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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
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
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
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
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
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
Entities connected to both Michael Cohen and Fahnstock & Co.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Marc Rich
PERSON
United States
LOCATION
New York
LOCATIONMaria Farmer
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATIONJane Doe
PERSONSecond Circuit
ORGANIZATION
Anderson
PERSONO'Brien
PERSON
U.S. Virgin Islands
LOCATIONAce Greenberg
PERSONFISTOS & LEHRMAN
ORGANIZATION
Ashcroft
PERSONthe Upper East Side
LOCATION
Andy Warhol
PERSONTwombly
PERSONBell Atlantic Corp.
ORGANIZATION