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give rise to the "strong inference of fraudulent intent" required to plead a fraud claim in satisfaction of Rule 9(b). Wood, 328 Fed.Appx. at 747; O'Brien, 936 F.2d at 676. The allegation that Epstein had no intention of following through on his alleged promises to assist Plaintiff in gaining admissio
allegations state that Epstein promised and Plaintiff received generous support from Epstein, including "living quarters at 301 East 66th Street" on the Upper East Side of Manhattan, "a car service for Plaintiff to use as needed" and a "cell phone." FAC. ¶ 53. The FAC further alleged that Epstein even encouraged Pl
a factual basis, let alone an "ample factual basis," that would give rise to a "strong inference of fraudulent intent." Wood, 328 Fed.Appx. at 747; O'Brien, 936 F.2d at 676. The allegation that Epstein had no intention of following through on his alleged promises to assist Plaintiff in gaining admission
tead, the factual allegations state that Epstein promised and Plaintiff received generous support from Epstein, including "living quarters at on the Upper East Side of Manhattan, "a car service for Plaintiff to use as needed" and a "cell phone." Cplt. ¶ 49. These specific factual allegations do not support and,
a factual basis, let alone a "ample factual basis," that would give rise to a "strong inference of fraudulent intent." Wood, 328 Fed.Appx. at 747; O'Brien, 936 F.2d at 676. The allegation that Epstein had no intention of following through on his alleged promises to assist Plaintiff in gaining admission
raint, the Complaint alleges that Plaintiff traveled freely within the United States and abroad, and was provided with living quarters of her own on the Upper East Side of Manhattan as well as a car service and cellphone. Cplt. ¶¶ 49, 51, 57. Plaintiff alleges that, when Plaintiff was in where she held citizenship
Entities connected to both O'Brien and the Upper East Side

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
United States
LOCATION
New York
LOCATIONLeon Black
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATIONthe Southern District
LOCATION
George W. Bush
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
Alan Dershowitz
PERSON
Bill Clinton
PERSON
Joe Biden
PERSON
Scarlett Johansson
PERSON
U.S. Virgin Islands
LOCATION
Michael Jackson
PERSON
Bradley Cooper
PERSON