Epstein Secrets

acility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to per

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

acility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to per

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

acility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to per

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

acility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to per

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

acility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States v. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to per

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

facility (the mail, phone, or intemet)—not thereafter—and the scienter element must be present while the facility is being used. See United States'. Murrell, 368 F.3d 1283, 1286 (11th Cir. 2004) ("[T]he government must first prove that [Defendant], using the Internet, acted with a specific intent to per

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