Epstein Secrets

im for damages. whether pursuant to state. federal or common law". Exhibit 2, NPA 1 8. More is required of a plaintiff than to simply allege, as did Jane Doc 101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended Complaint 1 24. Such an averment satisfies only the e

Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 25. Epstein's conduct caused severe emotional distress to Janc Doe. Epstein knew or had

were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 25. Epstein's conduct caused severe emotional distress to Janc Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional distress and damage to Jane Doe, or Epstein a

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

ssues Mr. Epstein, through counsel, has fully remedied any perceived breach. Please advise if you for any reason disagree. Respectfully submitted, Jay P. Le owiiz, P.C. Chicago Hong Kong London Los Angeles Munich San Francisco Washington, D.C. EFTA00194706 KIIUCLAND & ELLIS LLP CC: Jeffrey Slo

g to recall, because I know she was going less and less to his residence. Q. Do you recal1writing in this table cause affidavit that events —that Jane Doe you that Ka relationship continued to escalate during the period she saw Mr. Epstein? A. Fri:intik beginning, yes. Q. And Ws fair to say that so

d to speaking with you about this matter and your position on the SORA hearing in advance of our scheduled court date on November 9th. Sincerely, Jay P. Le t r 'tz, P.0 Sandra Lynn Musumeci IPL/slm Attachments EFTA00312755 EXHIBIT A EFTA00312756 Page 1 In 8I: I bityrAPED 1 WE RV1Rit O1 Sandy

7th Floor Ft. Lauderdale, FL 33394 Re: B.B. I. JEFFREY EPSTEIN OUR FILE NO.: 080303 Dear Ms. As you are aware, this firm represents Plaintiff, Jane Doe, a/k/a/ B.B. in the civil litigation against Jeffrey Epstein styled Jeffiey Epstein. case no.: 502008CA037319 MB AB. We are hereby requesting that

ssues Mr. Epstein, through counsel, has fully remedied any perceived breach. Please advise if you for any reason disagree. Respectfully submitted, Jay P. Le owifr, Chicago Hong Kong London Los Angeles Munich San Francisco Washington, EFTA00183752 KIRKLAND & ELLIS LLP . N.sq. Esq. EFTA0018375