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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
plaintiffs have stated claims cognizable in this jurisdiction. 2. New York's 'Martin Act Does Not Apply to this Lawsuit The defendants aver that the Martin Act, New York General Business section 352 et seq., bars the plaintiffs' claims for negligent misrepresentation (Count IV) and breach of fiduciary dut
-3- EFTA00314492 legal basis to hold Bear Stearns responsible for these losses — much less to hold Mr. Spector personally responsible. FACTS A. Jeffrey Epstein's Long History with Bear Stearns. According to the Amended Statement of Claim (cited herein as "Am. St. Claim"), Jeffrey Epstein joined Bear Steams a
rust Company, Inc. ("FTC") and The C.O.U.Q. Foundation, Inc. ("COUQ") (collectively, "Claimants"), are retail investors managed by Jeffrey Epstein. Epstein, a very wealthy individual and a former partner at Bear, Steams & Co., Inc. ("Bear Steams"), is a long-standing customer of Bear Steams and a sophis
y, "Claimants"), are retail investors managed by Jeffrey Epstein. Epstein, a very wealthy individual and a
hree of Epstein's claims — those for breach of fiduciary duty, constructive fraud, and negligent misrepresentation — are barred in their entirety by the Martin Act, N.Y. Gen Bus. Law §§ 352(a)-(c) (McKinney 2007), which "prohibits various fraudulent and deceitful practices in the distribution, exchange, sale 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
the plaintiffs have stated claims cognizable in this jurisdiction. 2. NEW YORK'S MARTIN ACT DOES NOT APPLY TO THIS LAWSUIT The defendants aver that the Martin Act, New York General Business section 352 et seq., bars the plaintiffs' claims for negligent misrepresentation (Count IV) and breach of fiduciary duty
Entities connected to both Jeffrey Epstein and the Martin Act

Prince Charles
PERSON
U.S. Virgin Islands
LOCATION
Michael Jackson
PERSON
Financial Trust Company
ORGANIZATION
the United States District Court
ORGANIZATIONthe State of New York
LOCATION
Rhodes
PERSONScheuer
PERSONRockefeller Ctr
ORGANIZATIONCharles Schwab & Co. Sec
ORGANIZATIONShutte v. Armco Steel Corp.
ORGANIZATIONJumara
LOCATION