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

that your office advise what Statute or Code that letter was referring to. Finally, we would like to schedule the depositions of FBI Special Agents Nesbitt Kirkendall, Junior Ortiz and Mr. Solomon. Please let me know who we need to direct our subpoenas to in order to schedule these depositions. I appreciate your

about the possible existence of CSAM among images the Estate had just discovered. Exs. 4 and 5. The Estate...advised counsel for the Government and Jane Doel of its concern that some of the Epstein Media might contain child sex abuse imagery ("CSAM"). The knowing accessing, possession, or distribution or

former FBI agents, employees, administrators, and/or representatives with knowledge about FBI protocols, guidelines, procedures and practices 26. Nesbitt Kirkendall and other current and former FBI agents, employees, administrators, and/or representatives with knowledge about any investigations into the Epstein

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

that your office advise what Statute or Code that letter was referring to. Finally, we would like to schedule the depositions of FBI Special Agents Nesbitt Kirkendall, Junior Ortiz and Mr. Solomon. Please let me know who we need to direct our subpoenas to in order to schedule these depositions. I appreciate your