Epstein Secrets

261 at *7 (D.N.J. May 24, 2005); Clohessy v. St. Francis Hosp. & Healthcare, No. 98-C-4818, 1999 WL 46898

testimony, she was brought by another minor girl (Jane Doe No. 3) to EPSTEIN's Palm Beach home the one time

District Court for the Northern District of Florida confirmed this position and specifically rejected the plaintiffs' contrary argument. See Doe v. Francis, No. 5:03 CV 260, 2005 WL 950623, at *2 (N.D. Fla. 2005). The plaintiffs there argued that "the stay should be lifted due to the fact that the mino

ered on FLSD Docket 08/12/2008 Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida .... " See In re. Jane Doe, Case No. 08-80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14), Deel. of AUSA Villafana, 07/09/08, ,i 5, attached hereto as Exhibit "A" (emphasis added).

ope. Defendant’s argument of statutory construction fails. The single case cited by Defendant in support of his motion is not on point. In Doe 1 v. Francis, No. 5:03CV260/MCR/WCS, 2005 WL 517847 (N.D. Fla. Feb. 10, 2005), the stay was entered because criminal charges had been filed against the defendant

ISTRICT OF FLORIDA NO. 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant.

abuse. This argument is unsupported by the statute or its underlying policies. The unpublished, trial court decisions cited by Defendant of Doe v. Francis, 2005 WL 517487 (N.D. Fla. Apr. 20, 2005) (Francis I) and Doe v. Francis, 2005 WL 950623 (N.D. Fla. Apr. 20, 2005) (Francis II) are readily disting

r No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs Jane Doe 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 CERTIFICATE OF SERVICE I hereby certify

05 WL 517847, at *1-2 (N.D. Fla. Feb. 10, 2005) (Francis I) (staying federal civil action in favor of "a cri

OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend

TRICT OF FLORIDA NO. 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defenda

pe. Defendant's argument of statutory construction fails. The single case cited by Defendant in support of his motion is not on point. In Doe 1 v. Francis, No. 5:03CV260/MCR/WCS, 2005 WL 517847 (N.D. Fla. Feb. 10, 2005), the stay was entered because criminal charges had been filed against the defendant