EFTA00285631.txt

"On behalf of defendant Ghislaine Maxwell, I would ask the Court to dismiss the first amended complaint"

"the defendants' argument that the amended complaint fails to plead a causal link"

"the defendants' argument that the amended complaint fails to plead a causal link"

"the plaintiff's claim that they violated Section 1592"

"interaction with Epstein occurred at his townhouse in New York"

"on his private island in the U.S. Virgin Islands"

"Michael Miller and Justin Chu from the law firm of Steptoe & Johnson, and Darren Indyke, who is counsel to Mr. Epstein. We represent Jeffery Epstein"

"Michael Miller and Justin Chu from the law firm of Steptoe & Johnson... We represent Jeffery Epstein"

"Darren Indyke, who is counsel to Mr. Epstein"

"Laura Menninger, on behalf of Ghislaine Maxwell, from Haddon Morgan & Foreman"

"Before: HON. JOHN G. KOELTL District Judge"

"JEFFERY EPSTEIN, GHISLAINE MAXWELL, and Defendants"

"JEFFERY EPSTEIN, GHISLAINE MAXWELL, and Defendants"

"left New York City, left where Mr. Epstein and the defendants were allegedly located"

"predated the plaintiff's departure from New York to go to"

"the defendants and their current ties to New York relate to Mr. Epstein"

"plaintiff returned to New York City... and was promptly ordered by the defendant Maxwell to have sex with defendant Epstein"

"was promptly ordered by the defendant Maxwell to have sex with defendant Epstein"

"In their response, plaintiff has pointed to two particular paragraphs that they claim adequately state a claim for coercion"

"suggest under the terms of the amended complaint that this individual, Mr. Epstein, could control all higher institutions"

"But there is even less with respect to my client, your Honor. There are no allegations that she controlled the world"

"between October 2006 and May 2007, the defendants knowingly, coercively, and fraudulently recruited and enticed the plaintiff to engage in commercial "

"between October 2006 and May 2007, the defendants knowingly, coercively, and fraudulently recruited and enticed the plaintiff"

"between October 2006 and May 2007, the defendants knowingly, coercively, and fraudulently recruited and enticed the plaintiff"

"the plaintiff was approached by [REDACTED], allegedly one of the enterprise's recruiters. [REDACTED] informed the plaintiff that she would introduce t"

"Epstein allegedly converted the massage into a sexual act and made it known to the plaintiff that further sex would be required in order for the plain"

"Ghislaine Maxwell, who allegedly oversaw the entire sexual enterprise with Epstein, told the plaintiff that in order to reap the benefits of Epstein's"

"while being transported to Epstein's island in the U.S. Virgin Islands"

"the plaintiff performed sex acts on Epstein"

"recruited an enticed into performing sex acts with Epstein"

"recruited an enticed into performing sex acts with Epstein as part of a larger enterprise to provide Epstein with young females for sex"

"the plaintiff performed sex acts on Epstein in return for numerous financial inducements"

"while the plaintiff was on Epstein's private island"

"coerced the plaintiff into performing and continuing to perform the sexual acts requested by Epstein"

"Maxwell, and [REDACTED] each confirmed and reiterated to the plaintiff many times that Epstein would use his wealth and connections to advance the pla"

"substantial portion of her interaction with Epstein occurred at his townhouse in New York"

"substantial portion of her interaction with Epstein occurred... on his private island in the U.S. Virgin Islands"

"BOIES SCHILLER & FLEXNER LLP Attorneys for Plaintiff BY: SIGRID MCCAWLEY"

"Michael Miller and Justin Chu from the law firm of Steptoe & Johnson"

"Laura Menninger, on behalf of Ghislaine Maxwell, from Haddon Morgan & Foreman"

"coerce the plaintiff into providing sex to Epstein"

"the plaintiff left New York City, left where Mr. Epstein and the defendants were allegedly located"

"in January of 2007... the plaintiff left New York City... and went home [to Mexico]"

"the threat was you'll never go to college anywhere, you'll never get a career going anywhere"

"she was asked to look for somebody to work as a personal assistant to Mr. Epstein"

"Epstein, Maxwell, and [REDACTED] took possession of the plaintiff's passport in order to coerce her to comply with their demands"

"Epstein, Maxwell, and [REDACTED] took possession of the plaintiff's passport in order to coerce her to comply with their demands"

"provide body massages to Epstein, both at his alleged townhouse in New York City"

"provide body massages to Epstein... on his alleged private island in the U.S. Virgin Islands"

"the plaintiff was allegedly recruited and enticed by the defendants who knew that she would be fraudulently induced to engage in commercial sex acts w"