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sd-10-EFTA01386065Dept. of Justice

EFTA Document EFTA01386065

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[the "Mass Mutual Fund"]. On June 15, 2000, Epstein borrowed an additional $10 million from Citibank, that Epstein agreed to invest in the Mass Mutual Fund. (Mem. Of Law in Support of Defs.' Mot. To Dismiss, Ex. D.) Although the plaintiffs have stated an intent to seek to amend the complaint to include claims related to the Mass Mutual Fund, they have not yet done so. (See Pls.' Mem. Of Law in Opp'n to Mot. To Dismiss at 12 n. 12.) 2. The Martin Act is New York's blue sky law. General Busine

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Dept. of Justice
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sd-10-EFTA01386065
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