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Response to Motion, to Compel Answers to Interrogatories and Production of Documents by Jane Doe No. 4. (Attachments: # 1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/03/2009) 04/06/2009 71 Defendant's MOTION for Extension of Time to File Response as to 21 MOTION for Protective Order Agains
for failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has failed to allege sufficient factual allegations in the Counts and instead alleges labels and conclusions, and an attempted formulaic recitation of the elements in each Count. 2. In the alternative, Defendant s
Response to Motion, to Compel Answers to Interrogatories and Production of Documents by Jane Doe No. 3. (Attachments: # 1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/03/2009) 04/06/2009 61 Defendant's MOTION for Extension of Time to File Response as to $1 MOTION for Protective Order Agains
for failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has failed to allege sufficient factual allegations in the Counts and instead alleges labels and conclusions, and an attempted formulaic recitation of the elements in each Count. 2. In the alternative, Defendant s
Response to Motion, to Compel Answers to Interrogatories and Production of Documents by Jane Doe No. 5. (Attachments: # 1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/03/2009) 04/13/2009 73 Unopposed MOTION for Extension of Time to File Response /Memorandum in Opposition to Motion to Stay a
for failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has failed to allege sufficient factual allegations in the Counts and instead alleges labels and conclusions, and an attempted formulaic recitation of the elements in each Count. 2. In the alternative, Defendant s
to 62 Response to Motion, to Compel Answers to Interrogatories and Production of Documents by Jane Doe. (Attachments: # 1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/03/2009) 04/06/2009 71 Defendant's MOTION for Extension of Time to File Response as to 66 MOTION for Protective Order and t
for failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has failed to allege sufficient factual allegations in the Counts and instead alleges labels and conclusions, and an attempted formulaic recitation of the elements in each Count. 2. In the alternative, Defendant s
Entities connected to both Mermelstein and Counts

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSONRobert D. Critton
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSON
Jeffrey Marc Herman
PERSONRobert C. Josefsberg
PERSON
Scarlett Johansson
PERSON
George W. Bush
PERSONMichael J. Pike
PERSONSouthern District
LOCATIONHerman
PERSON
Wilbur Ross
PERSONthe Southern District
LOCATIONStuart
PERSON
Ghislaine Maxwell
PERSONMaria Farmer
PERSON
United States
LOCATION