Epstein Secrets

Fax: 8 Email: ATTORNEY TO BE NOTICED Martin G. Weinberg 20 Park Plaza 2116 Fax: 338-9538 PRO HAC VICE

lan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 , FL 33401-5012 Fax: 8 Email: ATTORNEY TO BE NOTICED Martin G. Weinberg 20 Park Plaza 2116 Fax: 338-9538 PRO HAC VICE ATTORNEY TO BE NOTICED https://ecfflsd.uscourts.gov/egi-bin/D1ctRpt.pl?482840805650403-L_801_0-1

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

perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the question and answer "in the context of the line of questionin

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

perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the question and answer "in the context of the line of questionin

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

perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the question and answer "in the context of the line of questionin

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

perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the question and answer "in the context of the line of questionin

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

perjury by falsely denying memory or knowledge of an event. See, e.g., United States v. Alberti, 568 F.2d 617, 625 (2d Cir. 1977); United States v. Weiner, 479 F.2d 923, 926, 929 (2d Cir. 1973); Forde, 740 F. Supp. 2d at 410-11. Viewing the question and answer "in the context of the line of questionin

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