EFTA Document EFTA01386058

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%" and assured him that Citibank was going to remain actively involved in the investment. (Epstein Decl. 1111.) After further discussion between Epstein and Davison. Citibank offered to loan Epstein 510 million on the express condition that the money be used exclusively to fund