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

tate a claim sounding in fraud, a plaintiff must plead, among other things, that she reasonably relied on the alleged misrepresentation. Crigger v. Fahnstock & Co., Inc., 443 F.3d 230, 234 (2d Cir. 2006). The FAC does not meet this basic requirement. Instead, the FAC merely states in conclusory terms that "Pla

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

tate a claim sounding in fraud, a plaintiff must plead, among other things, that she reasonably relied on the alleged misrepresentation. Crigger v. Fahnstock & Co., Inc., 443 F.3d 230, 234 (2d Cir. 2006). The Complaint does not meet this basic requirement. Instead, the Complaint merely states in conclusory ter

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

tate a claim sounding in fraud, a plaintiff must plead, among other things, that she reasonably relied on the alleged misrepresentation. Crigger v. Fahnstock & Co., Inc., 443 F.3d 230, 234 (2d Cir. 2006). The Doc. # DC-10084480 v.8 EFTA00298457 Brad Edwards, Esq. May , 2017 Page 4 Complaint does not meet