10
Shared Docs
10
Same-Page
10 / 10
Mentions
for which he cannot realistically or genuinely be expected to be charged with a crime are not subject to Fifth Amendment protection. See Krause v. Rhodes, 390 F.Supp. 1070, 1071-72 (N.D. Ohio 1974). In summary, Epstein has failed to sustain his burden of making a particularized showing to support his
ida, has MI intent to stay in Palm Beach County after his incarceration and is otherwise suijuris. 4. Defendant, Mil is a citizen and resident of the State of New York and otherwise sui juris. EFTA00723266 5. This is an action for damages in excess of Fifteen Thousand Dollars (815,000), exclusive of interest a
.2d 338 (1989) (" Rule 12(b)(6) does not countenance ... dismissals based on a judge's disbelief of a complaint's factual allegations"); Scheuer v. Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it appears "that a recovery is very remote an
use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of 550 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
d.2d 338 (1989) (" Rule 12(b)(6) does not countenance ... dismissals Ivsed on a judge's disbelief of a complaint's factual allegations"); Scheueri. Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it appears "that a recovery is very remote an
use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
d.2d 338 (1989) (" Rule 12(b)(6) does not countenance ... dismissals ivsed on a judge's disbelief of a complaint's factual allegations"); Scheueri. Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it appears "that a recovery is very remote an
t makes sensitive allegations of sexual assault and abuse upon her when she was a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
2d 338 (1989) (" Rule 12(b)(6) does not I countenance ... dismissals b sed on a judge's disbelief of a complaint's factual allegations"). Scheuer . Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974) (a we -pleaded complaint may proceed even if it appears "that a recovery is very remote and
use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
in a trial on the merits, but whether they should be afforded an opportunity to offer evidence in support of their claims." /d. (citing Scheuer I Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974), overruled on other grounds, Harlow Fitzgerald, 457 U.S. 800, 102 S.Ct. 2727, 73 L.Ed.2d
laced. In the Amended 1999 Note, the parties stipu- lated only that IOUs note shall be governed by, and construed in accordance with, the laws of the State of New York, including matters of construction, validity and per- formance, without giving effect to princi- ples of conflicts of law .... (Mem. Of Law in Supp
in a trial on the merits, but whether they should be afforded an opportunity to offer evidence in support of their claims." Id. (citing Scheuer v. Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974), overruled on other grounds, Harlow v. Fitzgerald, 457 U.S. 800, 102 S.Ct. 2727, 73 L.Ed.2d
isplaced. In the Amended 1999 Note, the parties stipulated only that [t]his note shall be governed by, and construed in accordance with, the laws of the State of New York, including matters of construction, validity and performance, without giving effect to principles of conflicts of law (Mem. Of Law in Support of De
in a trial on the merits, but whether they should be afforded an opportunity to otter evidence in support of their claims." Id. (citing Scheuer v. Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974), overruled on other grounds, Harlow v. Fitzgerald. 457 U.S. 800, 102 S.Ct. 2727, 73 L.Ed.2d
isplaced. In the Amended 1999 Note, the parties stipulated only that (t)his note shall be governed by, and construed in accordance with, the laws of the State of New York, including matters of construction, validity and performance, without giving effect to principles of conflicts of law (Mem. Of Law in Support of De
in a trial on the merits, but whether they should be afforded an opportunity to offer evidence in support of their claims." Id. (citing Scheuer v. Rhodes, 416 U.S. 232, 236 (1974), overruled on other grounds, Harlow v. Fitzgerald, 457 U.S. 800 (1982)). The defendants raise several arguments in suppor
placed. In the Amended 1999 Note, the parties stipulated only that [t]his note shall be governed by, and construed in accordance with, the laws of the State of New York, including matters of construction, validity and performance, without giving effect to principles of conflicts of law . . . . (Mem. Of Law in Sup
.2d 338 (1989) ( Rule 12(b)(6) does not I countenance ... dismissals b sed on a judge's disbelief of a complaint's factual allegations"); Scheuer . Rhodes, 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974) (a we -pleaded complaint may proceed even if it appears "that a recovery is very remote and
use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
Entities connected to both Rhodes and the State of New York

Jeffrey Epstein
PERSON
JPMorgan Chase
ORGANIZATION
the Internal Revenue Service
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATION
Newark
LOCATION
George W. Bush
PERSONLeon Black
PERSON
New York
LOCATION
New York City
LOCATION
Samantha Power
PERSONthe Southern District
LOCATIONJane Doe
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
U.S. Virgin Islands
LOCATION
Scarlett Johansson
PERSON
Financial Trust Company
ORGANIZATION
Baltimore
LOCATION
Eric Holder
PERSON