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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
Page 28 of 36 the same act are intended to have the same meaning.") (quotation and citation omitted). Two Mann Act cases are particularly apt. In Hansen v. Half, 291 U.S. 559 (1934), the Government charged the defendant with violating the Mann Act after she returned to the country with a man with whom she w
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
Page 28 of 36 the same act are intended to have the same meaning.") (quotation and citation omitted). Two Mann Act cases are particularly apt. In Hansen v. Half, 291 U.S. 559 (1934), the Government charged the defendant with violating the Mann Act after she returned to the country with a man with whom she w
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
Page 28 of 36 the same act are intended to have the same meaning.") (quotation and citation omitted). Two Mann Act cases are particularly apt. In Hansen v. Half, 291 U.S. 559 (1934), the Government charged the defendant with violating the Mann Act after she returned to the country with a man with whom she w
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
Page 28 of 36 the same act are intended to have the same meaning.") (quotation and citation omitted). Two Mann Act cases are particularly apt. In Hansen v. Half, 291 U.S. 559 (1934), the Government charged the defendant with violating the Mann Act after she returned to the country with a man with whom she w
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
Page 28 of 36 the same act are intended to have the same meaning.") (quotation and citation omitted). Two Mann Act cases are particularly apt. In Hansen v. Half, 291 U.S. 559 (1934), the Government charged the defendant with violating the Mann Act after she returned to the country with a man with whom she w
Entities connected to both the First Amended Complaint and Hansen v. Half

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