Epstein Secrets

a claim which is barred by the statute of limitations; (c) fails to allege personal jurisdiction over Intervenors; and (d) improperly lays venue in the Southern District of New York. The FAC alleges a brief adult relationship between Jane Doe and Mr. Epstein beginning in October 2006. Jane Doe describes herself as a

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

The Claim Is Barred by the Statute of Limitations 19 E. The Court Does Not Have Jurisdiction Over Defendants 21 F. Venue Is Improperly Laid in the Southern District of New York 22 CONCLUSION 22 EFTA00307097 Defendants Jeffrey Epstein ("Epstein") and (a") (collectively "Defendants") submit this memorandum

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

y individual who, along with and , has previously been investigated by Florida state law enforcement and the United States Attorney's office for the Southern District of Florida for various offenses relating to sex trafficking, including 18 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00285672 43 I87

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

s barred by the statute of limitations; (c) the Complaint fails to allege personal jurisdiction over Defendants; and (d) venue is improperly laid in the Southern District of New York. Because the claim turns on whether there was fraud and coercion, as you admitted in open court during the initial case management conf

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