back did you read this From: Jef
00 > When are you back did you read this From: Jeffrey E. [mailto:[email protected] Sent: Tuesday,
ay 9, 2017 at 4:19 PM, Faith Kates • wrote: Help can you can go with me on Monday pleaseeeeeeeeeeeeeeee read away xoxo Attached is a copy of your Mass Mutual policy along with the "plain English" explanation that John had forwarded to you. I will forward you the new proposed coverage in a separate email
er, shall have THIRTY DAYS within which to file an amended complaint with respect to these counts. FOOTNOTES 1. Sometime in 2000, Davison informed Epstein about a second, similar investment fund to be managed by Mass Mutual [the "Mass Mutual Fund']. On June 15, 2000, Epstein borrowed an additional $10
int with respect to these counts. FOOTNOTES 1. Sometime in 2000, Davison informed Epstein about a second, similar investment fund to be managed by Mass Mutual [the "Mass Mutual Fund']. On June 15, 2000, Epstein borrowed an additional $10 million from Citibank, that Epstein agreed to invest in the Mass Mut
er, shall have THIRTY DAYS within which to file an amended complaint with respect to these counts. FOOTNOTES 1. Sometime in 2000, Davison informed Epstein about a second, similar investment fund to be managed by Mass Mutual CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0087598 CONFIDENTIAL
int with respect to these counts. FOOTNOTES 1. Sometime in 2000, Davison informed Epstein about a second, similar investment fund to be managed by Mass Mutual CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0087598 CONFIDENTIAL SDNY_GM_00233782 EFTA01386064
Entities connected to both Jeffrey Epstein and Mass Mutual

Julie K. Brown
PERSONthe Southern District
LOCATION
New York
LOCATION
the United States District Court
ORGANIZATIONDeutsch
PERSONShapiro
PERSONBurlington
LOCATIONDavison
PERSONRockefeller Ctr
ORGANIZATIONthe AIG Investment
ORGANIZATIONUJB Fin. Corp.
ORGANIZATIONGranite Partners
ORGANIZATIONBurlington Coat Factory Sec
ORGANIZATIONSee Nairobi Holdings Ltd.
ORGANIZATIONBurlington Coat Factory
PERSONDan Andriano
PERSONBetty Anne Smith
PERSONLowth, Wilson
PERSONJohn Lowth &
ORGANIZATIONAndriano & Greco
ORGANIZATION