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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.
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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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Case 9:10-cv-80309-KAM Document 14 Entered on FLSD Docket 04/05/2010 Page 2 of 15
Supporting Memorandum of Law
Principles of Statutory Interpretation
It is well settled that in interpreting a statute, the cour
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