Epstein Secrets

en on the liberal standard of Rule 12(b)(6)." De Jesus v. Sears, Roebuck & Co., 87 F.3d 65, 70 (2d Cir

i- rected activities where defendant delivered products into stream of commerce with ex- pectation they would be purchased by resi- dents of forum); Calder, 465 U.S. at 789- 90, 104 S.Ct. 1482 (fording publishing ac- tivities outside of forum were calculated to cause injury to plaintiff in forum where

m, and the litigation results from al- leged injuries that arise out of or related to those activities"). Pursuant to the hold- ings in Thayer King, Calder, and three recent terrorism cases—Rein v. Socialist People's Libyan Arab Jamahiriya, 995 F.Supp. 325 (E.D.N.Y.1998), Daliberti v. Republic of Ira

at three. GAVIN (O.S.) Did you forget the interview? ROBERT What interview? GAVIN (O.S.) CNBC. You're doing Bartiromo in an hour. ROBERT Oh, Jesus... Why are we doing that? EFTA00724934 20. GAVIN (O.S.) To create speculation?... (no response) It was your idea, remember?... Robert just di

t an employee. ROBERT Not an employee. I was an investor. GOWER What made you invest? ROBERT She had a great eye. She found me (points) those Calder prints, the ones on the wall there. They appreciated quickly, and on the strength of that I agreed to fund some of the gallery. GOWER (after a b

at three. GAVIN (O.S.) Did you forget the interview? ROBERT What interview? GAVIN (O.S.) CNBC. You're doing Bartiromo in an hour. ROBERT Oh, Jesus... Why are we doing that? EFTA_R1_02008820 EFTA02685383 20. GAVIN (O.S.) To create speculation?... (no response) It was your idea, remember?.

t an employee. ROBERT Not an employee. I was an investor. GOWER What made you invest? ROBERT She had a great eye. She found me (points) those Calder prints, the ones on the wall there. They appreciated quickly, and on the strength of that I agreed to fund some of the gallery. GOWER (after a b

ven on the liberal standard of Rule 12(b)(6).” De Jesus v. Sears, Roebuck & Co. 87 F.3d 65, 70 (2d Cir.19

minimum contacts existed since dispute arose from a contract with substantial con- tacts with the forum) (internal quotations and citations omitted); Calder v. Jones, 465 U.S. 783, 789, 104 S.Ct. 1482, 79 L.Ed.2d 804 (1984) (finding personal juris- diction appropriate over non-resident de- fendants who “e

tates. Accordingly, Plaintiffs may rely on their “purposefully directed” theory to establish these mini- mum contacts. But as existed in Burger King, Calder, and the three terrorism cases, Plaintiffs must allege some personal or direct involvement by the Defendants in the conduct giving rise to their clai