Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE 43, Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE MAXWELL, AND Defendants. CASE NO. 17 Civ 616 (JGK) MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS EFTA00307096 ARGUMENT 1 A.

er Defendants 21 F. Venue Is Improperly Laid in the Southern District of New York 22 CONCLUSION 22 EFTA00307097 Defendants Jeffrey Epstein ("Epstein") and (a") (collectively "Defendants") submit this memorandum in support of their motion to dismiss the First Amended Complaint ("FAC") filed by

th substance and cited sources. See FAC at ¶11 ("Defendant Epstein is widely recognized..."), ¶22 ("Defendants Epst

TRICT OF NEW YORK JANE DOE 43, Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE MAXWELL, AND Defendants. C

rgin Islands. Dated: July 2017 Respectfully submitted, STEPTOE & JOHNSON, LLP By /s/ Michael Miller Justin Y.K. Chu Attorneys for Defendants JEFFREY EPSTEIN & To: FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Brad Edwards Attorney for Plaintiff Jane Doe 43 ALSTON & BIRD, LLP Alexander S L

re relaxed pleading standards set forth by the United States Supreme Court in Bell Atlantic Corp. v. Twombly, 127 S.Ct. 1955 (2007) and Ashcroft v. Igbal, 129 S.Ct. 1937 (2009). These two decisions set forth the basic requirements for pleading a claim. As explained and applied by the Second Circuit:

mim Michael C. Miller May 15, 2017 Brad Edwards, Esq. Re: v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear Brad: Steptoe stenos • JOHNSON 1.0 In accordance with the Court's May 15, 2017 Stipulation and Order in t

stenos • JOHNSON 1.0 In accordance with the Court's May 15, 2017 Stipulation and Order in the above- referenced matter, defendants Jeffrey Epstein ("Epstein") and (collectively "Defendants" se f rth in this letter sinds pursuant to which the Complaint filed by plaintiff ("Plaintiff" or ' ') should be

"in addition to their requiring Plaints to prow e Defendant Epstein with sex acts, Defendants continued to pressure

Miller May 15, 2017 Brad Edwards, Esq. Re: v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 Dear

fendant's liability, it stops short of the line between possibility and plausibility of entitlement to relief. Wood, 328 Fed.Appx. at 747 (quoting Igbal, 129 S.Ct. at 1949). Here, at best, the Complaint merely parrots the statutory elements of a Section 1595 claim regarding fraud and coercion withou

ds, 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 manar. conference in th

ordance with the procedures directed by the Court at the initial case manar. conference in the above-referenced matter, defendants Jeffrey Epstein ("Epstein") and ("=") (collectively "Defendants") set forth in this letter the pursuant to which the Complaint filed by plaintiff ("Plaintiff" or a") sho

addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, Defendants continued to pressure h

erence in the above-referenced matter, defendants Jeffrey Epstein ("Epstein") and ("=") (collectively "De

fendant's liability, it stops short of the line between possibility and plausibility of entitlement to relief. Wood, 328 Fed.Appx. at 747 (quoting Igbal, 129 S.Ct. at 1949). Here, the Complaint merely parrots the statutory elements of a Section 1595 claim regarding fraud and coercion. As described i