Epstein Secrets

d until 2002, just months before the commencement of this litigation. On Jan- uary 31, 2002, Citibank closed its last re- maining bank branch in the U.S. Virgin Islands, and Citibank no longer makes real estate-related loans in the Virgin Islands. (Malin Aff. 11 3-4.) Citibank, however, continues to process its ou

ing the depositions for a date and time that is suitable for both the Defendants and Plaintiff, and relocating the depositions from Philadelphia to the U.S. Virgin Islands for Mr. Epstein and Ms. Maxwell; and New Albany, Ohio for the Wexners. Accordingly, this Court should grant Defendants' motion for a protective ord

fs counter that the defendants are currently doing busi- ness in the Virgin Islands and that this Court has jurisdiction over the defendants under the Virgin Islands' Long—Arm Stat- ute. The plaintiffs insist that the defen- dants' depiction of Citigroup as a "holding company" is belied by Citigroup's public disclosur

e that this Court has jurisdiction under the Virgin Islands Long-Arm Statute over both the defendants. 2. The Defendants' "Minimum Con- tacts" in the Virgin Islands Meet the Constitution's Due Process Re- quirements In addition to finding jurisdiction under this forum's long-arm statute, I must also determine whet

e 12(b)(6) motion, I ac- cept all allegations in the complaint as true, and draw all reasonable inferences in favor of the non-moving party. In re Rockefeller Ctr. Props., Int, 311 F.3d 198, 215 (3d Cir.2002). "The inquiry is not whether plaintiffs will ultimately prevail in a trial on the merits, but whethe

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

an increased measure of protection for their reputations, and reduce[] the number of frivolous suits brought solely to extract settlements." In re Rockefeller Ctr. Props., Inc., 311 F.3d at 215 (quoting In re Burlington Coat Factory Sec. Litig., 114 F.3d at 1418). "Rule 9(b) requires a plaintiff to plead (1)

lists the same office address. Rackliffe said via e-mail, "He no longer has a company registered in Florida, however, maintains an office for his Virgin Island business, Financial Trust Co. Inc. at 250 South Australian Ave, West Palm Beach. We have a copy of the business license registered in the U.S. Virg

by the person to whom it was made; (4) the intention that it should be acted upon; and (5) that the plaintiff acted upon it to his damages." in re Rockefeller Ctr. Props. Secs. Litig., 311 F.3d 198, 215 (3d Cir. 2002). Courts should apply Rule 9(b) with some flexibility and should not require plaintiffs to pl

in advising the plaintiffs about the AIG-managed fund. Accordingly, I find that New York law does not govern these claims, and instead shall look to Virgin Islands law to determine whether the plaintiffs have stated claims cognizable in this jurisdiction. 2. NEW YORK'S MARTIN ACT DOES NOT APPLY TO THIS LAWSUIT

Rule 12(b)(6) motion, I accept all allegations in the complaint as true, and draw all reasonable inferences in favor of the non-moving party. In re Rockefeller Ctr. Props., Inc., 311 F.3d 198, 215 (3d Cir.2002). "The inquiry is not whether plaintiffs will ultimately prevail in a trial on the merits, but whether