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end the complaint in accordance with Rule 15(a)." Tucker v. Union of Needletrades, Indus. & Textile Emps.
to put defendant on notice of such a claim. Plaintiffs cannot expand their claims at the summary judgment stage to assert new theories of recovery. Bridgeport Music, Inc. v. WB Music Corp.., 508 F.3d 394, 400 (6th Cir. 2007). "A non-moving party plaintiff may not raise a new legal claim for the first time in response
aft. On one occasion, Epstein flew the former President, Hollywood actor and staunch Democrat Kevin Spacey and another actor friend of Mr Clinton’s, Chris Tucker, to Africa, to ‘discuss AIDS policy’. Epstein, who has donated more than £75,000 over the years to candidates from the Democratic Party, also flew w
Page: HOUSE_OVERSIGHT_014669 →overns the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 HOUSE_OVERSIGHT_014680 --- PAGE BREAK --- Case 9:6ase-doFee
Page: HOUSE_OVERSIGHT_014681 →craft.On one occasion, Epstein flew the former President, Hollywood actor and staunch Democrat Kevin Spacey and another actor friend of Mr Clinton’s, Chris Tucker, to Africa, to ‘discuss AIDS policy’. GM_00715 http:/Awww.dailymail.co.uk/news/article-1363452/Bill-Clinton-15-year-old-masseuse-I-met-twice-claims
Page: HOUSE_OVERSIGHT_014805 →overns the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 HOUSE_OVERSIGHT_014850 --- PAGE BREAK --- Case 9:0&aé807E5-d0A07 4 oA nilk
Page: HOUSE_OVERSIGHT_014851 →Entities connected to both Chris Tucker and Bridgeport Music, Inc.

Jeffrey Epstein
PERSON
Donald Trump
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
George W. Bush
PERSON
United States
LOCATION
Stephen Hawking
PERSONEmmy Taylor
PERSON
Marc Rich
PERSON
Barack Obama
PERSON
Eric Trump
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSON
New York
LOCATION
Paul Ryan
PERSON
Kevin Spacey
PERSON
Hillary Clinton
PERSON