7
Shared Docs
7
Same-Page
7 / 7
Mentions
nt to a criminal statute that provides no civil remedy, her complaint is properly dismissed for failure to state a cause of action. See Mantooth v. Richards, 557 So. 2d 646, 646 (Fla. 4th DCA 1990) (per curiam) (affirming dismissal of plaintiff's claim for parental kidnapping where "the mentioned statut
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
or Victim-2 to testify about her abuse twice. Cl Richardson v. Marsh, 481 U.S. 200, 210 (1987) (recognizing
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
r Victim-2 to testify about her abuse twice. Cf. Richardson v. Marsh, 481 U.S. 200, 210 (1987) (recognizing
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
r Victim-2 to testify about her abuse twice. Cf. Richardson v. Marsh, 481 U.S. 200, 210 (1987) (recognizing
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
r Victim-2 to testify about her abuse twice. See Richardson v. Marsh, 481 U.S. 200, 210 (1987) (recognizing
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
r Victim-2 to testify about her abuse twice. Cf. Richardson v. Marsh, 481 U.S. 200, 210 (1987) (recognizing
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
ant to a criminal statute that provides no civil remedy, her complaint is properly dismissed for failure to state a cause of action. See Mantoothl. Richards, 557 So. 2d 646, 646 (Fla. 4th DCA 1990) (per curiam) (affirming dismissal of plaintiff's claim for parental kidnapping where "the mentioned statut
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
Entities connected to both Bill Richardson and Counts

Jeffrey Epstein
PERSONJack Goldberger
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Virginia Giuffre
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSON
Stephen Hawking
PERSON
Scarlett Johansson
PERSON
George Mitchell
PERSONJane Doe
PERSONFBI
ORGANIZATION
Michael Jackson
PERSONMaria Farmer
PERSONthe Southern District
LOCATION