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tly, but later informed them that she was having difficulty obtaining the information from SSB, and recommended that they seek the information from Chase Manhattan, the Trustee of the fund. (Pls.' Mem. Of Law in Opp'n to Mot. To Dismiss, Schantz Decl. ff 6-8. ) Chase Manhattan, however, referred the plaintiff
er-borrower relationships, there is a presumption that the parties operate at arms-length and in their own interest. Jo-Ann's Launder Ctr., Inc. v. Chase Manhattan Bank, N.A., 854 F. Supp. 387, 392 (D.V.I. 1994). A fiduciary relationship may arise, however, depending upon the particular circumstances of the financi
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 the Virgin
borrowed an additional $10 million from Citi- bank, that Epstein agreed to invest in the Mass Mutual Fund. (Mem. Of Law in Support 565 mation from Chase Manhattan, the Trust- ee of the fund. (Pls.' Mem. Of Law in Opp'n to Mot. To Dismiss, Schantz Decl. 116-8. ) Chase Manhattan, however, re- ferred the plainti
naged by MG. (Compl. 1112, 24; Epstein Decl. 118-10; Davison Aft 11 1, 102-18.) According to the plaintiffs, during the negotiations of this deal Davison represented to Epstein that he was "virtually assured of receiving an 18-20% return on [his] investment, with a possible return of as much as 80%"
ptly, but later informed them that she was having difficulty obtaining the information from SSB. and recommended that they seek the information from Chase Manhattan. the Trustee of the fund. (Pls' Mem. Of Law in Opp'n to Mot, To Dismiss, Schantz Dec11[1 6-8. ) Chase Manhattan, however, referred the plaintiffs b
d rapidly deteriorating." (Pls.' Mem. Of Law in Opp'n to Mot. To Dismiss, Epstein Decl.1120.) According to the plaintiffs, FTC's advisors contacted Davison and other employees of Citibank. and requested Citibank's help in coordinating the replacement of the AIG fund's manager. (Id. 121; Schantz Declif 5
ptly, but later informed them that she was having difficulty obtaining the information from SSB, and recommended that they seek the information from Chase Manhattan, the Trustee of the fund. (Pls' Mem. Of Law in Opp'n to Mot. To Dismiss, Schantz Decl. ¶¶ 6-8. ) Chase Manhattan, however, referred the plaintiffs
According to the plaintiffs, during the negotiations of this deal Davison represented to Epstein that he was "virtually assured of receiving an 18-20% return on [hisj investment, with a possible return of as much as 30%" a
Entities connected to both JPMorgan Chase and Davison

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONDarren Indyke
PERSON
NEW YORK NY
LOCATIONMaria Farmer
PERSON
Marc Rich
PERSON
Richard Kahn
PERSON
Financial Trust Company
ORGANIZATION
Justin Trudeau
PERSON
Eric Trump
PERSONthe State of New York
LOCATIONBarrett
PERSON
George W. Bush
PERSON
Stanton
PERSON
Puerto Rico
LOCATION
John Brennan
PERSON
Lawrence Krauss
PERSON
United States
LOCATION
Alan Dershowitz
PERSONLeon Black
PERSON