Epstein Secrets

, P.A. Attorneys for Plaintiff By: s/Katherine W. Ezell Robert C. Josefsberg, Fla. Bar No. 040856

Under notice pleading, the plaintiff need only provide the defendant fair notice of his claim and the grounds upon which it rests. See Erickson v. Pardus, 127 S. Ct. 2197, 2200 (2007). As this is a liberal pleading requirement, "[s]pecific facts are not necessary; the statement need only `give the de

clude Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein.

2686 EFTA01734466 Case 9:08-cv-80893-KAM Document 125 Entered on FLSD Docket 03/03/2010 Page 2 of 10 favorable to the plaintiff. See Erickson v. Pardus, 551 U.S. 89, 94 (2007). To satisfy the pleading requirements of Federal Rule of Civil Procedure 8, a complaint must contain a short and plain stat

clude Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein.

3294 EFTA02725751 Case 9:08-cv-80893-KAM Document 125 Entered on FLSD Docket 03/03/2010 Page 2 of 10 favorable to the plaintiff. See Erickson v. Pardus, 551 U.S. 89, 94 (2007). To satisfy the pleading requirements of Federal Rule of Civil Procedure 8, a complaint must contain a short and plain stat