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This Court had personal jurisdiction over Epstein at the time of his death because the tortious acts giving rise to Plaintiff's claims took place in New York State. 24. This Court has personal jurisdiction over because the tortious acts and omissions giving rise to Plaintiff's claims took place in New York S
stein to use for sexual purposes, and to facilitate sexual encounters between underage girls and Epstein. 86. Upon information and belief, kept a Rolodex that included numerous underage girls for Epstein to use for sexual purposes. 87. Upon information and belief, warned numerous underage girls who
red from a sexually transmitted disease ... failed to issue a retraction when the undisputed falsity of their story was presented to them, violated New York State medical privacy laws and rape shield laws to try and obtain confidential medical and other records about plaintiff, violated Journalism ethics stan
it represents an achievement to Jeffrey." Some girls who "worked" for Epstein—the term favored by the unfriendly assistant who allegedly kept the Rolodex—seem to have embraced that fantasy, too. One girl said she was "so in love with Jeff Epstein and would do anything for him." Two college girls/aspir
they knew they could get ... and that was the fraudulent promissory notes (i.e., the much larger and unrelated part of Hoffenberg's fraud, based in New York State)... What they couldn't get, they didn't bother with." Another lawyer involved in the criminal prosecution of Hoffenberg says, "In a criminal inves
represents an achievement to Jeffrey." Some girls who "worked" for Epstein—the term favored by the unfriendly assistant, , who allegedly kept the Rolodex—seem to have embraced that fantasy, too. One girl said she was "so in love with Jeff Epstein and would do anything for him." Two college girls/aspir
ey knew they could get ... and that was the fraudulent promissory notes [i.e.. the much larger and unrelated part of Hoffenberg's fraud, based in New York State].... What they couldn't get. they didn't bother with.- Another lawyer involved in the criminal prosecution of HotTenberg says. "In a crim- inal in
an achievement to Jeffrey." Some girls who "worked" for Epstein—the term favored by the unfriendly assistant, Sarah Kellen, who allegedly kept the Rolodex—seem to have embraced that fantasy, too. One girl said she was "so in love with Jeff Epstein and would do anything for him." Two college girls/aspir
Entities connected to both New York State and Rolodex

Jeffrey Epstein
PERSON
New York
LOCATION
United States
LOCATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Julie K. Brown
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
John F. Kennedy
PERSON
Lesley Groff
PERSON
U.S. Virgin Islands
LOCATION
Prince Charles
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSON
Bill Clinton
PERSON
Palm Beach
LOCATION