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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
o state a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a
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
o state a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a
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
statute of limitations. As to Count I, which is plead pursuant to state law, it is well settled that this Court is to apply Florida law. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o)., Fla. Stat. §95.11(3
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 alio solicitation of prostitution and solicitation of minors to e
statute of limitations. As to Count I, which is plead pursuant to state law, it is well settled that this Court is to apply Florida law. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o)., Fla. Stat. §95.11(3
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
o state a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a
Entities connected to both the State of New York and I. Tompkins

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSONLeon Black
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONRobert D. Critton
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSON
Virginia Giuffre
PERSONSouthern District
LOCATION
Adam D. Horowitz
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSONMichael J. Pike
PERSON
Supreme Court
ORGANIZATIONFL Bar No.
ORGANIZATION