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DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u
ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the
01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S
o relief, raising that possibility above a speculative level; if they do not, the plaintiffs complaint should be dismissed." James River Ins. Co. v. Ground Down Ena'a, Inc., 540 F.3d 1270, 1274 (11th Cir. 2008) (citation and quotation omitted); see also Iqbal, slip op. at 15 (complaint must be dismissed "where the well
4 mentions1 same-page
Page ?Same page
DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u
ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the
01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S
o relief, raising that possibility above a speculative level; if they do not, the plaintiffs complaint should be dismissed." James River Ins. Co. v. Ground Down Ena'a, Inc., 540 F.3d 1270, 1274 (11th Cir. 2008) (citation and quotation omitted); see also Iqbal, slip op. at 15 (complaint must be dismissed "where the well
4 mentions1 same-page
Page ?Same page
DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u
ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the
01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S
o relief, raising that possibility above a speculative level; if they do not, the plaintiffs complaint should be dismissed." James River Ins. Co. v. Ground Down Ena'a, Inc., 540 F.3d 1270, 1274 (11th Cir. 2008) (citation and quotation omitted); see also Iqbal, slip op. at 15 (complaint must be dismissed "where the well
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4 mentions1 same-page
Page ?Same page
DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u
ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the
01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S
o relief, raising that possibility above a speculative level; if they do not, the plaintiffs complaint should be dismissed." James River Ins. Co. v. Ground Down Ena'a, Inc., 540 F.3d 1270, 1274 (11th Cir. 2008) (citation and quotation omitted); see also Iqbal, slip op. at 15 (complaint must be dismissed "where the well
4 mentions1 same-page
Page ?Same page
DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u
ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the
01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S
o relief, raising that possibility above a speculative level; if they do not, the plaintiffs complaint should be dismissed." James River Ins. Co. v. Ground Down Ena'a, Inc., 540 F.3d 1270, 1274 (11th Cir. 2008) (citation and quotation omitted); see also Iqbal, slip op. at 15 (complaint must be dismissed "where the well
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Mutual Connections (101)
Entities connected to both Jeffrey Epstein and Ground Down Ena'a, Inc.
LB
Leon Black
PERSON10,461 w/ Jeffrey·5 w/ Ground
Prince Andrew
PERSON9,960 w/ Jeffrey·5 w/ Ground
Alan Dershowitz
PERSON5,935 w/ Jeffrey·5 w/ Ground
George W. Bush
PERSON5,075 w/ Jeffrey·5 w/ Ground
United States
LOCATION4,786 w/ Jeffrey·5 w/ Ground
JG
Jack Goldberger
PERSON3,877 w/ Jeffrey·5 w/ Ground
JD
Jane Doe
PERSON3,169 w/ Jeffrey·5 w/ Ground
Alfredo Rodriguez
PERSON2,569 w/ Jeffrey·5 w/ Ground
Scarlett Johansson
PERSON1,425 w/ Jeffrey·5 w/ Ground
Masha Drokova
PERSON1,158 w/ Jeffrey·5 w/ Ground
RC
Robert D. Critton
PERSON1,155 w/ Jeffrey·4 w/ Ground
Oliver Stone
PERSON1,079 w/ Jeffrey·5 w/ Ground
RJ
Robert C. Josefsberg
PERSON891 w/ Jeffrey·5 w/ Ground
Green
PERSON799 w/ Jeffrey·5 w/ Ground
MP
Michael J. Pike
PERSON771 w/ Jeffrey·5 w/ Ground
KE
Katherine W. Ezell
PERSON585 w/ Jeffrey·5 w/ Ground
United States District Court
ORGANIZATION490 w/ Jeffrey·5 w/ Ground
Supreme Court
ORGANIZATION487 w/ Jeffrey·5 w/ Ground
Jennifer Lopez
PERSON479 w/ Jeffrey·5 w/ Ground
John Kerry
PERSON397 w/ Jeffrey·5 w/ Ground