3
Shared Docs
3
Same-Page
3 / 3
Mentions
o meet the more relaxed pleading standards set forth by the United States Supreme Court in Bell Atlantic Corp. v. Twombly, 127 S.Ct. 1955 (2007) and Ashcroft v. Igbal, 129 S.Ct. 1937 (2009). These two decisions set forth the basic requirements for pleading a claim. As explained and applied by the Second
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
17 18 19 20 21 22 23 24 25 that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 667 (2009). While the Court should construe the factual allegations in the light most favorable to the plaintiff, "the ten
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
meet the more relaxed pleading standards set forth by the United States Supreme Court in Bell Atlantic Corp. v. Twombly, 127 S.Ct. 1955 (2007) and Ashcroft v. Igbal, 129 S.Ct. 1937 (2009). These two decisions set forth the basic requirements for pleading a claim. As explained and applied by the Second C
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"), but had no intention of doing so. Cplt. ¶¶ 37, 50, 53-55. This is insufficient to satisfy Rule 9(b). First, the Complaint fails to identify
Entities connected to both Ashcroft and the Fashion Institute of Technology

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATION
New York
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONJane Doe
PERSONTwombly
PERSON
Alan Dershowitz
PERSON
U.S. Virgin Islands
LOCATION
Michael Cohen
PERSON
Bradley Edwards
PERSONBell Atlantic Corp.
ORGANIZATION
George Mitchell
PERSONJoe Recarey
PERSONSecond Circuit
ORGANIZATION
Donald Trump
PERSON
Marc Rich
PERSONMaria Farmer
PERSON