Epstein Secrets

use such contact or the apprehension that such contact is imminent”. See Paul v. Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta v. Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plaintiff’s dress, and that there was an ac

tute, as follows: (i) Allegation in Complaint. Epstein used a facility or means of interstate commerce to knowingly persuade, induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or sexual activity for which any person can be charged with a criminal offense;

of a harmful or offensive contact upon another with the intent to cause such contact or the apprehension that such contact is imminent”); Scelta v. Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plaintiff’s dress, and that there was an a

_______________________________/ PLAINTIFF’S MEMORANDUM IN RESPONSE TO DEFENDANT’S MOTION TO DISMISS Plaintiff, Jane Doe No. 2, (“Jane” or “Jane Doe”), by and through her undersigned counsel, files this Memorandum in Response to Defendant’s Motion to Dismiss, and states as follows: 1. Defendant

t to cause such contact or the apprehension that such contact is imminent". See Paul Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plaintiff's dress, and that there was an ac

d "Factual Allegations" each describes the plan and scheme of Defendant Epstein to recruit underage girls to his Palm Beach mansion for "massages". (Jane Doe No. 2 Amd. Compl. '111 10-11; Jane Doe No. 3 Amd. Comp.1 10-11; Jane Doe No. 4 Amd. Compl. 111-12; Jane Doe No. 5 Amd. Compl. 1 10-11; Jane Doe No.

t to cause such contact or the apprehension that such contact is imminent". See Paul Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plaintiff's dress, and that there was an ac

d "Factual Allegations" each describes the plan and scheme of Defendant Epstein to recruit underage girls to his Palm Beach mansion for "massages". (Jane Doe No. 2 Amd. Compl. '111 10-11; Jane Doe No. 3 Amd. Comp.1 10-11; Jane Doe No. 4 Amd. Compl. 111-12; Jane Doe No. 5 Amd. Compl. 1 10-11; Jane Doe No.

t to cause such contact or the apprehension that such contact is imminent". See Paul Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plaintiff's dress, and that there was an ac

d "Factual Allegations" each describes the plan and scheme of Defendant Epstein to recruit underage girls to his Palm Beach mansion for "massages". (Jane Doe No. 2 Amd. Compl. '111 10-11; Jane Doe No. 3 Amd. Comp.1 10-11; Jane Doe No. 4 Amd. Compl. 111-12; Jane Doe No. 5 Amd. Compl. 1 10-11; Jane Doe No.