Epstein Secrets

vents of which he has been warned. Kline v. First W. Gov't Sec., 24 F.3d 480, 489 (3d Cir. 1994). The

follow-up telephone conversations during that same two week period, Davison and her associates r 5] made additional specific representations about the AIG Investment, without disclosing Citibank and AIG's relationship. Davison also during that period represented that Citibank had "done their due diligence" and w

By: /s/ Deputy Clerk Copies to: Hon. Geoffrey W. Barnard Gregory H. Hodges, Esq. Maria Tankenson

he Amended 1999 Note. (Id. Ex. A at 8-9; Ex. B at 7-8; Ex. D at 10; Ex. E at 2-3.) Sometime in the spring of 2001, Epstein and FTC discovered that the AIG Investment was "suddenly and rapidly deteriorating." (Pls.' Mem. Of Law in Opp'n to Mot. To Dismiss, Epstein Decl. 1 20.) According to the plaintiffs, FTC's a

nged by Abigail Wexner's personal assistant, Karl W. Koon. : . 13. Following 'the March 15, '2002

) In follow-up telephone conversations during that same two week period, Davison and her associates made additional specific representations about the AIG Investment, without disclosing Citibank and AIG's relationship. Davison also during that period represented that Citibank had "done their due diligence" and