Epstein Secrets

les his Reply to Plaintiff's Response In Opposition to Defendant's Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Doe's Amended Complaint, With Incorporated Memorandum of Law. In support of his motion, Defendant states: I. Introduction a. The Amended Complaint, Th

lorida looks to Federal authority regarding the interpretation and application of its Acts, citing 18 U.S.C. 1961, et seq. and Fla. Stat. 772.104); O'Malley v. St.. Thomas Univ.. Inc., 599 So.2d 999, 1000 (Ha. 3d DCA 1992)("Since Florida Rico is patterned after Federal RICO. . . .[f]ederal decisions sho

les his Reply to Plaintiff's Response In Opposition to Defendant's Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Doe's Amended Complaint, With Incorporated Memorandum of Law. In support of his motion, Defendant states: I. Introduction a. The Amended Complaint, Th

lorida looks to Federal authority regarding the interpretation and application of its Acts, citing 18 U.S.C. 1961, et seq. and Fla. Stat. 772.104); O'Malley v. St.. Thomas Univ.. Inc., 599 So.2d 999, 1000 (Ha. 3d DCA 1992)("Since Florida Rico is patterned after Federal RICO. . . .[f]ederal decisions sho

eorgia before a Georgia notary), DE 4-2, Jane Doe No. I v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."). DE 5-2, Jane Doe No. I v. Epstein, Case No. 08-80

indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO."' (quoting O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-in

laintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Doe's Amended Complaint, With Incorporated Memorandum Of Law Defendant, Jeffery Epstein, by and through his undersigned counsel, moves to dismiss and fo

lorida looks to Federal authority regarding the interpretation and application of its Acts, citing 18 U.S.C. 1961, et seq. and Fla. Stat. 772.104); O'Malley v, St,„ Thomas Univ.. Inc., 599 So.2d 999, 1000 (FM. 3d DCA 1992)flince Florida Rico is patterned after Federal RICO. .. .[f]ederal decisions should

Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLI

'indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO." (quoting O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-in

eorgia before a Georgia notary), DE 4-2, Jane Doe No. I v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."), DE 5-2, Jane Doe No. I v. Epstein, Case No. 08-80

indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO."' (quoting O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-in

eorgia before a Georgia notary), DE 4-2, Jane Doe No. 1 v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."), I)E 5-2, Jane Doe No. I v. Epstein, Case No. 08-8

indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO."' (quoting O'Malley v. St. Thomas Univ., Inc., 599 M. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-inj

eorgia before a Georgia notary), DE 4-2, Jane Doe No. l v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."). DE 5-2, Jane Doe No. I v. Epstein, Case No. 08-80

'indirect injuries, that is injuries sustained not as a direct result of predicate acts . . wit! not allow recovery under Florida RICO."' (quoting O'Malley v. St. Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-injury