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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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