Epstein Secrets

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

laint's allegations must be taken as true, "unwarranted deductions of facts or legal conclusions masquerading as facts will not prevent dismissal." Oxford Asset Mgnt., Ltd. v. Jaharis, 297 F.3d 1182, 1188 (11th Cir. 2002). Courts likewise may take note of public-record materials subject to judicial notice—even if

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

laint's allegations must be taken as true, "unwarranted deductions of facts or legal conclusions masquerading as facts will not prevent dismissal." Oxford Asset Mgnt., Ltd. v. Jaharis, 297 F.3d 1182, 1188 (11th Cir. 2002). Courts likewise may take note of public-record materials subject to judicial notice—even if

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

laint's allegations must be taken as true, "unwarranted deductions of facts or legal conclusions masquerading as facts will not prevent dismissal." Oxford Asset Mgnt., Ltd. v. Jaharis, 297 F.3d 1182, 1188 (11th Cir. 2002). Courts likewise may take note of public-record materials subject to judicial notice—even if

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

laint's allegations must be taken as true, "unwarranted deductions of facts or legal conclusions masquerading as facts will not prevent dismissal." Oxford Asset Mgnt., Ltd. v. Jaharis, 297 F.3d 1182, 1188 (11th Cir. 2002). Courts likewise may take note of public-record materials subject to judicial notice—even if

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

laint's allegations must be taken as true, "unwarranted deductions of facts or legal conclusions masquerading as facts will not prevent dismissal." Oxford Asset Mgnt., Ltd. v. Jaharis, 297 F.3d 1182, 1188 (11th Cir. 2002). Courts likewise may take note of public-record materials subject to judicial notice—even if