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ownhouse in Manhattan that was formerly owned by Les Wexner. a villa in Palm Beach, Florida, and a fortress on
ouse in Manhattan that was formerly owned by Les Wexner. a villa in Palm Beach, Florida, and a fortress o
al place of abode with Mark, a person of suitable age and discretion who resides there . . . ." 8. The foregoing service constituted proper service the Federal Rules of Civil Procedure. See Fed. R. Civ. P. 4(e)(2)(B). Under the Federal Rules of Civil Procedure, an answer to a properly served complaint must be filed withi
ter." 127. Before Staley, Epstein relied heavily on the massive wealth bestowed upon him primarily by one individual, Leslie (Les) Herbert Wexner ("Wexner"), to give him the appearance of grand importance while relying on his then-madame, Maxwell, to find and groom young women to be abused. 128. It h
Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 36 of 130 Epstein's international sex trafficking operation, most notably Ghislaine Maxwell, Les Wexner, Jean Luc Brunel, and Jes Staley, acting through and on behalf of JP Morgan. 139. In later years, Deutsche Bank swapped in for JP Morgan and provid
e other Class members. 284. This action has been brought and may properly be maintained as a class action against JP Morgan pursuant to Rule 23 of the Federal Rules of Civil Procedure because there is a well-defined community of interest in the litigation and the proposed Class is easily ascertainable from JP Morgan's r
ations of extortion relate to BSF. At oral argu Court asked if "the gist of the statement was tha conspired with people in [BS1Mrt, among others, Wexner" to which counsel for , BSF) confirmed the Complaint's allegation that it was a "defamatory statement" (Tr. 65:3, Sept. 24, 2019). A few moments
l be correct, that Dcrshowitz was always free to sue if he felt aggrieved by what he views as her false and defamatory statements about him. But the Federal Rules of Civil Procedure require Dershowitz, at the motion to dismiss stage, to satisfy different requirements from those applied to Plaintiff. The putative "unf
Entities connected to both Les Wexner and the Federal Rules of Civil

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Bill Clinton
PERSON
Donald Trump
PERSON
U.S. Virgin Islands
LOCATIONDarren Indyke
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
New York
LOCATION
Marc Rich
PERSONJane Doe
PERSON
United States
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSON
Kenneth Marra
PERSONAce Greenberg
PERSON
Virginia Giuffre
PERSON
Harvey Weinstein
PERSON