Case 9:10-cv-80447-KAM Document 9 Entered on FLSD Docket 05/26/2010 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: 10-80447 —CV-MARRA/a C. L. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S RESPONSE TO DEFENDANT EI'STEIN'S MOTION FOR MORE DEFINITE STATEMENT & TO STRIKE, & TO DISMISS DIRECTED TO COUNT III OF PLAINTIFF C.L.'S COMPLAINT Plaintiff, C. L., by and through her undersigned counsel, files this Response to Defendant Epstein's Motion For More Definite Statement & To Strike, & To Dismiss Directed To Count III Of Plaintiff C.L.'S Complaint. ("Motion"). First, Defendant argues that Count III of Plaintiff's Complaint should be dismissed because the predicate act relied upori, 18 U.S.C. § 2252 A(g), did not come into effect until July 27, 2006, well after Defendant's offensive conduct occurred. Defendant then seeks a more definite statement, i.e., for Plaintiff to allege her date of birth in order to establish when she reached 18, the age of majority under state and federal law. Finally, Defendant seeks to strike paragraphs 8 through 15 of Plaintiff's Complaint as immaterial and impertinent. Defendant's motion should be denied for the reasons set forth below: EFTA02732366