This letter from Michael C. Miller to Brad Edwards discusses the grounds for dismissal of the complaint in the case of Jane Doe 43 v. Jeffrey Epstein, et al. The letter argues that the complaint fails to state a claim under 18 U.S.C. § 1595, is barred by the statute of limitations, lacks personal jurisdiction over the defendants, and is improperly venued in the Southern District of New York. The letter details deficiencies in the complaint's allegations of fraud and coercion, and argues that the complaint fails to meet the pleading standards required under Rule 9(b) and the Twombly/Igbal standard.
documents/EFTA00298455.pdf
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