The document is a legal memorandum opposing Jeffrey Epstein's motion to dismiss a case filed by Jane Doe II. The plaintiff argues against the dismissal on several grounds, including the right to file claims in both state and federal courts, the retroactivity of amendments to 18 U.S.C. §2255, and the ability to claim damages for each distinct violation. The memorandum also addresses the legal standards for motions to dismiss and argues that the plaintiff has sufficiently pled a cause of action for conspiracy to violate §2255.
documents/EFTA00222873.pdf
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