Epstein Secrets

ions fall far short of an "offer of corporal injury by force." There are no allegations that Jane Doe was placed in any fear of imminent peril. See Gatto 's. Publix Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fea

10/06/2008 46 Defendant's MOTION to Dismiss 42 Amended Complaint and for More Definite Statement by Jeffrey Epstein. Responses due by 10/24/2008 (Critton, Robert) (Entered: 10/06/2008) 10/24/2008 4/ Unopposed MOTION for Extension of Time to File Response as to 46 Defendant's MOTION to Dismiss 42 Am

Fax. 6 EFTA00175615 Case 9:08-cv-80( •KAM Document 40 Entered d LSD Docket Ofd '2008 Page 7 of 8 CASE NO.: 08-80119-CIV-MARRA/JOHNSON By: Robert D. Critton, Esq. Fla. Bar No. 224162 [email protected] Michael J. Pike, Esq. Attorneys for Defendant Jetty Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL

ions fall far short of an "offer of corporal injury by force." There are no allegations that Jane Doe was placed in any fear of imminent peril. See Gatto v. Publix Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fear

561 515 3148 6 Case 9:08-cv-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 7 of 8 CASE NO.: 08-80119-CIV-MARRA/JOHNSON By: Robert D. Critton, Esq. Fla. Bar No. 224162 [email protected] Michael J. Pike, Esq. Fla. Bar No. 617296 [email protected] Attorneys for Defendant Jeffrey Epst

imminent peril. See Gatto v. Pubblx Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fear of imminent peril, there was no assault). In fact, the plaintiff does not even allege that Mr. Epstein touched her. Thus, there

01 6 EFTA00221982 Case 9:08-cv-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 7 of 8 CASE NO.: 08-80119-CIV-MARRA/JOHNSON By: Robert D. Critton, Esq. Fla. Bar No. 224162 Michael J. Pike, Esq. Fla. Bar No. 617296 Attorneys for Defendant Jeffrey Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL

imminent peril. See Gatto v. Pubblx Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fear of imminent peril, there was no assault). In fact, the plaintiff does not even allege that Mr. Epstein touched her. Thus, there

x. 6 EFTA00222425 Case 9:08-cv-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 7 of 8 CASE NO.: 08-80119-CIV-MARRA/JOHNSON By: Robert D. Critton, Esq. Fla. Bar No. 224162 Michael J. Pike, Esq. Fla. Bar No. 617296 Attorneys for Defendant Jeffrey Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL

imminent peril. See Gatto v. Pubblx Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fear of imminent peril, there was no assault). In fact, the plaintiff does not even allege that Mr. Epstein touched her. Thus, there

48 6 EFTA00222728 Case 9:08-cv-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 7 of 8 CASE NO.: 08-80119-CIV-MARRA/JOHNSON By: Robert D. Critton, Esq. Fla. Bar No. 224162 [email protected] Michael J. Pike, Esq. Fla. Bar No. 617296 [email protected] Attorneys for Defendant Jeffrey Epst