3
Shared Docs
3
Same-Page
3 / 3
Mentions
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
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
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
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
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
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 Ace Greenberg and Fahnstock & Co.

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