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52, 95-96; Ransome_000157-68. Jane Doe also admitted that Mr. Epstein provided her with a comfortable lifestyle, including a "massive" apartment on the Upper East Side of Manhattan and unlimited access to a car service whenever she needed it. Dep. 70-71. She also admitted, contrary to her allegations in the FAC, t
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
e for bringing to him. EFTA00808063 49. After the massages turned sexual, was allowed to live in a large apartment in Mr. Epstein's building on the Upper East Side. She was also given a cell phone, car service, and money for living expenses. Mr. Epstein invited her to fly to his island, which she did several t
y to his island, which she did several times in late 2006 and early 2007. Mr. Epstein and Ms. Maxwell told they could help arrange her admission at the Fashion Institute of Technology, where she dreamed of studying. 50. was told that if she refused to have sex with Mr. Epstein and his associates, her apartment would be taken aw
lars in exchange for bringing to him. 49. After the massages turned sexual, was allowed to live in a large apartment in Mr. Epstein's building on the Upper East Side. She was also given a cell phone, car service, and money for living expenses. Mr. Epstein invited her to fly to his island, which she did several t
y to his island, which she did several times in late 2006 and early 2007. Mr. Epstein and Ms. Maxwell told they could help arrange her admission at the Fashion Institute of Technology, where she dreamed of studying. 50. was told that if she refused to have sex with Mr. Epstein and his associates, her apartment would be taken aw
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
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
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
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 the Upper East Side and the Fashion Institute of Technology

Jeffrey Epstein
PERSON
New York
LOCATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSON
U.S. Virgin Islands
LOCATION
Prince Andrew
PERSON
Les Wexner
PERSON
United States
LOCATIONAce Greenberg
PERSON
Bear Stearns
ORGANIZATION
Palm Beach
LOCATION
Bill Clinton
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSON
Bradley Edwards
PERSONJ. Epstein & Co.
ORGANIZATION
Marc Rich
PERSON
Barry Diller
PERSON