EFTA00605538.pdf

Case 9:10-cv-80309-WJZ Document 14 Entered on FLSD Docket 04/05/2010 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-80309-CIV- JANE DOE No. 103, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS.COUNT VI & FOR MORE DEFINITE STATEMENT & TO STRIKE DIRECTED TO PLAINTIFF JANE DOE NO. 103'S COMPLAINT (dated 2/23/20101 Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, moves to dismiss Count Six of PlaintiffJANE DOE 103's Complaint for failure to state a cause of action, as specified herein. Rule 12(bX6), Fed.R.Civ.P. (2009); Local Gen. Rule 7.1 (S.D. Fla. 2009). Defendant further moves for More Definite Statement and to Strike. Rule 12(e) and (f), In support of his motion, Defendant states: The Complaint attempts to allege 6 counts, all of which are purportedly brought pursuant to 18 U.S.C. §2255 — Civil Remediesfor Personal Injuries. Count Six is subject to dismissal become the predicate act relied upon by Plaintiff for her claims did not come into effect until July 27, 2006, well after the conduct alleged by Plaintiff occurred. The More Definite Statement requested is for Plaintiff to allege her date of birth in that her being a minor has significance in the claims she alleges. 1 EFTA00605538