Epstein Secrets

ment 31 Entered on FLSD Docket 06/01/2009 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CIV- 80469 - MARRA/JOHNSON JANE DOE II, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY TO & MOTION TO STRIKE PORTIONS OF PLAINTIFF'S MEMORANDUM OF L

Motion To Dismiss, dated May 22, 2009, MOLT Accordingly, Defendant states: I. Legal Standard (pp. 1-2 of Plaintiff's MOLI Plaintiff's reliance on Conley v. Gibson, 355 U.S. 41, 45-46 (1957), as the Rule 12(b)(6) pleading standard is misplaced. As discussed in Defendant's motion to dismiss, (pp. 16 — 17), the

per acts by BoA. To the extent Mr. Steadman's claims are predicated on such acts, rather than on Green Tree's acts, they are not viable. 2 See also Johnson v. Fed Home Loan Mort. Corp.. No. C12-1712 TSZ. 2013 U.S. Dist. LEXIS 10485. 2013 WL 308957. at '4 (W.D. Wash. Jan. 25. 2013) ("IAN assignee is liab

t Rule l3(a)(2) requires that the pleading "'give the defendant fair notice of what the . . . claim is and the grounds upon which it rests" (quoting Conley v. Gibson. 355 U.S. 41. 47. 78 S. Ct. 99.2 L. Ed. 2d 80 (1957))). B. The Plaintiffs claims against BIC are properly asserted in tort. BIC argues that all cl

ocument 19 Entered on FLSD Docket 02/27/2009 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08- 80993-CIV-MARRA/JOHNSON JANE DOE NO. 7, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. AMENDED COMPLAINT Plaintiff, Jane Doe No. 7 ("Jane" or "Jane Doe"), brings this Com

ion To Dismiss, dated May 22, 2009, ("MOL"). Accordingly, Defendant states: I. Legal Standard (pp. 1-2 of Plaintiff's MOLI Plaintiff's reliance on Conley v. Gibson, 355 U.S. 41, 45-46 (1957), as the Rule 12(b)(6) pleading standard is misplaced. As discussed in Defendant's motion to dismiss, (pp. 16 - 17), the