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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
tute the offence." Russell v. United States, 369 U.S. 749, 764-65 (1962) (quoting United States v. Hess, 124 U.S. 483, 487 (1888); United States v. Carll, 105 U.S. 611, 612 (1881)). The FAC does not come close to discharging that burden. A. The applicable version of § 2255 only permits "minors" to sue
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
tute the offence." Russell v. United States, 369 U.S. 749, 764-65 (1962) (quoting United States v. Hess, 124 U.S. 483, 487 (1888); United States v. Carll, 105 U.S. 611, 612 (1881)). The FAC does not come close to discharging that burden. A. The applicable version of § 2255 only permits "minors" to sue
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
tute the offence." Russell v. United States, 369 U.S. 749, 764-65 (1962) (quoting United States v. Hess, 124 U.S. 483, 487 (1888); United States v. Carll, 105 U.S. 611, 612 (1881)). The FAC does not come close to discharging that burden. A. The applicable version of § 2255 only permits "minors" to sue
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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
tute the offence." Russell v. United States, 369 U.S. 749, 764-65 (1962) (quoting United States v. Hess, 124 U.S. 483, 487 (1888); United States v. Carll, 105 U.S. 611, 612 (1881)). The FAC does not come close to discharging that burden. A. The applicable version of § 2255 only permits "minors" to sue
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
tute the offence." Russell v. United States, 369 U.S. 749, 764-65 (1962) (quoting United States v. Hess, 124 U.S. 483, 487 (1888); United States v. Carll, 105 U.S. 611, 612 (1881)). The FAC does not come close to discharging that burden. A. The applicable version of § 2255 only permits "minors" to sue
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Mutual Connections (101)
Entities connected to both Jeffrey Epstein and Carll
LB
Leon Black
PERSON10,461 w/ Jeffrey·5 w/ Carll
Prince Andrew
PERSON9,960 w/ Jeffrey·5 w/ Carll
Alan Dershowitz
PERSON5,935 w/ Jeffrey·5 w/ Carll
George W. Bush
PERSON5,075 w/ Jeffrey·5 w/ Carll
United States
LOCATION4,786 w/ Jeffrey·5 w/ Carll
JG
Jack Goldberger
PERSON3,877 w/ Jeffrey·5 w/ Carll
JD
Jane Doe
PERSON3,169 w/ Jeffrey·5 w/ Carll
Alfredo Rodriguez
PERSON2,569 w/ Jeffrey·5 w/ Carll
Scarlett Johansson
PERSON1,425 w/ Jeffrey·5 w/ Carll
Masha Drokova
PERSON1,158 w/ Jeffrey·5 w/ Carll
RC
Robert D. Critton
PERSON1,155 w/ Jeffrey·4 w/ Carll
Oliver Stone
PERSON1,079 w/ Jeffrey·5 w/ Carll
RJ
Robert C. Josefsberg
PERSON891 w/ Jeffrey·5 w/ Carll
Green
PERSON799 w/ Jeffrey·5 w/ Carll
MP
Michael J. Pike
PERSON771 w/ Jeffrey·5 w/ Carll
KE
Katherine W. Ezell
PERSON585 w/ Jeffrey·5 w/ Carll
United States District Court
ORGANIZATION490 w/ Jeffrey·5 w/ Carll
Supreme Court
ORGANIZATION487 w/ Jeffrey·5 w/ Carll
Jennifer Lopez
PERSON479 w/ Jeffrey·5 w/ Carll
John Kerry
PERSON397 w/ Jeffrey·5 w/ Carll