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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
inal case described in that motion (State of Florida • Jeffrey Epstein, Case No. 2006 CF 09454 AXX, Fifteenth Judicial Circuit, Palm Beach County) (the "Florida Criminal Action"). As explained below, the parallel federal criminal action against him described in that motion (In re Grand Jury, No. FGJ 07-103(WPB), United St
nt 38 Entered on FLSD Docket Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida . . .." See In re. Jane Doe, Case No. 08-80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14), Decl. of AUSA ;07/09/08, ¶ 5, attached hereto as Exhibit "A" (emphasis added). Under the A
milar to those in the instant actions (State of Florida v. Jeffrey Epstein, Case No. 2006 CF 09454, Fifteenth Judicial Circuit. Palm Beach County) (the "Florida Criminal Action")) Shortly thereafter, the United States Attorney's Office for the Southern District of Florida (the "USAO") began a federal grand-jury investigati
OF FLORIDA CASE NO.: 08-CV-80380-MARRA-JOHNSON JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defend
nal case described in that motion (State of Florida v. Jeffrey Epstein, Case No. 2006 CF 09454 AXX, Fifteenth Judicial Circuit, Palm Beach County) (the "Florida Criminal Action"). As explained below, the parallel federal criminal action against him described in that motion (In re Grand Jury, No. FGJ 07-103(WPB), United St
ered on FLSD Docket 08/12/2008 Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida . ... See In re. Jane Doe, Case No. 08-80736-CIV-Marrahlohn.son (S.D. Fla.) (DE 14), 07/09/08, 1 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the
milar to those in the instant actions (State of Florida v. Jeffrey Epstein, Case No. 2006 CF 09454, Fifteenth Judicial Circuit. Palm Beach County) (the "Florida Criminal Action")) Shortly thereafter, the United States Attorney's Office for the Southern District of Florida (the "USAO") began a federal grand-jury investigati
red on FLSD Docket 08/12/2008 Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida . . .." See In re. Jane Doe, Case No. 08-80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14), 07/09/08, 1 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the
milar to those in the instant actions (State of Florida v. Jeffrey Epstein, Case No. 2006 CF 09454, Fifteenth Judicial Circuit. Palm Beach County) (the "Florida Criminal Action")) Shortly thereafter, the United States Attorney's Office for the Southern District of Florida (the "USAO") began a federal grand-jury investigati
nt to justify keeping this document (filed ex parte) under seal. The Court is supported in this conclusion by its decision in a similar case, In re: Jane Doe, No. 08-80736-CIV (S.D. Fla. July 11, 2008), in which the Court unsealed, over the objection of the United States Attorney, documents containing si
nal case described in that motion (State of Florida v. Jeffrey Epstein, Case No. 2006 CF 09454 AXX, Fifteenth Judicial Circuit, Palm Beach County) (the "Florida Criminal Action"). As explained below, the parallel federal criminal action against him described in that motion (In re Grand Jury, No. FGJ 07-103(WPB), United St
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
nal case described in that motion (State of Florida v. Jeffrey Epstein, Case No. 2006 CF 09454 AXX, Fifteenth Judicial Circuit, Palm Beach County) (the "Florida Criminal Action"). As explained below, the parallel federal criminal action against him described in that motion (In re Grand Jury, No. FGJ 07-103(WPB), United St
red on FLSD Docket 08/12/2008 Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida . . .." See In re. Jane Doe, Case No. 08-80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14), Decl. of AUSA Villafana, 07/09/08, 1 5, attached hereto as Exhibit "A" (emphasis added). U
milar to those in the instant actions (State of Florida v. Jeffrey Epstein, Case No. 2006 CF 09454, Fifteenth Judicial Circuit. Palm Beach County) (the "Florida Criminal Action")) Shortly thereafter, the United States Attorney's Office for the Southern District of Florida (the "USAO") began a federal grand-jury investigati
Entities connected to both Jane Doe and the "Florida Criminal Action

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Adam D. Horowitz
PERSONLeon Black
PERSON
Alexander Acosta
PERSON
A. Marie Villafana
PERSON
Virginia Giuffre
PERSONStuart S. Mermelstein
PERSONFBI
ORGANIZATION
United States District Court
ORGANIZATION
Palm Beach County
LOCATION
Palm Beach
LOCATION
Jeffrey Marc Herman
PERSON
the United States District Court
ORGANIZATION