MEMORANDUM OPINION
KAPLAN, District Judge.
In the late 1990s, Citibank, N.A. ("Citibank") agreed to make defendant Opportunity Equity Partners, Ltd. ("Opportunity"), an entity controlled by Daniel Valente Dantas, a Brazilian banker, the sole general partner of an investment vehicle, Citigroup Venture Capital International L.P. (the "CVC Fund" or the "Fund"), to which Citibank contributed the entire $728 million in capital. The CVC Fund now owns, through...
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