Epstein Secrets

ddress) LEAD ATTORNEY ATTORNEY TO BE NOTICED Stuart S. Mermelstein (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED represented by Bradley James Edwards Rothstein Rosenfeldt Adler 401 East Las Olas Blvd Suite 1650 Ft. Lauderdale , FL 33301 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Paul

Entered: 06/08/2009) 06/08/2009 14k RESPONSE in Opposition re 144 Defendant's MOTION to Strike Cases from Current Trial Docket filed by Jane Doe. (Edwards, Bradley) (Entered: 06/08/2009) 06/08/2009 147 RESPONSE in Opposition re 104 Defendant's MOTION to Strike Cases from Current Trial Docket filed b

for failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has failed to allege sufficient factual allegations in the Counts and instead alleges labels and conclusions, and an attempted formulaic recitation of the elements in each Count. 2. In the alternative, Defendant s

ue . .. ." United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, "[b]ecause minors often are not capable of remembering

f two depositions, the defendant knowingly made false material declarations, in violation of 18 U.S.C. § 1623. The defendant moves to dismiss those Counts, arguing that the Court can determine now—on a pre- 44 For similar reasons, the defendant's request fordiscovery regarding this matter should be deni

ssue ...." United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, lbJecause minors often are not capable of remembering

f two depositions, the defendant knowingly made false material declarations, in violation of 18 U.S.C. § 1623. The defendant moves to dismiss those Counts, arguing that the Court can determine now—on a pre- 44 For similar reasons, the defendant's request for discovery regarding this matter should be den

ssue ...." United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, lbJecause minors often are not capable of remembering

f two depositions, the defendant knowingly made false material declarations, in violation of 18 U.S.C. § 1623. The defendant moves to dismiss those Counts, arguing that the Court can determine now—on a pre- 44 For similar reasons, the defendant's request for discovery regarding this matter should be den

d States v. Young, 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation 154 EFTA00095246 mark omitted) (quoting Edwards v. Mazzuca, No 00 Civ. 2290 (12.1S), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, "[b]ecause minors often are not capable of rememberin

f two depositions, the defendant knowingly made false material declarations, in violation of 18 U.S.C. § 1623. The defendant moves to dismiss those Counts, arguing that that the Court can determine now—on a pre-trial record that is not factually developed—that the questions were fundamentally ambiguous

e . . . ." United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (RJS), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, "[b]ecause minors often are not capable of rememberin

f two depositions, the defendant knowingly made false material declarations, in violation of 18 U.S.C. § 1623. The defendant moves to dismiss those Counts, arguing that the Court can determine now—on a pre- 44 For similar reasons, the defendant's request for discovery regarding this matter should be den