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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
by one of Defendant's agents to give Defendant a massage for compensation," and that Defendant's agent "drove [Plaintiff] to [Defendant's] mansion." FAC S 18. After she allegedly was led to the massage room, the FAC alleges that a topless woman "with dark hair [and] an accent ... tried to coax Plaintiff
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
by one of Defendant's agents to give Defendant a massage for compensation," and that Defendant's agent "drove [Plaintiff] to [Defendant's] mansion." FAC S 18. After she allegedly was led to the massage room, the FAC alleges that a topless woman "with dark hair [and] an accent ... tried to coax Plaintiff
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
by one of Defendant's agents to give Defendant a massage for compensation," and that Defendant's agent "drove [Plaintiff] to [Defendant's] mansion." FAC S 18. After she allegedly was led to the massage room, the FAC alleges that a topless woman "with dark hair [and] an accent ... tried to coax Plaintiff
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
by one of Defendant's agents to give Defendant a massage for compensation," and that Defendant's agent "drove [Plaintiff] to [Defendant's] mansion." FAC S 18. After she allegedly was led to the massage room, the FAC alleges that a topless woman "with dark hair [and] an accent ... tried to coax Plaintiff
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
by one of Defendant's agents to give Defendant a massage for compensation," and that Defendant's agent "drove [Plaintiff] to [Defendant's] mansion." FAC S 18. After she allegedly was led to the massage room, the FAC alleges that a topless woman "with dark hair [and] an accent ... tried to coax Plaintiff
Entities connected to both the First Amended Complaint and FAC S 18

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