Epstein Secrets

NS WERE NEVER TESTED OR VERIFIED UNDER OATH THROUGH CROSS-EXAMINATION. 22. Mr. Epstein told to report back to him about what the men liked. In his New York mansion, Mr. Epstein had also installed a video system that taped every room in the house, which could allow Mr. Epstein to accumulate information t

y to his island, which she did several times in late 2006 and early 2007. Mr. Epstein and Ms. Maxwell told they could help arrange her admission at the Fashion Institute of Technology, where she dreamed of studying. 50. was told that if she refused to have sex with Mr. Epstein and his associates, her apartment would be taken aw

NS WERE NEVER TESTED OR VERIFIED UNDER OATH THROUGH CROSS-EXAMINATION. 22. Mr. Epstein told to report back to him about what the men liked. In his New York mansion, Mr. Epstein had also installed a video system that taped every room in the house, which could allow Mr. Epstein to accumulate information t

y to his island, which she did several times in late 2006 and early 2007. Mr. Epstein and Ms. Maxwell told they could help arrange her admission at the Fashion Institute of Technology, where she dreamed of studying. 50. was told that if she refused to have sex with Mr. Epstein and his associates, her apartment would be taken aw

2007. DOCUMENT REQUEST NO. 54 (Directed to All Defendants) All documents identifying all individuals who resided or stayed at 301 East 66th Street, New York, New York between August 2006 and May 2007. DOCUMENT REQUEST NO. 55 (Directed to All Defendants) All documents identifying all individuals who resi

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

ew York. As a result, personal jurisdiction over the 21 EFTA00307118 Defendants would have to be based on tortious conduct allegedly committed in New York. CPLR 302(a)(2). As explained below, however, there are insufficient allegations of tortious conduct during the limitations period upon which Plaint

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

o the period covered by the statute of limitations and that therefore the amended complaint fails to show that the suit-related conduct occurred in New York. This argument depends upon accepting the defendants' arguments on the statute of limitations that the Court has already rejected. In any event, to

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

2017 Page 10 III. The Court Does Not Have Jurisdiction Over Defendants The Complaint alleges without elaboration that Defendants are residents of New York. Cplt. II 4, 8. However, the Complaint alleges no facts to support this assertion. In fact, as you know, you cannot support these allegations of tie

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