Epstein Secrets

595 claim on the Defendants' supposed fraudulent statements and, as a result, the heightened pleading standards set forth in Fed.R.Civ.P 9(b) apply. Cohen v. SAC Trading Corp., 711 F.3d 353, 359 (2d Cir. 2013) (Rule 9(b) "standard also applies to allegations of fraudulent predicate acts supporting a R

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

5 claims on the Defendants' supposed fraudulent statements and, as a result, the heightened pleading standards set forth in Fed.R.Civ.P 9(b) apply. Cohen v. SAC Trading Corp., 711 F.3d 353, 359 (2d Cir. 2013) (Rule 9(b) "standard also applies to allegations of fraudulent predicate acts supporting a RI

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

5 claims on the Defendants' supposed fraudulent statements and, as a result, the heightened pleading standards set forth in Fed.R.Civ.P 9(b) apply. Cohen v. SAC Trading Corp., 711 F.3d 353, 359 (2d Cir. 2013) (Rule 9(b) "standard also applies to allegations of fraudulent predicate acts supporting a RI

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