Epstein Secrets

ilar to Jane Doe. Juries considering punitive damages issues are plainly entitled to consider "the existence and frequency of similar past conduct." TXO Production Corp. I. Alliance Resources Corp., 509 U.S. 443, 462 n.28 (1993). This is because Supreme Court holdings recognize "that a recidivist may be punished mor

ated Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 / PLAINTIFF JANE DOE'S NOTICE REGARDING EVIDENCE OF SIMILAR ACTS OF SEXUAL ASSAULT Plaintiff, Jane Doe, through undersigned counsel, hereby files this notice pursuant to

ex. She was taken up to Epstein's bedroom, and he told her to undress and massage him. Then he rolled over and began masturbating as he also touched Jane Doe's naked breasts, buttocks and vagina. At times Epstein inserted his fingers into her vagina and used a vibrator on Jane Doe's vagina. He and his assis

irls admissible. Juries considering punitive damages issues are plainly entitled to consider "the existence and frequency of similar past conduct." TXO Production Corp. v. Alliance Resources Corp., 509 U.S. 17 EFTA00725985 443, 462 n.28 (1993). This is because the Supreme Court recognizes "that a recidivist may b

atement of Undisputed Facts. 12 EFTA00725980 In addition, if Epstein had thought that there was some improper coercion involved in, for example, Jane Doe's case, his remedy was to raise the matter before Federal District Court Judge Kenneth A. Marra who was presiding over the matter. Far from raising an

ards filed a civil sot against Jeffrey Epstein to recover damages for his sexual assault of L.M. See Complaint, LM. v. Epstein, (Exhibit “V”). 3 47. Jane Doe’s federal complaint indicated that she sought damages of more than $50,000,000. Listing the amount of damages sought in the complaint was in accord wit

girls admissible. Juries considering punitive damages issues are plainly entitled to consider “the existence and frequency of similar past conduct.” TXO Production Corp. v. Alliance Resources Corp., 509 U.S. 443, 462 0.28 (1993). This is because the Supreme Court recognizes “that a recidivist may be punished more seve