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Davison"], Vice President of Citibank in New York and Epstein's private banker, and other Citibank employees telephoned Epstein while he was in the Virgin Islands and recommended that the plaintiffs invest through EFTA01726510 Financial Trust Co., Inc. v. Citibank, N.A. Civ. No. 2002-108 Memorandum Opinion
tiffs counter that the defendants are currently doing business in the Virgin Islands and that this Court has jurisdiction over the defendants under the Virgin Islands' Long- Arm Statute. The plaintiffs insist that the defendants' depiction of Citigroup as a "holding company" is belied by Citigroup's public disclos
r explicitly relied upon in the complaint . . . without converting the motion to dismiss into one for summary judgment." U.S. Express Lines Ltd. v. Higgins, 281 F.3d 383, 388 (3d Cir. 2002) (emphasis added) (quoting In re Burlington Coat Factory Litig., 114 F.3d 1410, 1426 (3d Cir. 1997)). Because the
the defendants' actions caused the plaintiffs' losses under New York law. (Mem. Of Law in Supp. of Defs' Mot. to Dismiss at 40-44.) >As noted above, Virgin Islands law governs these claims. The plaintiffs maintain that they have adequately stated causation by alleging that the defendants did not disclose their
o or explicitly relied upon in the complaint ... without converting the motion to dismiss into one for summary judgment." U.S. Express Lines Ltd. v. Higgins, 281 F.3d 383, 388 (3d Cir.2002) (emphasis added) (quoting In re Burlington Coat Factory Litig.. 114 F.3d 1410, 1426 (3d Cir. 1997)). Because the pa
W Gratitude America, Ltd. 12/6/2017 $50,000 W Gratitude America, Ltd. Cecile de Jongh 12/29/2015 De Jongh is the former First Lady of the U.S. Virgin Islands. There have been public reports that she worked as an "Office Manager" for Epstein's companies during her husband's tenure as Governor. John de Jon
348 Jla. Christopher Higgins Higgins is likely a private pilot used by Epstein. A Linkedln account belonging to "Christopher Higgins" identifies Higgins as a Chief Pilot and 727 First Officer. Jeffrey Epstein's private jet, the so-called Lolita Express, is reportedly a Boeing 727. 8 $17,010 TBD
Entities connected to both U.S. Virgin Islands and Higgins

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Richard Kahn
PERSON
New York
LOCATION
Financial Trust Company
ORGANIZATION
George W. Bush
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Bill Clinton
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Virginia Giuffre
PERSONthe Southern District
LOCATION
Palm Beach
LOCATION
Marc Rich
PERSON
Bradley Edwards
PERSON
Sarah Ferguson
PERSON