Epstein Secrets

Point EFTA00175272 Case 9:09-cv-80469-KAM Document 31 Entered on FLSD Docket 06/01/2009 Page 11 of 11 Jane Doe II v. Epstein, et al. Page 11 Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 F isidrogarcia(a:bellsouth.net Counsel for Plaintiff Jack A

ant Jeffrey Epstein Date Filed: 03/24/2009 Jury Demand: Plaintiff Nature of Suit: 360 P.I.: Other Jurisdiction: Federal Question represented by Isidro Manuel Garcia Garcia Elkins & Boehringer 224 Datura Avenue Suite 900 West Palm Beach , FL 33401 I - Email:11111 LEAD ATTORNEY TO BE NOTICED represented by Mi

tive date, undoubtedly impose on employers found liable a "new disability" in respect to past events. See Society for Propagation of the Gospel, 22 F. Cas. at 767. The extent of a party's liability, in the civil context as well as the criminal, is an important legal consequence that cannot be ignored.

Dismiss must be denied; however, if the Court determines otherwise, Plaintiff respectfully requests leave to amend. Respectfully submitted, BY: s/ Isidro M. Garcia ISIDRO M. GARCIA Florida Bar No. AIR IA LAW FIRM P.A. West Palm Beach, FL 33401 Telephon Telecopie e-mail CERTIFICATE OF SERVICE ft bellsouth

tive date, undoubtedly impose on employers found liable a "new disability" in respect to past events. See Society for Propagation of the Gospel, 22 F. Cas. at 767. The extent of a party's liability, in the civil context as well as the criminal, is an important legal consequence that cannot be ignored.

Dismiss must be denied; however, if the Court determines otherwise, Plaintiff respectfully requests leave to amend. Respectfully submitted, BY: s/ Isidro M. Garcia ISIDRO M. GARCIA GARCIA LAW FIRM, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 19 EFTA00222860 Case 9:09-cv-80469-KAM Documen

tive date, undoubtedly impose on employers found liable a "new disability" in respect to past events. See Society for Propagation of the Gospel, 22 F. Cas. at 767. The extent of a party's liability, in the civil context as well as the criminal, is an important legal consequence that cannot be ignored.