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use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
Atlantic Corp. supra at 1664-65: While a complaint attacked by a Rule 12(b)(6) moti to dismiss does not need detailed factual allegations, ibid.; Saniva . American Bd. of Psychiatry and Neuroloay. Inc. 40 F.3d 247, 251 .7 1994), a plaintiffs obligation to provide the "grounds" of his "entitle[ment
use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
l Atlantic Corp. supra at 1664-65: While a complaint attacked by a Rule 12(b)(6) moti to dismiss does not need detailed factual allegations ibid.• Saniva American Bd. of Psychiatry and Neurology. Inc. 40 F.3d 247, 251 .7 1994), a plaintiffs obligation to provide the "grounds" of his "entitle[ment]
use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
Atlantic Corp., supra at 1664-65: While a complaint attacked by a Rule 12(b)(6) moti to dismiss does not need detailed factual allegations ibid.; Saniva . American Bd. of Psychiatry and Neurology. Inc. 40 F.3d 247, 251 .7 1994), a plaintiffs obligation to provide the "grounds" of his "entitle[ment
Entities connected to both the State of New York and Saniva

Jeffrey Epstein
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONRobert D. Critton
PERSON
Virginia Giuffre
PERSONSouthern District
LOCATION
Adam D. Horowitz
PERSON
Supreme Court
ORGANIZATIONMichael J. Pike
PERSON
Wilbur Ross
PERSONFL Bar No.
ORGANIZATIONFiler
PERSONHerman & Mermelstein, P.A.
ORGANIZATION
United States District Court
ORGANIZATIONStuart S. Mermelstein
PERSON
Jeffrey Marc Herman
PERSONthe Commonwealth of Virginia
LOCATION