Epstein Secrets

g., Lopez I. Davis, 531 U.S. 230, 241 (2001) (noting Congress' "use of a mandatory `shall' to impose discretionless obligations") (emphasis added); Lexecon Inc. I Milberg Weiss Bershad Hynes & Lerach, 523 U.S. 26, 35 (1998) (explaining that "the mandatory `shall' . . . normally creates an obligation impervi

us conduct would cause emotional trauma and damage to Jane Doe. 24. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiff Jane Doe No. 2 demands judgment against Defendant Jef

turned executed" as the proper Event. (Ik) (Entered: 05/27/2008) 05/29/2008 2 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doc. (Attachments: #J, Exhibit A and B, #2 Text of Proposed Order Default Ord)(Horowitz, Adam) (Entered: 05/29/2008) 06/06/2008 8 CLERK'S NOTICE Denyi

se discretionless obligations") (emphasis added); Lexecon Inc. v. Mi/berg Weiss Bershad Hynes & Lerach, 523 U.S

OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend

.g., Lopez v. Davis, 531 U.S. 230, 241 (2001) (noting Congress' use of a mandatory `shall' to impose discretionless obligations") (emphasis added); Lexecon Inc. v. Milberg Weiss Bershad Hynes & Lerach, 523 U.S. 26, 35 (1998) (explaining that "the mandatory `shall' . . . normally creates an obligation imperv

lm Beach state court, the other in Miami federal court. Both cases purport to arise from the same occurrence: the alleged sexual assault of a minor, Jane Doe No. 2. A federal statute directly on point provides that when an alleged sexual assault involving a child victim results in a "criminal proceeding,

g., Lopez v. Davis, 531 U.S. 230, 241 (2001) (noting Congress' "use of a mandatory `shall' to impose discretionless obligations") (emphasis added); Lexecon Inc. v. Milberg Weiss Bershad Hynes & Lerach, 523 U.S. 26, 35 (1998) (explaining that "the mandatory `shall' . . . normally creates an obligation imperv

lm Beach state court, the other in Miami federal court. Both cases purport to arise from the same occurrence: the alleged sexual assault of a minor, Jane Doe No. 2. A federal statute directly on point provides that when an alleged sexual assault involving a child victim results in a "criminal proceeding,

.g., Lopez v. Davis, 531 U.S. 230, 241 (2001) (noting Congress' use of a mandatory `shall' to impose discretionless obligations") (emphasis added); Lexecon Inc. v. Milberg Weiss Bershad Hynes & Lerach, 523 U.S. 26, 35 (1998) (explaining that "the mandatory `shall' . . . normally creates an obligation imperv

tted willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 26. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had

g., Lopez v. Davis, 531 U.S. 230, 241 (2001) (noting Congress' "use of a mandatory 'shall' to impose discretionless obligations") (emphasis added); Lexecon Inc. v. Milberg Weiss Bershad Hynes & Lerach, 523 U.S. 26, 35 (1998) (explaining that "the mandatory 'shall' . . . normally creates an obligation imperv

ction. Introduction This lawsuit arises from a pending federal criminal action concerning, among other things, an alleged assault of the plaintiff Jane Doe, who, according to her complaint, on "numerous occasions" provided "massages" to Epstein with "no credentials to provide massage therapy" and was "

e.g., Lopez' Davis, 531 U.S. 230, 241 (2001) (noting Congress' "use of a mandatory `shall' to impose discretionless obligations") (emphasis added); Lexecon Inc. I. Milberg Weiss Bershad Hynes & Lerach, 523 U.S. 26, 35 (1998) (explaining that "the mandatory `shall' . . . normally creates an obligation imperv

ction. Introduction This lawsuit arises from a pending federal criminal action concerning, among other things, an alleged assault of the plaintiff Jane Doe, who, according to her complaint, on "numerous occasions" provided "massages" to Epstein with "no credentials to provide massage therapy" and was "