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ng "the need for Congress to take effective action to protect children and families front online harm") (emphasis added); see also United States v. Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005) (noting that Congress enacted § 2422(b) "after the Senate Judiciary Committee held a hearing regarding child
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
ng "the need for Congress to take effective action to protect children and families front online harm") (emphasis added); see also United States v. Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005) (noting that Congress enacted § 2422(b) "after the Senate Judiciary Committee held a hearing regarding child
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
ng "the need for Congress to take effective action to protect children and families front online harm") (emphasis added); see also United States v. Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005) (noting that Congress enacted § 2422(b) "after the Senate Judiciary Committee held a hearing regarding child
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
ng "the need for Congress to take effective action to protect children and families front online harm") (emphasis added); see also United States v. Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005) (noting that Congress enacted § 2422(b) "after the Senate Judiciary Committee held a hearing regarding child
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
ng "the need for Congress to take effective action to protect children and families front online harm") (emphasis added); see also United States v. Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005) (noting that Congress enacted § 2422(b) "after the Senate Judiciary Committee held a hearing regarding child
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
sing "the need for Congress to take effective action to protect children and families from online harm") (emphasis added); see also United States'. Searcy, 418 F.3d 1193, 1197 (Ilth Cir. 2005) (noting that Congress enacted § 2422(b) "after the Senate Judiciary Committee held a hearing regarding child
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
Entities connected to both Searcy and the First Amended Complaint

Jeffrey Epstein
PERSONJack Goldberger
PERSON
George W. Bush
PERSONJane Doe
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONMurrell
PERSONEvans
PERSON
Supreme Court
ORGANIZATION
United States District Court
ORGANIZATION
Alfredo Rodriguez
PERSONThe Eleventh Circuit's
ORGANIZATION
Ashcroft
PERSON
Griffith
PERSONRobert D. Critton
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Oliver Stone
PERSON