Epstein Secrets

ectfully requests tha ourt grants his motion directed to Plaintiff's Amended Complaint. By: ROBERT D. CRITTBN, JR., ESQ. Florida Bar No. 224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of th

4) (a well-pleaded complaint may proceed even if it appears "that a recovery is very remote and unlikely"). b. More Definite Statement, Pleading, & Motion to Strike Next, Pursuant to Rule 12(e), a party may move for more definite statement of a pleading to which a responsive pleading is allowed where

se 9:08-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 18 of 21 C.M.A. v. Epstein, et al. Page 18 WOW Respectfully su tted, MICHAEL J. PIKE, ESQ. Florida Bar #617296 BURMAN CRITTON, JR., ESQ. 4162 RITT • k ■ • s llen COLEMAN (Counsel for Defendant Jeffrey Epstein) ' ENDNOTE: U

o render [the element] plausible." Watts 495 F.3d at 1296 (quoting Twombly, 127 S.Ct. at 1965). II. Standard for More Definite Statement, Pleading, & Motion to Strike Pursuant to Rule 12(e), a party may move for more definite statement of a pleading to which a responsive pleading is allowed where the pl

te act relied upon. WHEREFORE, Defendant respectfully requests that this Court dismiss Plaintiffs entire action. By: ROBERT D RITTON, JR., ESQ. MICHAEL J. PIKE, ESQ. EFTA00222838 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 27 of 29 Jane Doe II v. Epstein, et al. Page 27

statute in effect at the time of the alleged conduct. 18 U.S.C. §2255 (2005). Ill. Standard - Motion To Dismiss, More Definite Statement. Pleading, & Motion to Strike As established by the Supreme Court in Bell Atlantic Corp. V. Twombly, 127 S.Ct. 1955 (2007), a motion to dismiss should be granted if th