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ated in any way with M, asserting instead that Epstein merely "had contacts at M." FAC ¶ 60. Such bare allegations are insufficient. Ashland Inc. v. Morgan Stanley & Co., 652 F.3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); Schlaifer Nance & Co. v. Es
laim involves allegations of fraud, the Plaintiff's decision to lump all defendants in groups is insufficient to state a claim. Camofi Master LDC v. Riptide Worldwide, Inc., 2011 WL 1197659, at *6 (S.D.N.Y. Mar. 25, 2011) ("group pleading doctrine is an exception to the requirement that the fraudulent acts of eac
the ability "to have Plaintiff admitted to' For example, the Complaint fails to allege that Epstein was associated in any way wit Ashland Inc. v. Morgan Stanley & Co., 652 F.3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); Schlaifer Nance & Co. v. Est
aim involves allegations of fraud, the Plaintiff's decision to lump all defendants in groups is insufficient to state a claim. Camofi Master LDC v. Riptide Worldwide, Inc., 2011 WL 1197659, at *6 (S.D.N.Y. Mar. 25, 2011) ("group pleading doctrine is an exception to the requirement that the fraudulent acts of eac
bility "to have Plaintiff admitted to" . For example, the Complaint fails to allege that Epstein was associated in any way with . Ashland Inc. v. Morgan Stanley & Co., 652 F.3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); Schlaifer Nance & Co. v. Est
aim involves allegations of fraud, the Plaintiff's decision to lump all defendants in groups is insufficient to state a claim. Camofi Master LDC v. Riptide Worldwide, Inc., 2011 WL 1197659, at *6 (S.D.N.Y. Mar. 25, 2011) ("group pleading doctrine is an exception to the requirement that the fraudulent acts of eac
Entities connected to both Morgan Stanley & Co. and Riptide Worldwide

Jeffrey Epstein
PERSON
United States
LOCATION
New York
LOCATION
Michael Cohen
PERSONO'Brien
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Ashcroft
PERSONTwombly
PERSONSecond Circuit
ORGANIZATIONBell Atlantic Corp.
ORGANIZATIONthe Southern District
LOCATIONthe Upper East Side
LOCATIONAbarca
PERSONCamofi
PERSONThe Court Does Not Have Jurisdiction Over Defendants
ORGANIZATIONWood v. Research Applied Associates
ORGANIZATIONO'Brien v. Nat'l
ORGANIZATIONFahnstock & Co.
ORGANIZATIONSchlaifer Nance & Co.
ORGANIZATION