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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
re 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 Circuit:
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
fendant's liability, it stops short of the line between possibility and plausibility of entitlement to relief. Wood, 328 Fed.Appx. at 747 (quoting Igbal, 129 S.Ct. at 1949). Here, at best, the Complaint merely parrots the statutory elements of a Section 1595 claim regarding fraud and coercion withou
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
fendant's liability, it stops short of the line between possibility and plausibility of entitlement to relief. Wood, 328 Fed.Appx. at 747 (quoting Igbal, 129 S.Ct. at 1949). Here, the Complaint merely parrots the statutory elements of a Section 1595 claim regarding fraud and coercion. As described i
Entities connected to both O'Brien and Igbal

Jeffrey Epstein
PERSON
United States
LOCATION
Michael Cohen
PERSON
Ghislaine Maxwell
PERSON
New York
LOCATIONMaria Farmer
PERSONthe Southern District
LOCATION
Anderson
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSONJane Doe
PERSONSecond Circuit
ORGANIZATION
Ashcroft
PERSONAce Greenberg
PERSON
U.S. Virgin Islands
LOCATION
Andy Warhol
PERSONRiptide Worldwide
ORGANIZATIONBraskem S.A. Sec
ORGANIZATIONthe Upper East Side
LOCATIONAbarca
PERSON