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Case 9:10-cv-80309-KAM Document 15-1 Entered on FLSD Docket 04/12/2010 Page 1 of 16
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 10-80309-CIV-
JANE DOE No. 103,
Plaintiff,
vs.
JEFFERY EPSTEIN,
Defendant.
I
DEFENDANT EPSTEIN'S AMENDED 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, files this Amended Motion To Dismiss Count VI, & Motion For More Definite
Statement & Strike Directed To Plaintiff JANE DOE I 03 's Complaint. Defendant 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/or 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.
Case 9:10-cv-80309-KAM Document 15-1 Entered on FLSD Docket 04/12/2010 Page 2 of 16
Supporting Memorandum of Law
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