Epstein Secrets

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

tate a claim sounding in fraud, a plaintiff must plead, among other things, that she reasonably relied on the alleged misrepresentation. Crigger v. Fahnstock & Co., Inc., 443 F.3d 230, 234 (2d Cir. 2006). The FAC does not meet this basic requirement. Instead, the FAC merely states in conclusory terms that "Pla

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,

tate a claim sounding in fraud, a plaintiff must plead, among other things, that she reasonably relied on the alleged misrepresentation. Crigger v. Fahnstock & Co., Inc., 443 F.3d 230, 234 (2d Cir. 2006). The Complaint does not meet this basic requirement. Instead, the Complaint merely states in conclusory ter

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

tate a claim sounding in fraud, a plaintiff must plead, among other things, that she reasonably relied on the alleged misrepresentation. Crigger v. Fahnstock & Co., Inc., 443 F.3d 230, 234 (2d Cir. 2006). The Doc. # DC-10084480 v.8 EFTA00298457 Brad Edwards, Esq. May , 2017 Page 4 Complaint does not meet