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use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
battery." 3A Fla.Jur.2d Assault §1. An assault and battery are intentional acts. See generally Spivey I. Battaglia, 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co.'. PCR. Inc., 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawful offer of corporal injury to another by force, or exertion of
t makes sensitive allegations of sexual assault and abuse upon her when she was a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
s battery." 3A Fla.Jur.2d Assault §1. An assault and battery are intentional acts. See generally Spivey'. Battaglia, 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co.". PCR. Inc. 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawful offer of corporal injury to another by force, or exertion of
use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan
battery." 3A FIa.Jur.2d Assault §1. An assault and battery are intentional acts. See generally, Spivey I. Battaglia 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co. I. PCR, Inc. 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawful offer of corporal injury to another by force, or exertion of
use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York, and presently serving a prison sentence In Palm Beach County, Florida for, inter alia solicitation of prostitution and solicitation of minors to e
battery." 3A Fla.Jur.2d Assault §1. An assault and battery are intentional acts. See generally, Spivey'. Battaglia, 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co.'. PCR, Inc., 889 So.2d 779 (Fla. 2004). On the face of the Complaint, the applicable four year statute of limitations has expired, and accordi
515 N. Flagler Drive West Palm Beach, FL 33401 upon an oral examination before a Notary Public or officer authorized by law to take depositions in the State of New York. The oral examination will continue from day to day until completed. The depositions are being taken for purposes of discovery, for use at trial or
then apply to the court having personal jurisdiction over the witness for the process necessary to secure the attendance of the witness. Id. (citing Travelers Indem. Co. v. Hill 388 So.2d 648 (Fla. 5th DCA 1980)). See Greenliaht Financial Services. Inc. v. Union America M ortg.. Inc. 971 So.2d 983 (Fla. 3" DCA
Entities connected to both the State of New York and Travelers Indem

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONRobert D. Critton
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Julie K. Brown
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSON
Supreme Court
ORGANIZATIONLoxahatchee
LOCATIONFL Bar No.
ORGANIZATION