Epstein Secrets

added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appropriate United States District Court."' Id, at 1189. See also Tilton v. Playboy Entertainment Group, Inc., 554 F.3d 1371 (11th Cir. Jan. 15, 2009)(District Court granted plaintiff "the minimum 'actual damages' prescr

2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. I ------------ JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ___________ __;/ JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________ / JANE DOE NO. 5, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ___________ _

e violations, all counts and violations must be lumped together as one with a single penalty. Multiple counts are proper, as shown, for example, in Tilton v. Playboy Entertainment Group, Inc., 554 F.3d 1371, 1375 (11th Cir. 2009), on which Defendant relies in his Motion. (Motion 34). In Tilton, the co

D BY DEFENDANT'S NOTICE OF WITHDRAWAILDE ARGUMENTS I THROUGH VII OF DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT Plaintiff, Jane Doe No. 101, by and through her undersigned attorneys, hereby responds to Defendant's Motion to Dismiss Plaintiff's First Amended Complaint [D.E. 29] ("

cases involving this defendant in this Court) involved a single count predicated on multiple alleged violations of predicate criminal statutes. See Tilton v. Playboy Entertainment Grotto. Inc., 554 F.3d 1371 (11th Cir. Jan. 15, 2009); Smith, 428 F. Supp. 2d at 432; Doe, 478 F. Supp. 2d at 754; Doe No.

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

cases involving this defendant in this Court) involved a single count predicated on multiple alleged violations of predicate criminal statutes. See Tilton v. Playboy Entertainment Grotto. Inc., 554 F.3d 1371 (11th Cir. Jan. 15, 2009); Smith, 428 F. Supp. 2d at 432; Doe, 478 F. Supp. 2d at 754; Doe No.

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

cases involving this defendant in this Court) involved a single count predicated on multiple alleged violations of predicate criminal statutes. See Tilton v. Playboy Entertainment Grotto. Inc., 554 F.3d 1371 (11th Cir. Jan. 15, 2009); Smith, 428 F. Supp. 2d at 432; Doe, 478 F. Supp. 2d at 754; Doe No.

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

cases involving this defendant in this Court) involved a single count predicated on multiple alleged violations of predicate criminal statutes. See Tilton v. Playboy Entertainment Grotto. Inc., 554 F.3d 1371 (11th Cir. Jan. 15, 2009); Smith, 428 F. Supp. 2d at 432; Doe, 478 F. Supp. 2d at 754; Doe No.

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

phasis added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appropriate United States District Court.'" Id, at 1189. In Tilton v. Playboy Entertainment Group Inc 554 F.3d 1371 (11th Cir. Jan. 15, 2009), the District Court granted plaintiff "the minimum 'actual damages' pres

of sexual exploitation and abuse. In the Jane Doe II state action, an Order was entered reassigning the state action to a Division in which other Jane Doe cases against EPSTEIN had been filed. See "Clerk's Notice Of Reassignment," dated April 10, 2009, and attached hereto as Exhibit B. The state court

violation is different. There is no language in the statute that prohibits the Plaintiff from suing for each violation, and the dicta set forth in Tilton v. Playboy Entertainment Group, Inc., 554 F. 3d 1371 (11th Cir. 2009), vaguely noting that the District Court awarded the Plaintiff "the minimum 'a

TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defen

cases involving this defendant in this Court) involved a single count predicated on multiple alleged violations of predicate criminal statutes. See Tilton v. Playboy Entertainment Grotto. Inc., 554 F.3d 1371 (11th Cir. Jan. 15, 2009); Smith, 428 F. Supp. 2d at 432; Doe, 478 F. Supp. 2d at 754; Doe No.

Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED

cases involving this defendant in this Court) involved a single count predicated on multiple alleged violations of predicate criminal statutes. See Tilton Playboy Entertainment Group. Inc., 554 F.3d 1371 (I lth Cir. Jan. 15, 2009); Smith, 428 F. Supp. 2d at 432; Doe, 478 F. Supp. 2d at 754; poc No. 2

IM G., the first victim identified in PBPD's investigation. Plaintiff filed motion to remand to state court, which was granted by Judge Marra. 2. Jane Doe #2I. Epstein, 08-CV-80 I 19-KAM: Complaint filed on February 6, 2008, alleging: sexual assault (Count l), and intentional infliction of emotional di