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Case 9:09-cv-81092-KAM Document 20 Entered on FLSD Docket 06/16/2010 Page 1 of 6
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-CIV-81092- MARRNJOHNSON
L.M.,
Plaintiff,
V.
JEFFREY EPSTEIN,
Defendants.
I
EPSTEIN'S MOTION TO DISMISS COMPLAINT
AND INCORPORATED MEMORANDUM OF LAW
Defendant, JEFFREY EPSTEIN ("Epstein") pursuant to Fed. R. Civ. P. 4(m), moves to
dismiss the Complaint (DE #1) filed by Plaintiff, L.M. due to her failure to serve the Complaint
on Epstein within the time specified in Rule 4(m), and states:
I. On July 24, 2009, L.M. filed a two hundred thirty-four (234) page, one hundred
fifty-six (156) count Complaint (DE#!) against Epstein.
2. Each of the one hundred fifty-six (I 56) counts is a separate cause of action pursuant
to 18 U.S.C. §2255.
3. The Complaint was filed by Bradley J. Edwards while he was employed by the now
defunct Rothstein, Rosenfeldt & Adler firm.
4. However, this Complaint served no legal purpose whatsoever in that at the time the
Complaint was filed LM had a pending state court action (which is still currently pending) seeking
damages under theories other than the exclusive remedies in 18 U.S.C. §2255. See L.M. v. Jeffrey
Epstein, Case No. 502008CA028051XXXXMB in the Fifteenth Judicial Circuit in and for Palm
Beach County, Florida.
Case 9:09-cv-81092-KAM Document 20 Entered on FLSD Docket 06/16/2010 Page 2 of 6
L.M. v. Epstein
Case No. 09-CIV-81092-Marra/Johnson
Page 2
5. This Complaint was never served on Epstein within the time required by Fed. R. Civ.
P. 4(m) and should therefore be dismissed. Epstein files this motion
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