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tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the
this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De
tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the
this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De
tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the
this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De
tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the
this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De
tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the
this Court may not accept "unwarranted deductions of facts or legal conclusions masquerading as facts" Oxford Asset Mgnt., 297 F.3d at 1188 (citing Fernandez-Montes, 987 F.2d at 284), and Plaintiffs contrary assertions "will not prevent dismissal." Id. Because Plaintiff has not alleged—and cannot allege—that De
Entities connected to both Counts IV and Fernandez-Montes
Jane Doe
PERSON
Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSON
Alfredo Rodriguez
PERSONJack Goldberger
PERSONLeon Black
PERSON
Oliver Stone
PERSON
John Kerry
PERSONEvans
PERSON
Supreme Court
ORGANIZATIONHansen
PERSON
Mortensen
PERSON
Searcy
PERSON
Estelle
PERSONSiljander
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Bowen
PERSON
H.R.
PERSON