Case 9:08-cv-80893-KAM Document 87 Entered on FLSD Docket 06)12'2009 Page 1 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Doe's Amended Complaint, With Incorporated Memorandum Of Law Defendant, Jeffery Epstein, by and through his undersigned counsel, moves to dismiss and for more definite statement of Plaintiff, Jane Doe's Amended Complaint. Rules 12(b)(6), and 12(e) and (f), Fed.R.Civ.P. (2008). In support of his motion, Defendant states: I. The Amended Complaint The Amended Complaint attempts to allege four counts, entitled Count I - "Sexual Battery Upon a Minor," Count II — "Cause of Action Pursuant to 18 USC §22 55," Count III — "Intentional Infliction of Emotional Distress," Count IV — "Civil Remedy for Criminal Practices" and Count VI — "Cause of Action Pursuant to Florida Statute 796.09 Against Defendant, Jeffrey Epstein." Defendant seeks dismissal of Counts II and IV of the Amended Complaint or, alternatively, a motion for more definite statement as requested. IL Applicable Standards a. Dismissal While the Supreme Court has held that every civil complaint 'must contain something more than a statement of facts that merely creates a suspicion of a legally cognizable right of EFTA00234845