Epstein Secrets

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

STATEMENT Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states: Pleading Standard & Summary of Argument T

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

STATEMENT Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states: Pleading Standard & Summary of Argument T

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

STATEMENT Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states: Pleading Standard & Summary of Argument T

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

STATEMENT Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states: Pleading Standard & Summary of Argument T

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

STATEMENT Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states: Pleading Standard & Summary of Argument T

Page 28 of 36 the same act are intended to have the same meaning.") (quotation and citation omitted). Two Mann Act cases are particularly apt. In Hansen', Half, 291 U.S. 559 (1934), the Government charged the defendant with violating the Mann Act after she returned to the country with a man with who

STATEMENT Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states: Pleadine Standard & Summary of Areument T