Epstein Secrets

rk October 5, 2017 ly subwitted, el C. Miller Justin Y.K. Chu Michael A. Keough STEPTOE & JOHNSON LL

extravagant New York lifestyle, including a "massive" Upper East Side apartment, he failed to fulfill his alleged promise to "have her admitted" to the Fashion Institute of Technology ("FIT"). More than ten years later, based on these events, Jane Doe filed the original Complaint (and now the FAC) in which, astonishingly, she cla

3 Counsel for Ghislaine Maxwell Michael Miller Justin Y.K Chu Michael A. Keough STEPTOE & JOHNSON LLP

All Defendants) All documents evidencing money paid to at any time. DOCUMENT REQUEST NO. 6 (Directed to All Defendants) All documents relating to the Fashion Institute of Technology ("F.I.T."). 7 EFTA00793331 DOCUMENT REQUEST NO. 7 (Directed to All Defendants) All communications with F.I.T. related in any way to DOCUMENT RE

STEPTOE & JOHNSON, LLP By /s/ Michael Miller Justin Y.K. Chu Attorneys for Defendants JEFFREY EPSTE

ns of fraud boil down to this: Epstein allegedly "confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into the Fashion Institute of Technology" ("E") and to advanced her career, but had no intention of doing so. FAC ¶¶ 38, 53, 58-64. This is insufficient to satisfy Rule 9(b). First, the F

ndants Jeffery Epstein, and BY: MICHAEL MILLER JUSTIN CHU DARREN K. INDYKE LLC Attorney for Defendant

again that her sexual compliance would be SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00285645 16 I877DOEC rewarded with admission to the Fashion Institute of Technology or a comparable college, a promise which they knew to be false." 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25