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Case 9:09-cv-80591-KAM Document 53 Entered on FLSD Docket 06/12/2009 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-CIV- 80591- KAM
JANE DOE NO. 101,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
I
DEFENDANT JEFFREY EPSTEIN'S NOTICE OF WITHDRAWL OF ARGUMENTS I
THROUGH VII OF THE DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S FIRST
AMENDED COMPLAINT (DE29)
Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, hereby
withdraws arguments I through VII as set forth in the Defendant's Motion to Dismiss the
Plaintiff's First Amended Complaint (FAC) [DE 29], dated May 26, 2009. Defendant withdraws
his arguments contained subparagraphs A, B, C and Sections I (The Complaint Must Be
Dismissed Because Plaintiff Is Not A Minor), II (The FAC Must Be Dismissed Because The
Defendant Has Not Been Convicted Of A Predicate Offense), III (Count One Of The FAC Must
Be Dismissed Because It Does Not Please A Violation Of 18 U.S.C. § 2422(b)), IV (Count Two
Must Be Dismissed Because It Does Not Plead A Violation Of 18 U.S.C. §2423(b)), V (Count
Three Must Be Dismissed Because It Does Not Plead A Violation Of 18 U.S.C. § 2251, VI
(Counts Four and Five Must Be Dismissed Because They Do Not Plead Violation of 18 U.S.C.
§§ 2252(a)(l) Or 2252(a)(l), and VII (Count Six Must Be Dismissed Because 18 U.S.C. §
2252A(g) Was Not Enacted Until 2006).
Defendant will rely only on those arguments set forth in subparagraph D, on page 3, and
Paragraph VIII (Any Surviving Count Should Be Merged Into A Single Count) of the
Case 9:09-cv-80591-KAM Document 53 Entered on FLSD Docket 06/12/2009 Page 2 of 2
Defendant's Motion to Dismiss the First Amended Complaint Or, In The
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