This document is a memorandum of law filed under seal in the United States District Court for the Southern District of New York. It supports a supplemental motion to dismiss the First Amended Complaint (FAC) filed by plaintiff Jane Doe 43 against defendants Jeffrey Epstein, Ghislaine Maxwell, Lesley Groff, and others. The memorandum argues that the FAC 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 improperly lays venue in the Southern District of New York. It also contends that the FAC does not meet the Twombly/Iqbal standard and that the allegations regarding prior proceedings should be stricken. The document includes a detailed argument section addressing various legal deficiencies in the FAC, including failure to plead fraud, coercion, and a causal link, as well as failure to allege knowledge against Groff and any predicate acts.
documents/EFTA00801426.pdf
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