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ce in its entirety is probative of the issues which will be raised in the Motion to Dismiss, including whether the statute of limitations has run on Jane Doe's claim, whether the Court in the Jane Doe Matter has personal jurisdiction over the defendants, and whether the Motion to Dismiss should be granted
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
") (collectively "Defendants") submit this memorandum in support of their motion to dismiss the First Amended Complaint ("FAC") filed by plaintiff Jane Doe ("Plaintiff') pursuant to Fed.R.Civ.P. 12(b)(2) and (6). The FAC represents the Plaintiff's second unsuccessful bite at the apple. On January 26,
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
017 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Re: Jane Doe 43 v. Jeffery Epstein, et al. Civil Action No. 17-cv-616 Dear Brad: In accordance with the procedures directed by the Court at the initial case ma
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
Entities connected to both Jane Doe and the Fashion Institute of Technology

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONFISTOS & LEHRMAN
ORGANIZATION
New York
LOCATION
Palm Beach
LOCATION
Marc Rich
PERSON
U.S. Virgin Islands
LOCATION
Jean-Luc Brunel
PERSON
Les Wexner
PERSON
David Boies
PERSON