Epstein Secrets

of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION Defendant, JEFFREY EPSTEIN, ("EPSTEIN

Count I of Plaintiffs Complaint for failure to state a cause of action. Rule 12(b)(6), Fed.R.Civ.P. (2008). Count II is directed only to Defendant KELLEN, who has not yet been served. In support of dismissal, Defendant states: Plaintiff, CMA, attempts to assert a cause of action against EPSTEIN in Cou

rp. supra at 1664-65: While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations, ibid.. Sanivan v. American Bd. of Psychiatry and Neurology, Inc., 40 F.3d 247, 251 (C.A.7 1994), a plaintiffs obligation to provide the "grounds" of his "entitle[ment] to relief

Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, the underage victim would be introduced to Sarah Kellen, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl u

would be introduced to Sarah Kellen, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. There were photograph

orp. supra at 1664-65: While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations ibid.. Sanivan v. American Bd. of Psychiatry and Neurology. Inc., 40 F.3d 247, 251 (C.A.7 1994), a plaintiffs obligation to provide the "grounds" of his "entitle[ment] to relief

, including Plaintiff, Jane Doe, to engage in prostitution... ;" ale Amended Complaint at 133(a) (b) ". . . conspir(ind with others known (such as Sarah Kellen) and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct with minors, including Plaintiff Jane Doe, as d

. . conspir(ind with others known (such as Sarah Kellen) and unknown to travel in interstate commerce fo

ic Corp., supra at 1664-65: While a complaint attacked by a Rule 12(6)(6) motion to dismiss does not need detailed factual allegations, Sanivan v. American Bd. of Psychiatry and EFTA00234846 Case 9:08-cv-80893-KAM Document 87 Entered on FLSD Docket 06/12/2009 Page 3 of 26 Doe v. Epstein Page No. 3