Epstein Secrets

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

time of the underlying conduct unless there is a clear statement that an amendment should apply retroactively to pre-enactment conduct. See, e.g., Hughes Aircraft Co. v. United States ex rel. Schumer, 520 U.S. 939, 952 (1997) ("Given the absence of a clear statutory expression of congressional intent to apply the

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

time of the underlying conduct unless there is a clear statement that an amendment should apply retroactively to pre-enactment conduct. See, e.g., Hughes Aircraft Co. v. United States ex rel. Schumer, 520 U.S. 939, 952 (1997) ("Given the absence of a clear statutory expression of congressional intent to apply the

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

time of the underlying conduct unless there is a clear statement that an amendment should apply retroactively to pre-enactment conduct. See, e.g., Hughes Aircraft Co. v. United States ex rel. Schumer, 520 U.S. 939, 952 (1997) ("Given the absence of a clear statutory expression of congressional intent to apply the

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

time of the underlying conduct unless there is a clear statement that an amendment should apply retroactively to pre-enactment conduct. See, e.g., Hughes Aircraft Co. v. United States ex rel. Schumer, 520 U.S. 939, 952 (1997) ("Given the absence of a clear statutory expression of congressional intent to apply the

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

time of the underlying conduct unless there is a clear statement that an amendment should apply retroactively to pre-enactment conduct. See, e.g., Hughes Aircraft Co. v. United States ex rel. Schumer, 520 U.S. 939, 952 (1997) ("Given the absence of a clear statutory expression of congressional intent to apply the