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e accepted as true, the alleged "enterprise" would clearly not act independently of Epstein, the RICO Defendant. See Boca Raton Comm. Hosp. Inc. v. Tenet Healthcare Corp. 502 F.Supp.2d 1237, 1253 (S.D. Fla.2007) (the key to "distinctiveness" depends less on whether the enterprise members are separate in the legal sen
tion to dismiss or for more definite statement of Count II is DENIED. Count IV - Civil Remedy for Criminal Practices Count IV alleges a claim under the Florida Civil Remedies for Criminal Practices Act, Fla. Stat. 772.104(1) and (2) ("Florida RICO"). These sections state as follows: (I) Any person who proves by clear and convincing evidence that h
accepted as true, the alleged "enterprise" would clearly not act independently of Epstein, the RICO Defendant. See Boca Raton Comm. Hosp.. Inc. v. Tenet Healthcare Corp., 502 F.Supp.2d 1237, 1253 (S.D. Fla.2007) (the key to "distinctiveness" depends less on whether the enterprise members are separate in the legal se
tion to dismiss or for more definite statement of Count II is DENIED. Count IV - Civil Remedy for Criminal Practices Count IV alleges a claim under the Florida Civil Remedies for Criminal Practices Act, Fla. Stat. 772.104(1) and (2) ("Florida RICO"). These sections state as follows: (1) Any person who proves by clear and convincing evidence that h
accepted as true, the alleged "enterprise" would clearly not act independently of Epstein, the RICO Defendant. See Boca Raton Comm. Hosp.. Inc. v. Tenet Healthcare Corp., 502 F.Supp.2d 1237, 1253 (S.D. Fla.2007) (the key to "distinctiveness" depends less on whether the enterprise members are separate in the legal se
tion to dismiss or for more definite statement of Count II is DENIED. Count IV - Civil Remedy for Criminal Practices Count IV alleges a claim under the Florida Civil Remedies for Criminal Practices Act, Fla. Stat. 772.104(1) and (2) ("Florida RICO"). These sections state as follows: (1) Any person who proves by clear and convincing evidence that h
Entities connected to both Tenet Healthcare Corp. and the Florida Civil Remedies for Criminal Practices Act

Jeffrey Epstein
PERSON
United States
LOCATION
Kenneth Marra
PERSON
the United States Supreme Court
ORGANIZATION
Ashcroft
PERSONTwombly
PERSONthe Florida Supreme Court
ORGANIZATIONBell Atlantic Corp.
ORGANIZATIONJane Doe
PERSONTurkette
PERSONChambers
PERSONGibson
PERSONConley
PERSON
Anderson
PERSONSorema N.A.
ORGANIZATION
Swierkiewicz
PERSONS.D. Fla.2007
LOCATIONthe Eleventh Circuit
ORGANIZATIONTexas Parks
LOCATIONBonner v. City of
LOCATION