Epstein Secrets

Michael C. Miller 1114 Avenue of the Americas New York. NY 10036 main www.steploe.com May 2017 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrew

cuments or had any power to affect her ability to travel to the United States. To the contrary, the Complaint alleges that she travelled to and from the United States as she wished. Indeed, she admits that "she refused to perform the recruitment assignment" allegedly "demanded" by Epstein to find young females to

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

assignment" allegedly "demanded" by Epstein to find young females to serve in "sexual servitude." Cplt. 1 51. Yet, she was able to come back to the United Stat ere is no showing of any threatened "serious harm" had she chosen to remain in There is simply no "threat of serious harm" alleged. In any event, this

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

Doe v. Shakur, 164 F.R.D. 359 (S.D.N.Y. 1996). 3 EFTA00307100 her prior employment, social or travel experiences, nor her purposes for coming to the United States, nor her immigration status while she was in the United States. One can only assume that she has chosen to omit these important facts, which are dir

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