Epstein Secrets

racy claim against must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).1° 10 This case is governed by the general rule. Cf. Churr

s"). 5 Lewis Tein n. 3059 Gump Ave mut Sulu 340, Cocorout Goon. haulm 33133 So1316 EFTA00234228 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07121:2008 Page 6 of 100 1. The amount in controversy in this action exceeds $75,000. This case is a duplicate of the First Federal Lawsuit. In th

ingle viable cause of action against 1. The plaintiff has not asserted a cause of action against for civil conspiracy.. The plaintiff, citing to Wright Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984), concedes that "there muse [sic] be an `actionable underlying tort or wrong' for an actionable co

for monetary compensation. (Am. Compl. ¶ 13). brought Plaintiff to Epstein's mansion 2 EFTA00175528 Case 9:08-ov-80004-KAM Document Entered . FLSD Docket 10/03/2„8 Page 3 of 8 in Palm Beach. (Am. Compl. ¶ 13). Plaintiff was introduced to a, who led her up the stairs to the room with the massage tab

utionality or even impropriety. Incendy at 956 (citing United States v. Kordel, 397 U.S. 1, 11 (1970)). See also Securities and Exchange Comm 'n v. Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o `special circumstances' existed in this case warranting a stay, as there is no record evidence sug

-Prosecution Agreement between the United States and Defendant Jeffrey Epstein. -3- EFTA00599144 Case 9:08-cv-80119-KAM Document 121 Enterod on FLSD Docket 05/29/2009 Page 4 of 17 ISSUE PRESENTED The United States is not a party to these lawsuits and, accordingly, is not fully aware of the scope of t

stitutionality or even impropriety. Incendy at 956 (citing United States' Kordel, 397 U.S. I, 11 (1970)). See also Securities and Exchange Comm'nl. Wright, 261 Fed. Appx. 259, 263 (11th Cir. 2008) ("[N]o 'special circumstances' existed in this case warranting a stay, as there is no record evidence sug

of Investigation Washington. U.C. 3 Govt Exhibit Case No. 08-80736-CIV.N1ARRA EFTA00185246 Case 9:08-cv-80119-KAM Document 15-2 , Entered on FLSD Docket 06/30/2008 Page 2 of 35 lfralsor.,&Ass2ciates I sor & Associates I O IN MS CIACUST COURT Or WE rirrtASH IM MO 1 PAU. WW1 COMITY. MORICA CAW

laim against Robson must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).1° 10 This case is governed by the general rule. Cf. Churr

FTA00180304 Case !:i:08-cv 1 2 3 80119-KAM Document 180 Entered UNITED STATES SOUTHERN DISTRICT WEST PALM CASE NO. 08-80119-CIV-MARRA on FLSD Docket 06/24/2009 Page 1 of 51 DISTRICT COURT OF FLORIDA BEACH DIVISION 4 WEST PALM BEACH, FLORIDA 5 JANE DOE, et al., 6 Plaintiffs, vs. JUNE 12