Epstein Secrets

rida Statute 796.09. Defendant seeks dismissal of Counts II and IV of the Amended Complaint or, alternatively, moves for a more definite statement. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), a court must accept all factual allegations in a complaint as

ept all factual allegations in a complaint as true and take them in the light most 1 EFTA00728574 Case 9:08-cv-80893-KAM Document 125 Entered on FLSD Docket 03/0312010 Page 2 of 10 favorable to the plaintiff. See Erickson v. Pardus, 551 U.S. 89, 94 (2007). To satisfy the pleading requirements of Federal

et 12/10/2009 Page 6 of 9 provide Defendant with sufficient notice of the underlying factual bases for the claims raised in the thirty-one counts. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), a court must accept all factual allegations in a complaint as

pstein; and Count XXXII - Conspiracy to Commit Tortious Assault Against Defendant 1 EFTA00731326 Case 9:08-cv-80811-KAM Document 168 Entered on FLSD Docket 12/10/2009 Page 2 of 9 The facts, as alleged in the Amended Complaint, are as follows: At all relevant times, Defendant was an adult male, born in

joined to the action. As such, Plaintiff asserts that complete diversity does not exist, and this Court does not have jurisdiction over this case. Standard of Review A defendant may remove any civil action brought in a state court over which a federal court would also have original jurisdiction. 28 U.S.C. § 1441

for monetary compensation. (Am. Compl. ¶ 13). brought Plaintiff to Epstein's mansion 2 EFTA00175528 Case 9:08-ov-80004-KAM Document Entered . FLSD Docket 10/03/2„8 Page 3 of 8 in Palm Beach. (Am. Compl. ¶ 13). Plaintiff was introduced to a, who led her up the stairs to the room with the massage tab

orida Statute 796.09. Defendant seeks dismissal of Counts H and IV of the Amended Complaint or, alternatively, moves for a more definite statement. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(bX6), a court must accept all factual allegations in a complaint as

is 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 10 (explaining "only a complaint that states a plausible claim for relief survives a motion to dismiss"). Rule 12(e) permits

orida Statute 796.09. Defendant seeks dismissal of Counts H and IV of the Amended Complaint or, alternatively, moves for a more definite statement. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(bX6), a court must accept all factual allegations in a complaint as

is 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 10 (explaining "only a complaint that states a plausible claim for relief survives a motion to dismiss"). Rule 12(e) permits