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STATEMENT Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states: Pleading Standard & Summary of Argument T
"[T]he government must show that the criminal sexual act was a dominant purpose of the trip, not a merely incidental one.") (citing United States v. Hayward, 359 F.3d 631, 638 (3d Cir. 2004)) (emphasis added). That interpretation of the law is obviously correct. While § 2423(b) is relatively new—it firs
STATEMENT Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states: Pleading Standard & Summary of Argument T
"[T]he government must show that the criminal sexual act was a dominant purpose of the trip, not a merely incidental one.") (citing United States v. Hayward, 359 F.3d 631, 638 (3d Cir. 2004)) (emphasis added). That interpretation of the law is obviously correct. While § 2423(b) is relatively new—it firs
STATEMENT Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states: Pleading Standard & Summary of Argument T
"[T]he government must show that the criminal sexual act was a dominant purpose of the trip, not a merely incidental one.") (citing United States v. Hayward, 359 F.3d 631, 638 (3d Cir. 2004)) (emphasis added). That interpretation of the law is obviously correct. While § 2423(b) is relatively new—it firs
STATEMENT Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states: Pleading Standard & Summary of Argument T
"[T]he government must show that the criminal sexual act was a dominant purpose of the trip, not a merely incidental one.") (citing United States v. Hayward, 359 F.3d 631, 638 (3d Cir. 2004)) (emphasis added). That interpretation of the law is obviously correct. While § 2423(b) is relatively new—it firs
STATEMENT Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states: Pleading Standard & Summary of Argument T
"[T]he government must show that the criminal sexual act was a dominant purpose of the trip, not a merely incidental one.") (citing United States v. Hayward, 359 F.3d 631, 638 (3d Cir. 2004)) (emphasis added). That interpretation of the law is obviously correct. While § 2423(b) is relatively new—it firs
Entities connected to both the First Amended Complaint and Hayward

Jeffrey Epstein
PERSON
United States
LOCATIONEllis
PERSON
Mortensen
PERSONLeon Black
PERSON
Supreme Court
ORGANIZATIONGarcia-Lopez
PERSON
Jennifer Lopez
PERSON
Griffith
PERSONEvans
PERSON
George W. Bush
PERSONJane Doe
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSON
H.R.
PERSONMurrell
PERSON
Searcy
PERSON
Alfredo Rodriguez
PERSON
Scarlett Johansson
PERSONGustafson
PERSON