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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
actual basis must be supplied to support the charges. 4 EFTA00307101 Wood v. Research Applied Associates, 328 Fed.Appx. 744, 747 (2d Cir. 2009); O'Brien v. Nat'l Prop. Analysts Partners, 936 F.2d 674, 676 (2d Cir.1991). Plaintiff's allegations of fraud boil down to this: Epstein allegedly "confirmed to Plain
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
ations. An ample factual basis must be supplied to support the charges. Wood v. Research Applied Associates, 328 Fed.Appx. 744, 747 (2d Cir. 2009); O'Brien v. Nat'l Prop. Analysts Partners, 936 F.2d 674, 676 (2d Cir.1991). Plaintiff's allegations of fraud boil down to this: Epstein allegedly "confirmed to Plain
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
ations. An ample factual basis must be supplied to support the charges. Wood v. Research Applied Associates, 328 Fed.Appx. 744, 747 (2d Cir. 2009); O'Brien v. Nat'l Prop. Analysts Partners, 936 F.2d 674, 676 (2d Cir.1991). Plaintiff's allegations of fraud boil down to this: Epstein allegedly "confirmed to Plain
Entities connected to both Ace Greenberg and O'Brien v. Nat'l

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
United States
LOCATION
New York
LOCATION
U.S. Virgin Islands
LOCATION
Marc Rich
PERSONMaria Farmer
PERSONthe Upper East Side
LOCATIONthe Southern District
LOCATION
Michael Cohen
PERSONJane Doe
PERSONFISTOS & LEHRMAN
ORGANIZATIONSecond Circuit
ORGANIZATION
Anderson
PERSONO'Brien
PERSON
Andy Warhol
PERSON
Ashcroft
PERSONIgbal
ORGANIZATIONWood v. Research Applied Associates
ORGANIZATION