Epstein Secrets

E DOE NO. 7 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS & FOR MORE DEFINITE STATEMENT DIRECTED TO PLAINTIFF JANE DOE NO.7'S COMPLAINT Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves to dismiss and for more definite statement of Plaintiff

egal conclusion couched as a factual allegation"). Factual allegations must be enough to raise a right to relief above the speculative level, see 5 C. Wright & A. Miller Federal Practice and Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller) C[T]he pleading must contain something more ... than ... a statement o

ant is filing similar motions to dismiss and for more definite statement directed to the Amended Complaints filed against Defendant in this Court in JANE DOE NO. 2, JANE DOE NO. 3, JANE DOE NO. 4 and JANE DOE NO. 5. The motions are directed to the Counts for "Sexual Assault and Battery," and "Coercion an

egal conclusion couched as a factual allegation"). Factual allegations must be enough to raise a right to relief above the speculative level, see 5 C. Wright & A. Miller Federal Practice and EFTA00221997 Case 9:08-cv-80119-KAM Document 46 Entered on FLSD Docket 10/06/2008 Page 4 of 10 Case No. CV-80119-Marra-Johnson Page No. 4

tted willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 26. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had

egal conclusion couched as a factual allegation"). Factual allegations must be enough to raise a right to relief above the speculative level, see 5 C. Wright & A. Miller Federal Practice and EFTA00222746 Case 9:08-cv-80119-KAM Document 46 Entered on FLSD Docket 10/06/2008 Page 4 of 10 Case No. CV-80119-Marra-Johnson Page No. 4