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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
this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De
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
this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De
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
this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De
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
this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De
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
this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De
Entities connected to both the First Amended Complaint and Fernandez-Montes

Jeffrey Epstein
PERSONLeon Black
PERSONJack Goldberger
PERSON
George W. Bush
PERSON
Alfredo Rodriguez
PERSON
United States
LOCATION
Oliver Stone
PERSON
John Kerry
PERSONEvans
PERSONSiljander
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
H.R.
PERSON
Schumer
PERSON
Corley
PERSON
Green
PERSONCalder
ORGANIZATIONEllis
PERSON
Masha Drokova
PERSONGustafson
PERSON