This document is a memorandum of law in support of a motion to dismiss the First Amended Complaint (FAC) filed by Jane Doe 43 against Jeffrey Epstein, Ghislaine Maxwell, 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 is improperly venued in the Southern District of New York. It also contends that the FAC fails to meet the pleading standards required under Rule 9(b) and Twombly/Iqbal, and that the allegations regarding prior proceedings should be stricken.
documents/EFTA00307096.pdf
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