Epstein Secrets

employment with attached Complaint against Scott Rothstein and Bradley J. Edwards 1/4/2010 Villafafia Spe

Exhibit # 12/9/2009 Villafafia Roy Black Letter in response to 11/02/09 letter re Epstein's place of employment with attached Complaint against Scott Rothstein and Bradley J. Edwards 1/4/2010 Villafafia Spencer Kuvin Letter re computer seized by FBI 1/20/2010 Villafalia Roy Black Letter re attorney's

Criminal Chief Matt Menchel contacted SLC Schultz about moving me to Appeals after I pointed out actions that I considered to be in violation of the Ashcroft memo and victims' rights legislation. I also understand that SLC Schultz may have knowledge of USA Acosta providing my prosecution memorandum to Cr

Doe v. Epstein Page No. 26 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

clear that "Twombly expounded the pleading standard for "'all civil actions'" and not just "pleadings made in the context of an antitrust dispute," Ashcroft v. lqbal, No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting Fed. R. Civ. P. 1), the need for enforcing these modest pleading requirements i

must only make a prima facie showing of venue.- Rothstein v. Harstad, Civ. No. 2:10-01421, 2010 WL 3259789,

s Motion to Dismiss the Complaint with Points and Authorities should be denied in its entirety. Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), Ashcroft v. !Oat 556 U.S. , 129 S. Ct. 1937 (2009), Fowler v. UPMC Shadyside, 578 F.3d 203, 210- 211 (3r° Cir. 2009) (quoting %bal. 129 S.O. at 1949-50), Sh

nsel, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East

ion that all the allegations in the complaint are true (even if doubtful in fact)." Id. The United States Supreme Court very recently made clear in Ashcroft v. lubal No. 07-1015 (U.S. May 18, EFTA00175268 Case 9:09-cv-80469-KAM Document 31 Entered on FLSD Docket 06/01/2009 Page 3 of 11 Jane Doe II