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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
nt must be dismissed "where the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct") (emphasis added); Bawa v. U.S., No. C 07- 00200 WHA, 2007 WL 1456040, *5 (N.D. Cal. May 17, 2007) (dismissing complaint alleging that defendant "may have played a substantial role
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
nt must be dismissed "where the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct") (emphasis added); Bawa v. U.S., No. C 07- 00200 WHA, 2007 WL 1456040, *5 (N.D. Cal. May 17, 2007) (dismissing complaint alleging that defendant "may have played a substantial role
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
nt must be dismissed "where the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct") (emphasis added); Bawa v. U.S., No. C 07- 00200 WHA, 2007 WL 1456040, *5 (N.D. Cal. May 17, 2007) (dismissing complaint alleging that defendant "may have played a substantial role
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
nt must be dismissed "where the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct") (emphasis added); Bawa v. U.S., No. C 07- 00200 WHA, 2007 WL 1456040, *5 (N.D. Cal. May 17, 2007) (dismissing complaint alleging that defendant "may have played a substantial role
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
nt must be dismissed "where the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct") (emphasis added); Bawa v. U.S., No. C 07- 00200 WHA, 2007 WL 1456040, *5 (N.D. Cal. May 17, 2007) (dismissing complaint alleging that defendant "may have played a substantial role
Entities connected to both the First Amended Complaint and Bawa v. U.S.

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