Case 9:10-cv-80309-KAM Document 15 Entered on FLSD Docket 04/12/2010 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-80309-CIVJANE DOE No. 103, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO AMEND DEFENDANT'S MOTION TO DISMISS. & FOR MORE DEFINITE STATEMENT & STRIKE DIRECTED TO PLAINTIFF JANE DOE NO. 103'S COMPLAINT Idated 4/5/20101 Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, moves to amend by his previously filed Motion To Dismiss, & Motion For More Definite Statement & Strike Directed To Plaintiff JANE DOE 103 's Complaint, (hereinafter "Motion To Dismiss"), dated and filed April 5, 2010. In support of his motion, Defendant states: 1. On April 5, 2010, Defendant previously filed with this Court his Motion To Dismiss. Defendant seeks dismissal of Count VI, which is brought pursuant to 18 U.S.C. §2255, because Plaintiff is relying on a criminal predicate act enumerated in §2255 that did not come into effect until after the alleged time period of the alleged conduct by Defendant involving Plaintiff. 18 U.S.C. §2252A(g), the criminal statute relied upon by Plaintiff in attempting to assert her §2255 claim in Count VI, was not enacted until 2006; the allegedly violative conduct by Defendant occurred, according to Plaintiff's own EFTA02739204