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in this Complaint). Under Epstein's plan, underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Reach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or
in this Complaint). Under Epstein's plan, underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or
a man of tremendous wealth, powcr and influence. Ile maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Reach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach. 8. Upon information and belief, Epstein has a sexu
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
in this Complaint). Under Epstein's plan, underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or
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
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
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
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
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
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
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
Entities connected to both Palm Beach and Counts

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSONLeon Black
PERSON
United States
LOCATION
Alan Dershowitz
PERSONJack Goldberger
PERSONJane Doe
PERSON
Palm Beach County
LOCATION
Bradley Edwards
PERSONFBI
ORGANIZATIONthe Southern District
LOCATION
Kenneth Marra
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSON
Alexander Acosta
PERSON
Scarlett Johansson
PERSON
Julie K. Brown
PERSONDoug Band
PERSONMartin Weinberg
PERSON