Epstein Secrets

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

laintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleade

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

laintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleade

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

laintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleade

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

laintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleade

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

laintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleade

IM G., the first victim identified in PBPD's investigation. Plaintiff filed motion to remand to state court, which was granted by Judge Marra. 2. Jane Doe #2I. Epstein, 08-CV-80 I 19-KAM: Complaint filed on February 6, 2008, alleging: sexual assault (Count l), and intentional infliction of emotional di

laintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleade