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menced until January 27, 2017, more than four years after any of the events alleged in the FAC occurred. Plaintiff's claim is therefore time-barred. Abarca v. Little, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitation
ge Other Predicate Acts 16 C. The FAC Fails to Meet the Twombly/Igbal Standard 18 D. The Claim Is Barred by the Statute of Limitations 19 E. The Court Does Not Have Jurisdiction Over Defendants 21 F. Venue Is Improperly Laid in the Southern District of New York 22 CONCLUSION 22 EFTA00307097 Defendants Jeffrey Epstein ("Epstein") and
d until January 27, 2017, more than four years after any of the events alleged in the Complaint occurred. Plaintiffs claim is therefore time-barred. Abarca v. Little, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitation
f the specific factual allegations necessary to establish what Epstein or=actually did during that limitations period to violate the statute. III. The Court Does Not Have Jurisdiction Over Defendants The Complaint alleges without elaboration that Defendants are residents of New York. Cplt. ¶ ¶ 4, 8. However, the Complaint alleges no facts to
until January 27, 2017, more than four years after any of the events alleged in the Complaint occurred. Plaintiff's claim is therefore time-barred. Abarca v. Little, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitation
cifying what Epstein or actually did to violate the statute. Doc. # DC-10084480 v.8 EFTA00298463 Brad Edwards, Esq. May , 2017 Page 10 III. The Court Does Not Have Jurisdiction Over Defendants The Complaint alleges without elaboration that Defendants are residents of New York. Cplt. II 4, 8. However, the Complaint alleges no facts to supp
Entities connected to both Abarca and The Court Does Not Have Jurisdiction Over Defendants

United States
LOCATIONthe Southern District
LOCATION
Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONthe Upper East Side
LOCATIONTwombly
PERSON
New York
LOCATION
Ashcroft
PERSON
Michael Cohen
PERSONO'Brien
PERSON
Bradley Edwards
PERSONAce Greenberg
PERSON
Andy Warhol
PERSONSecond Circuit
ORGANIZATIONBell Atlantic Corp.
ORGANIZATIONthe Fashion Institute of Technology
ORGANIZATIONMorgan Stanley & Co.
ORGANIZATIONCamofi
PERSONWood v. Research Applied Associates
ORGANIZATIONO'Brien v. Nat'l
ORGANIZATION