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dorsement on letter to Judge Chin from Ellen Yaroshefsky dated 10/8/98; counsel for Den Cohen requests that the Court permit the adjournment of Ms. Cohen's deposition beyond the current discovery cutoff date. I have reviewed this letter; the Govt's letter of today; and Ms. Yarostefsky's 2d letter of
r the plain- tiffs to amend their pleadings. I. FACTUAL AND PROCEDURAL BACKGROUND In their amended complaint, Jeffrey E. Epstein ("Epsteinn and Financial Trust Company, Inc. ("Fr) (collectively "plain- tiffs") allege that Citibank, N.A. ("Citi- bank") and Citigroup, Inc. ("Citigroup"I [collectively "defendants"] misrepre
itch book" referenced in the amended complaint is the document that plaintiffs rely on is a disputed fact that precludes a Rule 12(bX6) dismissal. Financial Trust Co., 268 F.Supp.2d at 572. Nothing in any of the briefs have convinced me that the parties do not dispute which pitch book Epstein received, what disc
ed to meet Federal Rule of Civil Proce- dure 9(b)'s heightened pleading standard. I did, however, grant the plaintiffs leave to amend the complaint Financial Trust Co.' Citibank, 268 F.Supp.2d 661 (D.Vir- gin Islands 2003). H. LEGAL ANALYSIS A. Federal Rule of Civil Procedure 9(b) (1-31 In order to state a viable
New York, NY 10007 Robert A. Skirnick MEREDITH COHEN GREENFOGEL & SKIRNICK PC One Liberty Plaza 35t
ATTORNEYS-AT-LAW JOHN K. DEMA ADMITTED USVI-CA 8 January 2010 Vla Cat(/!d mall- Return Recdpt and E-ntall Darren K. Indyke, Esquire President, Financial Trust Company, Inc. 6100 Red Hook Quarter, Suite B-3 St. Thomas, U.S. Virgin Islands 00802 301 East 66ih Street New York, New York 10065 RE: Financial Trust Compan
dicial Panel on Multidistrict Litigation on January 7, 2010 with respect to the procedures to be followed as a result of the conditional transfer of Financial Trust to the MDL in New York: 1. Conditional Transfer Order (CTO-3), dated January 7, 2010, transferring the Financial Trust case to the MDL in the South
of fiduciary duty, courts have applied a six year statute of limitations, running from the date of the alleged injury. See CPLR 213(8); Kaufman v. Cohen, 307 A.D.2d 113, 119 (1st Dep't 2003) (noting six year statute applicable to breach of fiduciary duty claim premised on underlying claim that partne
investments in the D.B. Zwim Special Opportunities Fund (the "Fund") in light of the Settlement Agreement and Release entered into between Jeepers, Financial Trust Company, Inc., and you on the one hand, and the Fund, on the other (the "Settlement Agreement"). Section One of this memorandum addresses the Settlement Agreemen
ination Provisions As you are aware, the terms of the Settlement Agreement release the Fund and certain other parties from any claims that Jeepers, Financial Trust, or you might have in connection with your investments in the Fund in exchange for the right to withdraw the principal amounts of two of Jeepers's
ael Gyure is a bad person," declared lawyer Irwin Cohen, asserting that on three occasions Gyure chisele
. Epstein reportedly made all the investment calls. Since the 1990s, the company has been incorporated in the U.S. Virgin Islands and is now called Financial Trust Co. A person answering the phone at the Saint Thomas-based company hung up after a request for comment was made. The main client was Wexner, the founde
up that he ran out of his apartment, according to Vanity Fair. Later he set up a money management firm called J. Epstein & Co. It eventually became the Financial Trust Company, based in the Virgin Islands. EFTA00076644 But there was an expensive footnote about him and Bear Stearns. When two big Bear Stearns hedge funds
ael Gyure is a bad person," declared lawyer Irwin Cohen, asserting that on three occasions Gyure chisele
. Epstein reportedly made all the investment calls. Since the 1990s, the company has been incorporated in the U.S. Virgin Islands and is now called Financial Trust Co. A person answering the phone at the Saint Thomas-based company hung up after a request for comment was made. The main client was Wexner, the founde
up that he ran out of his apartment, according to Vanity Fair. Later he set up a money management firm called J. Epstein & Co. It eventually became the Financial Trust Company, based in the Virgin Islands. But there was an expensive footnote about him and Bear Stearns. When two big Bear Stearns hedge funds collapsed in 20
ial, et al Sheridan, et al v. Hoffenberg, et al Cohen, et al v. Hoffenberg, et al Cohen, et al v. Hoff
and Bondholders of Towers Financial Corporation, Plaintiff, v. Jeffrey E. Epstein, individually, and as President and Chief Executive Officer of The Financial Trust Company, The Financial Trust Company, XYZ Corp. and ABC, Inc. Defendant. X Index No. RELATED ACTIONS: Case No. 94 CR 213 (RWS) Case No. 95 CR 213 (RW
nberg, et al filed 02/08/94 Amer. Inel. lanes, ct al v. Toners Fulani:said al filed 04/14/94 Sheridan. et al v. Hoffenberg, ct al filed 12/29/94 Cohen. et al v. Hoffenberg, et al filed 06r21/96 Cohen. et al v. Hoffenberg, et al filed 07/08/96 Shawmut Bank v. Towers Financial, et al filed 02/25/
used the monies he misappropriated and earned from his illegal trading activities and used them as start-up capital for his corporations, including The Financial Trust Company. 19. Epstein conceived many ways we could cover up our dubious activities. Some of the actions we took included routing all securities trades conf
EPSTEIN, Ivan S. Fishes. Ellyn Bank, Debra Elise Cohen. Diann Father .. when the United Suites severed
erg httpsiNnywhbomberg.comiresoarchistockeipeopletpersonkisp?porsonid. . • Jeffrey E. Epstein serves ea the Chairman and Chief Exeotarre Officer of the Financial Trust Company. Mr Esenset craned hr. career at Sear Stearns wilh an . Donald Trump denies woman's claims that she was raped by the ... anwederlymed co okr..iDon
rt; Gerzog, Lawrence D; Fisher, Ivan; Fisher, Diane DBA the Fisher Group; Fisher & Soffer AKA Fisher & Sophir; Epstein, Jeffrey E; Ellyn Bank; Cohen, Debra Elisa COUNTER-CLAIMANT: Fisher, Ivan COUNTER-DEFENDANT: United States of America CROSS-CLAIMANT: Fisher, Ivan; Epstein, Jeffrey E CROSS-D
NITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK (Foley Square - NYC) Citibank, NA v. Epstein, et al PLAINTIFF: Citibank, NA DEFENDANT: Financial Trust Company, Inc; Epstein, Jeffrey E DOCKET CASE NUMBER: 1:02cv5332 FILING DATE: 7/11/2002 JURISDICTION: Diversity JUDGE: Stein, Sidney H NATURE OF SUIT: 190 Ot
Entities connected to both Michael Cohen and Financial Trust Company

Jeffrey Epstein
PERSON
Barry Diller
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONLeon Black
PERSONDarren Indyke
PERSON
Donald Trump
PERSON
JPMorgan Chase
ORGANIZATION
Marc Rich
PERSON
United States
LOCATION
George W. Bush
PERSON
Department of Justice
ORGANIZATION
Denver
LOCATION
Richard Kahn
PERSON
U.S. Virgin Islands
LOCATION
Joe Biden
PERSON
Alan Dershowitz
PERSONSouthern District
LOCATION
Bear Stearns
ORGANIZATION
Colorado
LOCATION