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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
the removal of language from draft legislation as proof that the enacted bill carried the same meaning. Instead, courts draw the opposite inference. Russello 464 U.S. at 23-24 ("Where Congress includes limiting language in an earlier version of a bill but deletes it prior to enactment, it may be presumed tha
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
the removal of language from draft legislation as proof that the enacted bill carried the same meaning. Instead, courts draw the opposite inference. Russello 464 U.S. at 23-24 ("Where Congress includes limiting language in an earlier version of a bill but deletes it prior to enactment, it may be presumed tha
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
the removal of language from draft legislation as proof that the enacted bill carried the same meaning. Instead, courts draw the opposite inference. Russello 464 U.S. at 23-24 ("Where Congress includes limiting language in an earlier version of a bill but deletes it prior to enactment, it may be presumed tha
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
the removal of language from draft legislation as proof that the enacted bill carried the same meaning. Instead, courts draw the opposite inference. Russello 464 U.S. at 23-24 ("Where Congress includes limiting language in an earlier version of a bill but deletes it prior to enactment, it may be presumed tha
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
the removal of language from draft legislation as proof that the enacted bill carried the same meaning. Instead, courts draw the opposite inference. Russello 464 U.S. at 23-24 ("Where Congress includes limiting language in an earlier version of a bill but deletes it prior to enactment, it may be presumed tha
Entities connected to both the First Amended Complaint and Russello 464

Jeffrey Epstein
PERSONLeon Black
PERSON
United States
LOCATION
H.R.
PERSON
George W. Bush
PERSON
Oliver Stone
PERSONJack Goldberger
PERSONHansen
PERSON
Mortensen
PERSON
Searcy
PERSON
Estelle
PERSONSiljander
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alfredo Rodriguez
PERSON
John Kerry
PERSONEvans
PERSON
Supreme Court
ORGANIZATION
Bowen
PERSON
Schumer
PERSON