Epstein Secrets

ed this day on all counsel of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsb

tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the

ed this day on all counsel of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsb

tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the

ed this day on all counsel of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsb

tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the

d this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 26th day of May , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orsecic, P.A. 25 West Flagler Street, Suite 800 Fax• 105 15R-910 Counsellor Plaintiff Jack Alan Goldber

tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the

ed this day on all counsel of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsb

tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the

ography); and § 2252A(g) (engaging in a child exploitation enterprise). 12. Doe No. 102 I. Epstein, 09-CV-80656-KAM: This suit also was filed by Josefsberg's firm. On May I, 2009, Plaintiff filed suit alleging the same claims raised by Doe No. 101. Epstein has not yet filed his answer to that Complaint.

tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and, must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the F