Epstein Secrets

04/24/2007 BUSINESS INFORMATION Company Names J EPSTEIN FOUNDATION Address: 457 MADISON AVE NEW YORK,

25 Memorandum in opposition to plaintiffs motion for judgment on the pleadings as to count one - breach of contract, Certificate of service filed by JEFFREY E. EPSTEIN. (ph, ) Additional attachment(s) added on 9/4/2003 (ph, ). (Entered: 08/28/2003) 08/28/2003 26 Reply to EPSTEIN'S memorandum in opposition to plai

FREY A. SLOMOWITZ I. EPSTEIN, et al 33 EPSTEIN, JEFFREY E. Kelleher'. ADVO, Inc et al 34 EPSTEIN, JEFFREY

EFFREY LYDIA CAVAZOS PLASENCIA 3 EPSTEIN, JEFFREY YVONNE ROBLES CATHERINE 4 EPSTEIN, JEFFREY FRANCIS OLUSEGUN TIFASE 5 EPSTEIN, JEFFREY JAYSON LEE EPSTEIN 6 EPSTEIN, JEFFREY ERIC THOMAS 7 EPSTEIN, JEFFREY DONALD J REED AND SALLY A 8 EPSTEIN, JEFFREY ROSEMARY ELFIEDE BODEY PEREZ 9 EPSTEIN, JEFFREY

STEIN 22 EPSTEIN, JEFFREY CHARLES EDWARD NELSON 23 EPSTEIN, JEFFREY D JEFFREY D EPSTEIN 24 EPSTEIN, JEFFREY H. G. WARE TRAVELSTEAD 25 EPSTEIN, JEFFREY M. mdbkc 93-00207 05/05/1993 KAYE SCHOLER FIERMAN HAYS & HANDLER AND HAINLINE 26 EPSTEIN, JEFFREY R. pacbkc 03-34969 10/09/2003 JEFFREY R. EPSTEIN

EPSTEIN, JEFFREY E. Kelleher'. ADVO, Inc et al 34 EPSTEIN, JEFFREY E. DVO Inc et al 35 EPSTEIN, JEFFREY E. Golden I. Harding et al 36 EPSTEIN, JEFFREY-E. Field'. Advo Inc et al cacbkc 03-23966 cacbke 03-23968 flsbke 01-30953 flsbke 91-33375 mnbke 06-40989 cacbkc 02-45716 ilnbke 03-51468 mdbke

307 05/22/1998 230 03/17/1999 SA Epstein, et al 43 EPSTE ,JEFFREY K. nyedce 04/26/2004 08/10/2005 .1:2004mc00106 Epstein, Esq. 44 EPSTEIN, JEFFREY KENT nyedce 1:2004mc00106 04/26/2004 . 08/10/2005 Epstein, Esq. 45 EPSTEIN, JEFFREY ilndce 1;1991cv01926 01/09/1992 190 01/30/1992 Van Schouwen I

pieze 4 fitel ttotlittli Case No. 08-80736-CV-MARRA 4mq ORMli UW040)0704 EFTA00228084 relevant times, a principal and an offiper.of Defendant, J. Epstein and Company, :Inc, (collectively `Epstein"), which, at all relevant times, had its. principal piece of business at The villard House, 457 MadisOn A

tender of which was accepted by Epstein and/or the Wexners at Shanks' studio in Andalusia, Bucks County, Pennsylvania. 37. The subsequent attempts:Sy Epstein and/or the Wexners to reject the painting were based%on purely subjective grounds. 38. Subjective approval of the painting by the Wexner°, Maxwell

INDEX PURCHASE DATE: 08/29/1995; RJI PURCHASE FEE: YES; RJI PURCHASE DATE: 08/29/1995 PARTICIPANT INFORMATION J EPSTEIN i COMPANY INC PLAINTIFF EPSTEIN JEFFREY PLAINTIFF Names 457 MADISON AVENUE CORP 2007 Thomson/West. No Claim to Orig. U.S. Govt. Works. 7.00102 1 7 haps://web2.westlaw.com/print/princi

o Dade County, et al 30 EPSTEIN, JEFFREY codce Pierce Segerberg PC, et all. Epstein 31 EPSTEIN, JEFFREY Pierce Segerberg PC, et all. Epstein 32 EPSTEM, JEFFREY A. SLOMOWITZ I. EPSTEIN, et al 33 EPSTEIN, JEFFREY E. Kelleher'. ADVO, Inc et al 34 EPSTEIN, JEFFREY E. DVO Inc et al 35 EPSTEIN, JEFF

10/02/2002 195 10/21/2003 S WEXNER et al 40 EPSTEIN, JEFF nysdce 1:199.fici08307 05/22/1998 230 03/17/1999 USA Epstein, et al 41 EPSTEIN, JEFFRE nysdce 11996cv08307 05/22/1998 230 03/17/1999 USA Epstein, et al 42 EPSTEIN, JEFFREY nysdce 11996cv08307 05/22/1998 230 03/17/1999 SA Epst

d that would accompany 'the first paragraph of any newspaper story' - that is the 'who, what, when, where and how' of the events at issue.'" In re Rockefeller Ctr. Props., Inc., 311 F.3d at 217 (quoting In re Burlington, 114 F.3d at 1422). However, the Third Circuit Court of Appeals has held that the "require

econd amended complaint (the "Fisher counterclaim"), is granted in all respects. The Soffer ejectment motion is granted as against deft Ron Soffer. Defls Jeffrey E. Epstein, Ivan S. Fisher, Ellyn Bank, Debra Elisa Cohen, Dianeataga?/a The Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, D. Gerzog, Robert Heilbum,

the house to the tenant we have selected should Mr. Epstein decide not to reoccupy the premises under the ne

on of the budding pursuant to the Foreign Missions Act, 22 U.S.C. § 4301 of seq. 0FM leased the building to defen- dant Jeffrey E. Epstein in 1992. Epstein sublet the building to defendant Ivan S. Fish- er in 1996, purportedly without the Govern- ment's consent. Fisher, in turn, sublet a portion of the

n personally liable because Epstein did not sign the con- tract as an agent or as a corporate officer. Epstein signed the contract as follows: /s/ Jeffery Epstein 1AG. Under New York law, a signature in a representative capacity would have been "Jeffrey Epstein for I.A.G." or "I.A.G., by Jeffrey Epstein". 2

atters extrinsic to the complaint. we will treat defendant Epstein's motion to dismiss as a motion for summary judg

RDERED. UNITED STATES of America, Plaintiff, I Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elis

RDERED. UNITED STATES of America, Plaintiff, I Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elise

e 12(b)(6) motion, I ac- cept all allegations in the complaint as true, and draw all reasonable inferences in favor of the non-moving party. In re Rockefeller Ctr. Props., Int, 311 F.3d 198, 215 (3d Cir.2002). "The inquiry is not whether plaintiffs will ultimately prevail in a trial on the merits, but whethe

6100 RED HOOK QTRS ST THOMAS, VI 00802-1348 4. J EPSTEIN & CO INC ST THOMAS. VI 5. MOF VI LIMITED PARTN

ND INDUSTRY SIC CODES: 6282 - Investment advisory service LOAD-DATE: May 18, 2013 LEGAL RESULTS: Court Cases: FINANCIAL TRUST COMPANY, INC. AND JEFFREY E. EPSTEIN, Plaintiffs, v. CITIBANK, N.A. AND CITIGROUP, INC. d/b/a "CITIGROUP," Defendants. Civ. No. 2002-108 UNITED STATES DISTRICT COURT FOR THE DISTRICT

Debtor 2 Name: FINANCIAL TRUST COMPANY. INC. C/O J. EPSTEIN & COMPANY, INC Address: 457 MADISON AVE NEW YORK

Court Cases: FINANCIAL TRUST COMPANY, INC. AND JEFFREY E. EPSTEIN, Plaintiffs, v. CITIBANK, N.A. AND CITI

Court Cases: FINANCIAL TRUST COMPANY, INC. AND JEFFREY E. EPSTEIN, Plaintiffs, v. CITIBANK, N.A. AND CITIG

by the person to whom it was made; (4) the intention that it should be acted upon; and (5) that the plaintiff acted upon it to his damages." in re Rockefeller Ctr. Props. Secs. Litig., 311 F.3d 198, 215 (3d Cir. 2002). Courts should apply Rule 9(b) with some flexibility and should not require plaintiffs to pl

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

an increased measure of protection for their reputations, and reduce[] the number of frivolous suits brought solely to extract settlements." In re Rockefeller Ctr. Props., Inc., 311 F.3d at 215 (quoting In re Burlington Coat Factory Sec. Litig., 114 F.3d at 1418). "Rule 9(b) requires a plaintiff to plead (1)

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

that would accompany 'the first paragraph of any newspaper story—that is, the 'who, what, when, where and how' of the events at issue." In re Rockefeller Ctr. Props.. Inc.. 311 F.3d at 217 (quoting In re Burlington, 114 F.3d at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted

main purpose is to protect AIG's interests in its dealing with Epstein and FTC. The agreement discusses at length the process by which AIG, through its agent, Citibank, will deliver income notes to Epstein, the purchase

an increased measure of protection for their reputations, and reduce( ] the number of frivolous suits brought solely to extract settlements? In re Rockefeller Ctr. Props.. inc.. 311 F.3d at 215 (quoting In re Burlington Coat Factory Sec. Litig., 114 F.3d at 1418). "Rule 9(b) requires a plaintiff to plead (1) a

. Co.. 55 F.3d 873, 879-80 (3d Cir.1995). Considering the totality of the circumstances surrounding this case, I make the following findings. First, Epstein and Financial Trust have selected this forum, and they are residents of the Virgin Islands with strong ties to this community. Epstein owns a seven

Rule 12(b)(6) motion, I accept all allegations in the complaint as true, and draw all reasonable inferences in favor of the non-moving party. In re Rockefeller Ctr. Props., Inc., 311 F.3d 198, 215 (3d Cir.2002). "The inquiry is not whether plaintiffs will ultimately prevail in a trial on the merits, but whether

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

round that would accompany 'the first paragraph of any newspaper story—that is, the 'who, what, when, where and how' of the events at issue." In re Rockefeller Ctr. Props.. Inc.. 311 F.3d at 217 (quoting In re Burlington, 114 F.3d at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted