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

that defendants were acting in plaintiffs' best interests. For example, it is alleged that in conversations between April 29, 1999 and May 2, 1999, Dayle Davison, a Vice President of Citibank in the Private Banking Division, called Epstein to introduce him to an "exceptional investment opportunity." (Compl. P

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

(Count V). The plaintiffs seek rescission of the promissory note and punitive damages (Counts VI and VII). (Am. Compl. III 45-68.) In April 1999, Dayle Davison ["Davison"], Vice President of Citibank in New York and Epstein's private banker, and other Citibank employees telephoned Epstein while he was in t

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

that defendants were acting in plaintiffs' best interests. For example, it is alleged that in conversations between April 29, 1999 and May 2, 1999, Dayle Davison, a Vice President of Citibank in the Private Banking Division, called Epstein to introduce him to an "exceptional investment opportunity." (Compl.