Epstein Secrets

direct control and/or direction of the catlfiong reporter. 16 17 18 19 20 21 22 23 24 25' Doted this 13th day of October. 2009. Pamela/. Sullivan. RFR, FPR, CLIO 1 CERTIFICATE Page 258 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the foregoing 6

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME II Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893,

direct control and/or direction of the catlfiong reporter. 16 17 18 19 20 21 22 23 24 25' Doted this 13th day of October. 2009. Pamela/. Sullivan. RFR, FPR, CLIO 1 CERTIFICATE Page 258 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the foregoing 6

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME II Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893,

N present ability to effectuate the attempt." An assault thus requires "an affirmative act—a threat to use force, or the actual exertion of force." Sullivan v. Ad. Fed. Say. & Loan Assoc., 454 So. 2d 52, 54 (Fla. 4th DCA 1984) (affirming dismissal of assault claim where there was no affirmative act). I

40 Entered on FLSD Docket 09/04/2008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. MOTION TO DISMISS Defendant Jeffrey Epstein, pursuant to Rule 12(b) of the Federal Rules of Civi

Herzfeld, 781 So.2d 1070 (Fla.2001) (noting that plaintiff alleged intentional tort of "assault and battery" based on allegations of sexual abuse). Sullivan Atlantic Federal Savings & Loan 454 So.2d 52 (Fla. 4th DCA 1984) (holding that a cause of action for assault and battery cannot be based entirely

41 Entered on FLSD Docket 09/22/2008 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT'S MOTION TO DISMISS Plaintiff, Jane Doe No. 2,

N present ability to effectuate the attempt." An assault thus requires "an affirmative act—a threat to use force, or the actual exertion of force." Sullivan v. Ad. Fed. Say. & Loan Assoc., 454 So. 2d 52, 54 (Fla. 4th DCA 1984) (affirming dismissal of assault claim where there was no affirmative act). I

40 Entered on FLSD Docket 09/04/2008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. MOTION TO DISMISS Defendant Jeffrey Epstein, pursuant to Rule 12(b) of the Federal Rules of Civi

a situation where there was tremendous controversy over what happened in the case and whether or not the prosecutors went off the reservation. Judge Sullivan — and there were three or four independent — not independent, DOJ inquiries into the very same matter. But Judge Sullivan wanted his own opportunity

e. Thank you. THE COURT: Thanks very much. MR. EDWARDS: I believe my next client who is going to speak is probably going to speak as Jane Doe. JANE DOE NO. 1: Yes, Jane Doe. THE COURT: We'll say Jane Doe No. 1, just for the record. JANE DOE NO. 1: Okay. Thank you for allowing us to speak today.