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

identified separately in the complaint," its application is "limited to group-published documents," and "does not apply to oral statements"); In re Braskem S.A. Sec. Litig., 2017 WL 1216592, at *20 (S.D.N.Y. Mar. 30, 2017) ("the Court has doubt whether the group-pleading doctrine remains good law"). Defendants

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

identified separately in the complaint," its application is "limited to group-published documents," and "does not apply to oral statements"); In re Braskem S.A. Sec. Litig., 2017 WL 1216592, at *20 (S.D.N.Y. Mar. 30, 2017) ("the Court has doubt whether the group-pleading doctrine remains good law"). A small sa

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

identified separately in the complaint," its application is "limited to group-published documents," and "does not apply to oral statements"); In re Braskem S.A. Sec. Litig., 2017 WL 1216592, at *20 (S.D.N.Y. Mar. 30, 2017) ("the Court has doubt whether the group-pleading doctrine remains good law"). The Compla