The document is a legal memorandum filed by the plaintiff, C.M.A., in response to Jeffrey Epstein's motion to dismiss the first amended complaint. The plaintiff argues against the dismissal, asserting that sufficient factual bases have been pled to support the claims against Epstein. The memorandum addresses the statutory interpretation of 18 U.S.C. §2255, the allowance of punitive damages under federal common law, and the adequacy of the common law battery claim under Florida law. The plaintiff also agrees to re-plead certain predicate acts in light of a related court ruling.
documents/EFTA00201211.pdf
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