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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
merely 17 years old."). Plaintiff is bound by that admission, and the FAC must be dismissed with prejudice. Best Canvas Prods. & Supplies, Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618, 621 (11th Cir. 1983) ("[A] party is bound by the admissions in his pleadings."). B. Nor is Plaintiff the "victim of a violation
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
merely 17 years old."). Plaintiff is bound by that admission, and the FAC must be dismissed with prejudice. Best Canvas Prods. & Supplies, Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618, 621 (11th Cir. 1983) ("[A] party is bound by the admissions in his pleadings."). B. Nor is Plaintiff the "victim of a violation
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
merely 17 years old."). Plaintiff is bound by that admission, and the FAC must be dismissed with prejudice. Best Canvas Prods. & Supplies, Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618, 621 (11th Cir. 1983) ("[A] party is bound by the admissions in his pleadings."). B. Nor is Plaintiff the "victim of a violation
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
merely 17 years old."). Plaintiff is bound by that admission, and the FAC must be dismissed with prejudice. Best Canvas Prods. & Supplies, Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618, 621 (11th Cir. 1983) ("[A] party is bound by the admissions in his pleadings."). B. Nor is Plaintiff the "victim of a violation
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
merely 17 years old."). Plaintiff is bound by that admission, and the FAC must be dismissed with prejudice. Best Canvas Prods. & Supplies, Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618, 621 (11th Cir. 1983) ("[A] party is bound by the admissions in his pleadings."). B. Nor is Plaintiff the "victim of a violation
Entities connected to both the First Amended Complaint and Ploof Truck Lines.

Jeffrey Epstein
PERSON
George W. Bush
PERSONJane Doe
PERSONJack Goldberger
PERSONLeon Black
PERSON
Oliver Stone
PERSON
John Kerry
PERSONEvans
PERSON
Supreme Court
ORGANIZATIONHansen
PERSON
Mortensen
PERSON
Searcy
PERSON
Estelle
PERSON
H.R.
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alfredo Rodriguez
PERSON
United States
LOCATION
Bowen
PERSON
Schumer
PERSON