Epstein Secrets

d upon it to his damage. COUNSEL: ri] ATTORNEYS: Maria Tankenson Hodge, Esq., Hodge & Francois, St. Tho

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

m EFTA00187401 Page I of 2 VVestiaw. Page 1 Maria Tankenson Hodge Current Firm Information Unknown

F.34 at 1422). In Count I, plaintiffs allege that the defendants' conduct "constituted the mak- ing of fraudulent misrepresentations ... regarding the AIG Investment" that the defendants knew were materially mislead- ing "because of their failure to state or disclose the additional or qualifying infor- mation re

NC. d/b/a "CITIGROUP," Defendants. ATTORNEYS: Maria Tankenson Hodge, Esq. Hodge & Francois St. Thom

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

P," INC. ) ) ) Defendants. ) ) ATTORNEYS: Maria Tankenson Hodge, Esq. Hodge & Francois St. Thom

) 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