The filed complaint alleges that Apollo Global management, Inc. made materially false and/or misleading statements and/or failed to disclose that: (1) defendants, among other leadership figures at Apollo Global, frequently communicated with Jeffrey Epstein in the 2010s regarding Apollo Global’s business; (2) as a result, Apollo Global’s assertion that the Company had never done business with Jeffrey Epstein was untrue; (3) because of the entanglement between Apollo Global’s leaders and Jeffrey Epstein, the harm to Apollo Global’s reputation was more than a mere possibility; and (4) as a result, defendants’ statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all times.