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Case 9:10-cv-80447-KAM Document 5 Entered on FLSD Docket 05/03/2010 Page 1 of 22
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 10-80447-CIV
C.L.,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
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DEFENDANT EPSTEIN'S MOTION FOR MORE DEFINITE
STATEMENT & TO STRIKE, & TO DISMISS DIRECTED TO COUNT
III OF PLAINTIFF C.L.'S COMPLAINT (D.E. 1, dated 3/31/2010)
Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned
counsel, files this Motion For More Definite Statement & Strike, and Motion to Dismiss
Count III Directed To Plaintiff C.L.'s Complaint. Rule 12(b)(6), Rule 12(e) and (f),
Fed.R.Civ.P. (2010); Local Gen. Rule 7.1 (S.D. Fla. 2009). In support of his motion,
Defendant states:
The Complaint attempts to allege 3 counts, all of which are purportedly brought
pursuant to 18 U.S.C. §2255 - Civil Remedies for Personal Injuries. Defendant seeks
more definite statement of the precise time period during which the alleged conduct by
EPSTEIN involving Plaintiff occurred, and seeks more definite statement as to C.L.'s
date of birth so he can determine when she was no longer a minor. Plaintiffs complaint
fails to state even these rudimentary facts. As discussed more fully below herein, when
EPSTEIN's alleged conduct involving C.L. occurred determines what version of 18
U.S.C. §2255 applies to this action.
To be clear, Defendant recognizes that pursuant to the NPA (Non-Prosecution
Agreement) he cannot challenge the standing of Plaintiff to bring an action exclusively
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Case 9:10-cv-80447-KAM Document 5 Entered on FLSD Docket 05/03/2010 Page 2 of 22
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