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

rder, the proceedings should be stayed pending the adjudication of the first-filed action. (sac) (Entered: 10/16/2002) 10/09/2002 13 AFFIDAVIT of Dayle Davison by Citibank, N.A. in opposition to [7-1] motion for an order, pun. to Rules 1, 12 and 13(a) of the FRCP, dismissing the Complaint, [7-2] motion for

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

(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

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

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