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Case 9:09-cv-80591-KAM Document 56 Entered on FLSD Docket 06/26/2009 Page 1 of 10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARRA/JOHNSON
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
I
PLAINTIFF JANE DOE NO. lOl'S RESPONSE TO DEFENDANT'S
;MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT AS MODIFIED
BY DEFENDANT'S NOTICE OF WITHDRAWAL OF ARGUMENTS I THROUGH VII
OF DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED
COMPLAINT
Plaintiff, Jane Doe No. 101, by and through her undersigned attorneys, hereby responds
to Defendant's Motion to Dismiss Plaintiffs First Amended Complaint [D.E. 29] ("Motion"), as
modified by Defendant's Notice of Withdrawal [D.E. 53] ("Notice of Withdrawal") of
Arguments I Through VII of Defendant's Motion to Dismiss Plaintiffs First Amended
Complaint and, as grounds, states as follows:
Pleading Standard & Summary of Argument
It is well settled in the context of a civil action that a valid complaint requires only "a short and
plain statement of the claim showing that the pleader is entitled to relief." Fed. R. Civ. P.
8(a)(2). Defendant improperly attempts to heighten this standard through his characterization of
this action as one that is essentially criminal and punitive in nature. Such a characterization is
inappropriate, as this is a civil action that seeks only compensatory damages for the violation of
certain of the predicate offenses of Section 2255 of Title 18 of the U.S. Code as set forth in the
Podhurst Orseck, P.A.
25 West Flagler Street, S
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