Case 9:08-cv-80811-KAM

Case 9:08-cv-80811-KAM Document 58 Entered on FLSD Docket 04/13/2009 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON C.M.A., Plaintiff, vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. 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 The Plaintiff, C.M.A., by and through undersigned counsel, files this 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; and Motion to Strike (D.E. 47). As a preliminary matter, the Plaintiff submits that she has pled sufficient factual bases to support the 31 claims set forth against the Defendant in this case. In this Court's Opinion and Order on Motion to Dismiss and Mot