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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
any cases in which Congress has specified that a particular amendment applies in proceedings "commenced on or after the date of enactment," Tello v. Dean Witter Reynolds,. Inc., 410 F.3d 1275, 1283 (11th Cir. 2005) (collecting examples), Masha's Law was subject only to a standard effective date provision that sheds
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
any cases in which Congress has specified that a particular amendment applies in proceedings "commenced on or after the date of enactment," Tello v. Dean Witter Reynolds,. Inc., 410 F.3d 1275, 1283 (11th Cir. 2005) (collecting examples), Masha's Law was subject only to a standard effective date provision that sheds
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
any cases in which Congress has specified that a particular amendment applies in proceedings "commenced on or after the date of enactment," Tello v. Dean Witter Reynolds,. Inc., 410 F.3d 1275, 1283 (11th Cir. 2005) (collecting examples), Masha's Law was subject only to a standard effective date provision that sheds
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
any cases in which Congress has specified that a particular amendment applies in proceedings "commenced on or after the date of enactment," Tello v. Dean Witter Reynolds,. Inc., 410 F.3d 1275, 1283 (11th Cir. 2005) (collecting examples), Masha's Law was subject only to a standard effective date provision that sheds
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
any cases in which Congress has specified that a particular amendment applies in proceedings "commenced on or after the date of enactment," Tello v. Dean Witter Reynolds,. Inc., 410 F.3d 1275, 1283 (11th Cir. 2005) (collecting examples), Masha's Law was subject only to a standard effective date provision that sheds
Entities connected to both the First Amended Complaint and Dean Witter Reynolds

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