Case 9:10-cv-80447-KAM Document 5 Entered on FLSD Docket 05/03/2010 Page 1 of 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-80447-CIV C.L., Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION FOR MORE DEFINITE STATEMENT & TO STRIKE, & TO DISMISS DIRECTED TO COUNT III OF PLAINTIFF C.L.'S COMPLAINT ID.E. 1, dated 3/31/2010j Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, files this Motion For More Definite Statement & Strike, and Motion to Dismiss Count ❑I Directed To Plaintiff C.L.'s Complaint. Rule 12(b)(6), Rule 12(e) and (f), Fed.R.Civ.P. (2010); Local Gen. Rule 7.1 (S.D. Fla. 2009). In support of his motion, Defendant states: The Complaint attempts to allege 3 counts, all of which are purportedly brought pursuant to 18 U.S.C. §2255 — Civil Remedies for Personal Injuries. Defendant seeks more definite statement of the precise time period during which the alleged conduct by EPSTEIN involving Plaintiff occurred, and seeks more definite statement as to C.L.'s date of birth so he can determine when she was no longer a minor. Plaintiff's complaint fails to state even these rudimentary facts. As discussed more fully below herein, when EPSTEIN's alleged conduct involving C.L. occurred determines what version of 18 U.S.C. §2255 applies to this action. To be clear, Defendant recognizes that pursuant to the NPA (Non-Prosecution Agreement) he cannot challenge the standing of Plaintiff to bring an action exclusively EFTA02732341