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. Allegatio

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. Allegations Regard

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

st, the allegations of coercion are unspecific and wholly conclusory, as exemplified by the allegations in paragraph 45 that "Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaint

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

ere she held citizenship and where her parents resided, Epstein and Doc. # DC-1008444ki v.8 EFTA00298459 Brad Edwards, Esq. May , 2017 Page 6 Maxwell told her that "she would not be permitted to return to the United States to receive her promised education unless she lost weight." Plaintiff does n

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