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ssumption that all of the complaint's allegations are true." Id. Plaintiff must plead enough facts to state a plausible basis for the claim. Id. See Ashcroft v. lqbal, 129 S.Ct. 1937, 1950 2 EFTA00728575 Case 9:08-cv-80893-KAM Document 125 Entered on FLSD Docket 03/03/2010 Page 3 of 10 (explaining "o
nterprise must be "free to act independently and advance [their] own interests contrary to those of the other" enterprise members. United States v. Goldin Industries, Inc., 219 F.3d 1271-1276-77 (I Cir. 2000). In this case, Plaintiff alleges that Epstein directed his "underlings" to procure young girls for his own se
ssumption that all of the complaint's allegations are true." Id. Plaintiff must plead enough facts to state a plausible basis for the claim. Id. See Ashcroft v. labal 129 S.Ct. 1937, 1950 2 EFTA_R1_00012687 EFTA01734467 Case 9:08-cv-80893-KAM Document 125 Entered on FLSD Docket 03/0312010 Page 3 of 1
nterprise must be "free to act independently and advance [their] own interests contrary to those of the other" enterprise members. United States v. Goldin Industries, Inc., 219 F.3d 1271-1276-77 (11th Cir. 2000). In this case, Plaintiff alleges that Epstein directed his "underlings" to procure young girls for his own
ssumption that all of the complaint's allegations are true." Id. Plaintiff must plead enough facts to state a plausible basis for the claim. Id. See Ashcroft v. labal 129 S.Ct. 1937, 1950 2 EFTA_R1_02213295 EFTA02725752 Case 9:08-cv-80893-KAM Document 125 Entered on FLSD Docket 03/0312010 Page 3 of 1
nterprise must be "free to act independently and advance [their] own interests contrary to those of the other" enterprise members. United States v. Goldin Industries, Inc., 219 F.3d 1271-1276-77 (11th Cir. 2000). In this case, Plaintiff alleges that Epstein directed his "underlings" to procure young girls for his own
Entities connected to both Ashcroft and Goldin Industries, Inc.

Jeffrey Epstein
PERSON
United States
LOCATION
Anderson
PERSON
George W. Bush
PERSONJane Doe
PERSONTwombly
PERSONBell Atlantic Corp.
ORGANIZATION
Kenneth Marra
PERSONthe Eleventh Circuit
ORGANIZATION
Oliver Stone
PERSON
Murphy
PERSONGibson
PERSONConley
PERSONFLSD Docket
ORGANIZATIONthe Florida Supreme Court
ORGANIZATION
the United States Supreme Court
ORGANIZATION
the Fifth Circuit
ORGANIZATIONChambers
PERSONTenet Healthcare Corp.
ORGANIZATIONTurkette
PERSON