Case 9:08-cv-80811-KAM Document 78 Entered on FLSD Docket 05/08/2009 Page 1 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS FIRST AMEDNED COMPLAINT FOR FAIURE TO STATE A CAUSE OF ACTION, AND MOTION FOR MORE DEFINITE STATEMENT; MOTION TO STRIKE, AND SUPPORTING MEMORANDUM OF LAW, (dated April 13, 2009) Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, files his reply to Plaintiff's Memorandum in Response to Defendant, JEFFREY EPSTEIN's, Motion to Dismiss First Amended Complaint For Failure to State A Cause of Action; And Motion for More Definite Statement; Motion to Strike, And Supporting Memorandum of Law, dated April 13, 2009, (hereinafter "Plaintiff's response"). In reply to Plaintiff's response and further supporting Defendant's motion to dismiss Count I through XXXI of Plaintiffs First Amended Complaint for failure to state a cause of action, and for more definite statement, or to strike, [DE 47], dated April 12, 2009, (hereinafter "Defendant's motion"), Defendant states: I. The 2003 version of 18 U.S.C. §2255 applies to this action. A. The statute in affect during the time the alleged acts occurred is the applicable version of 18 U.S.C. §2255; in this action — the 2003 version (quoted at p. 7, EFTA00201259