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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
York Attorney General to investigate and prosecute violations of the Act. The Martin Act does not, however, provide for a private cause of action. See Nairobi Holdings Ltd. v. Brown Bros. Harriman & Co., Civ. No. 2002-1230, 2002 U.S. Dist. LEXIS 16995 at *10 (S.D.N.Y. Sept. 10, 2002) ("(Ilt is well established that the
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
w York Attorney General to investigate and prosecute violations of the Act. The Martin Act does not, however, provide for a private cause of action. See Nairobi Holdings Ltd. v. Brown Bros. Harriman & Co., Civ. No.2002-1230, 2002 WL 31027550, '4, 2002 U.S. Dist. LEXIS 16995 at *10 (S.D.N.Y. Sept. 10, 2002) Cult is well es
[the "Mass Mutual Fund"]. On June 15, 2000, Epstein borrowed an additional $10 million from Citibank, that Epstein agreed to invest in the Mass Mutual Fund. (Mem. Of Law in Support of Defs.' Mot. To D
w York Attorney General to investigate and prosecute violations of the Act. The Martin Act does not, however, provide for a private cause of action. See Nairobi Holdings Ltd. v. Brown Bros. Harriman & Co., Civ. No.2002-1230, 2002 WL 31027550, '4, 2002 U.S. Dist. LEXIS 16995 at 10 (S.D.N.Y. Sept. 10, 2002) ("(in is well es
Entities connected to both Jeffrey Epstein and See Nairobi Holdings Ltd.

Julie K. Brown
PERSONthe Southern District
LOCATION
New York
LOCATION
the United States District Court
ORGANIZATIONDeutsch
PERSONDavison
PERSONthe AIG Investment
ORGANIZATIONRockefeller Ctr
ORGANIZATIONMass Mutual
ORGANIZATIONGranite Partners
ORGANIZATIONThe Martin Act
PERSONthe Mass Mutual Fund
ORGANIZATIONBrown Bros. Harriman & Co.
ORGANIZATIONBear, Steams
ORGANIZATIONCPC Intl, Inc.
ORGANIZATIONMcKesson Corp
ORGANIZATION