Epstein Secrets

ton Luttier & Coleman 515 N Flagler Drive Suite 400 West Palm Beach , FL 33401-2918 Fax: 515-3148 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Robert Deweese Critton , Jr. Burman Critton Luttier & Coleman 515 N Flagler Drive Suite 400 s P Im Beach , FL 33401-2918 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NO

10/06/2008 41 Defendant's MOTION to Dismiss 3.7 Amended Complaint and for More Definite Statement by Jeffrey Epstein. Responses due by 10/24/2008 (Critton, Robert) (Entered: 10/06/2008) 10 `06%2008 42 MOTION for More Definite Statement directed to amended complaint by Jeffrey Epstein. See image DE 4

of her claims. Supporting Memorandum of Law Standard on Rule 12(b)(6) Motion To Dismiss As established by the Supreme Court in Bell Atlantic Corp. I. Twombly, 127 S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead "enough facts to state a claim to relief that is plau

10/06/2008 52 Defendant's MOTION to Dismiss 42 Amended Complaint and for More Definite Statement by Jeffrey Epstein. Responses due by 10/24/2008 (Critton, Robert) (Entered: 10/06/2008) 10/24/2008 53 Unopposed MOTION for Extension of Time to File Response as to 52 Defendant's MOTION to Dismiss 42 Am

09 Page 8 of 8 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Golc s i lber er Esq. Robert D. Critton. Es /s/ Adam D. Horowitz - 8 - EFTA00175866 Case 9:08-cv-8 11-KAM Document 71 Entered FLSD Docket 04 009 Page 1 of 7 UNITED STATES DISTRI

avorable to the plaintiff. . DeKalb County Sch. Dist. 446 F.3d 1153, 1156 (11th Cir.2006). Significantly, the Supreme Court in Bell Atlantic Corp. I. Twombly abrogated the often cited observation that "a complaint should not be dismissed for failure to state a claim unless it appears beyond doubt that th

2/2009 Page 20 of 20 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN CRITTON LUTTIER & COLEMAN, 515 N. Drive, Suite 400, West Palm Beach, Florida 33401 this 22nd day of May, 2009.

onley.. Gibson, 355 U.S. at 47. For a claim to state a cause of action however, facts, not labels and conclusions must be asserted. Bell Atl. Corp. I. Twombly 550 U.S. 544 (2007) II. ARGUMENT Point 1. Plaintiff has every right to proceed in State court for a Florida common law claim, and in this Court