Epstein Secrets

es to assist Plaintiff in gaining admission to or her career advancement is merely conclusory, and does not satisfy the requirements of Rule 9(b). Greenberg, 198 F.Supp.2d at 583 ("fraudulent intent cannot be inferred merely from the non-performance of a party's representations"). Plaintiff has alleged

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

Plaintiffs allegations that the Defendants did not act on the alleged promise is insufficient to show that the representation was false when made. Greenberg v. Chrust, 198 F.Supp.2d 578, 583 (S.D.N.Y. 2002) ("failure to fulfill a promise to perform future acts is not grounds for a fraud action" and "frau

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

d were false when made. That the Defendants did not act on the alleged promise is insufficient to show that the representation was false when made. Greenberg v. Christ, 198 F.Supp.2d 578, 583 (S.D.N.Y. 2002) ("failure to fulfill a promise to perform future acts is not grounds for a fraud action" and "fra

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