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Case 9:10-cv-80309-KAM Document 14 Entered on FLSD Docket 04/05/2010 Page 1 of 15




                           UNITED STATES DISTRICT COURT
                           SOUTHERN DISTRICT OF FLORIDA

                                   CASE NO. 10-80309-CIV-

     JANE DOE No. 103,

                            Plaintiff,
     vs.

     JEFFERY EPSTEIN,

                            Defendant.
     ------------~/
               DEFENDANT EPSTEIN'S MOTION TO DISMISS.COUNT VI &
                  FOR MORE DEFINITE STATEMENT & TO STRIKE
                   DIRECTED TO PLAINTIFF JANE DOE NO. 103'S
                          COMPLAINT (dated 2/23/2010)

             Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned

      counsel, moves to dismiss Count Six of Plaintiff JANE DOE 103's Complaint for failure

      to state a cause of action, as specified herein. Rule 12(b)(6), Fed.R.Civ.P. (2009); Local

      Gen. Rule 7.1 (S.D. Fla. 2009). Defendant further moves for More Definite Statement

      and to Strike. Rule 12(e) and (f), In support of his motion, Defendant states:

           The Complaint attempts to allege 6 counts, all of which are purportedly brought

      pursuant to 18 U.S.C. §2255-Civil Remedies for Personal Injuries. Count Six is subject

      to dismissal because the predicate act relied upon by Plaintiff for her claims did not come

      into effect until July 27, 2006, well after the conduct alleged by Plaintiff occurred. The

      More Definite Statement requested is for Plaintiff to allege her date of birth in that her

      being a minor has significance in the claims she alleges.




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                                  Supporting Memorandum of Law

                                 Principles of Statutory Interpretation

            It is well settled that in interpreting a statute, the cour

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