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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
laintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleade
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
laintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleade
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
laintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleade
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
laintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleade
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
laintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleade
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: Pleadine Standard & Summary of Areument T
laintiff has a right to relief, raising that possibility above a speculative level; if they do not, the plaintiff's complaint should be dismissed." James River Ins. Co., 540 F.3d at 1274 (citation and quotation omitted); see also lqbal, slip op. at 15 (holding the a complaint must be dismissed "where the well-pleade
Entities connected to both the First Amended Complaint and James River Ins. Co.

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
PERSONWeaver
PERSON
Bowen
PERSON
H.R.
PERSON
Schumer
PERSON
Corley
PERSON
Green
PERSONCalder
ORGANIZATIONEllis
PERSON