Epstein Secrets

ant Jeffrey Epstein Date Filed: 05/01/2009 Jury Demand: Plaintiff Nature of Suit: 360 P.I.: Other Jurisdiction: Federal Question represented by Katherine Warthen Ezell Podhurst Orseck Josefsberg et al City National Bank Building 25 W Flagler Street Suite 800 Miami FL 33130-1780 Fax: Email: LEAD ATTORNEY ATT

filed by Jane Doe No. 101.(Ezell, Katherine) (Entered: 05/01/2009) 05/01/2009 8 r 173 KB RESPONSE TO ORDER TO SHOW CAUSE by Jane Doe No. 101. (Ezell, Katherine) (Entered: 05/01/2009) 05/01/2009 9 ri 61.2 KB First AMENDED COMPLAINT and Demand For Jury Trial, filed by Jane Doe No. 101.(Ezell

e 6 of 7 Jane Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101, Jane Doe No. 102. Associated Cases: 9:08-cv-80119-KAM et al. (Ezell, Katherine) (Entered: 06/04/2009) 06/04/2009 28 ORDER STRIKING (112 in 9:08-cv-80381-ICAM, 111 in 9:08-cv-80232- KAM, 136 in 9:08-cv-80119-KAM, 11

and construed in the light most favorable to the plaintiff. M.T.V. v. DeKalb County Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006). In discussing Twombly the Eleventh Circuit in Watts v. Fla. International Univ., 495 F.3d 1289, 1295 (111h Cir. 2007), noted - "The Supreme Court's most recent formulati

egation in paragraph 15 as true, Plaintiff is not proceeding exclusively under §2255. Accordingly, under the standard of pleading as established in Twombly, supra, Plaintiff has failed to sufficiently allege the requisite elements of a §2255 claim, thus requiring dismissal for failure to state a cause

e to File Brief as Amicus Curiae in Support of Plaintiffs Reponse In Opposition to Defendant Jay Epstein's Motion to Dismiss by Jane Doe No. 101. (Ezell, Katherine) (Entered: 05/21/2009) 05/21/2009 98 2r .2 0 KB RESPONSE/REPLY to 89 Plaintiffs MOTION to Strike Z8 Reply to Response to Motion to

ant's Motion to Dismiss First Amended Complaint For Failure to State a Cause of Action and Motion for More Definite Statement by Jane Doe No. 101. (Ezell, Katherine) (Entered: 05/21/2009) 05/27/2009 99 NOTICE by Jane Doe re (111 in 9:08-cv-80119-KAM) Plaintiffs httns://ecf.flsd.uscourts.gov/cgi-bi

8-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 11 of 21 . v. Epstein, et al. 1111 the standard of pleading as established in Twombly, supra, Plaintiff has failed to sufficiently allege the requisite elements of a §2255 claim, thus requiring dismissal; for failure to state a cause

1683, 40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it appears "that a recovery is very remote and unlikely"). In discussing Twombly, the Eleventh Circuit in Watts v. Fla. International Univ., 495 F.3d 1289, 1295 (111h Cir. 2007), noted - "The Supreme Court's most recent formulat

of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsberg®podhurst.com kezell®p

t contain something more than a statement of facts that merely creates a suspicion of a legally cognizable right of action," Bell Atlantic Corp. v. Twombly, 550 U.S. 544. 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleading

of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsberg®podhurst.com kezell®p

t contain something more than a statement of facts that merely creates a suspicion of a legally cognizable right of action," Bell Atlantic Corp. v. Twombly, 550 U.S. 544. 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleading

of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsberg®podhurst.com kezell®p

t contain something more than a statement of facts that merely creates a suspicion of a legally cognizable right of action," Bell Atlantic Corp. v. Twombly, 550 U.S. 544. 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleading

f record identified on the following Service List in the manner specified by CM/ECF on this 26th day of May , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orsecic, P.A. 25 West Flagler Street, Suite 800 Fax• 105 15R-910 Counsellor Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldb

t contain something more than a statement of facts that merely creates a suspicion of a legally cognizable right of action," Bell Atlantic Corp. v. Twombly, 550 U.S. 544. 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleading

of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 [email protected] kezell@p

t contain something more than a statement of facts that merely creates a suspicion of a legally cognizable right of action," Bell Atlantic Corp. v. Twombly, 550 U.S. 544. 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleading

, and hereby demands trial by jury on all issues triable as of right by a jury. Date: April 17, 2009 C. 6-1 Robert C. Jose s re gt1tIo. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305)358-2382 (fax) riosefsberg@pod

a suspicion of a legally cognizable right of action,'" Hell Atlantic Corn. 1 Twomblv, 550 U.S. 544, 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleadings made in the context of an antitrust dispute," Ashcroft'. Iqbal No. 0

of 21 V. Consol Plaintiff Jane Doe No. 102 Como] Plaintiff Jane Doe No. 101 Consolrlabitiff Jane Doe 11 ATTORNEY TO BE NOTICED represented by Katherine Warthen Ezell Podhurst Orseck Josefsberg et al City National Bank Building 25 W Flagler Street Suite 800 Miami , FL 33130-1780 ax: Emai LEAD ATTORNEY TO B

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.'. Twombly, 127 S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead EFTA00175634 Case 9:08-cv-L .19-KAM Docuri... 1c 4