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Case 9:10-cv-80309-KAM Document 15 Entered on FLSD Docket 04/12/2010 Page 1 of 4
UN1TED 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 AMEND DEFENDANT'S
MOTION TO DISMISS. & FOR MORE DEFINITE STATEMENT &
STRIKE DIRECTED TO PLAINTIFF JANE DOE NO. 103'S
COMPLAINT (dated 4/5/2010)
Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned
counsel, moves to amend by his previously filed Motion To Dismiss, & Motion For More
Definite Statement & Strike Directed To Plaintiff JANE DOE I 03 's Complaint,
(hereinafter "Motion To Dismiss"), dated and filed April 5, 2010. In support of his
motion, Defendant states:
1. On April 5, 2010, Defendant previously filed with this Court his Motion To
Dismiss. Defendant seeks dismissal of Count VI, which is brought pursuant to 18 U.S.C.
§2255, because Plaintiff is relying on a criminal predicate act enumerated in §2255 that
did not come into effect until after the alleged time period of the alleged conduct by
Defendant involving Plaintiff. I 8 U.S.C. §2252A(g), the criminal statute relied upon by
Plaintiff in attempting to assert her §2255 claim in Count VI, was not enacted until 2006;
the allegedly violative conduct by Defendant occurred, according to Plaintiffs own
Case 9:10-cv-80309-KAM Document 15 Entered on FLSD Docket 04/12/2010 Page 2 of 4
allegations, beginning in January 2004 until approximately May 2005. As argued in
Defendant's motion to dismiss, Count VI is required to be dismissed because it violates
the constitutiona
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