Epstein Secrets

SON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT'S MOTION TO DISMISS Plaintiff, Jane Doe No. 2, ("Jane" or "Jane Doe"), by and through her undersigned counsel, files this Memorandum in Response to Defendant's Motion to Dismiss, and state

la. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease); see also Restatement (Second) of Torts Assault, § 21 (1965) (stating that an assault occurs when a person "acts intending to cause a harmful or offensive contact with the person of the other, or

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

la. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease); see also Restatement (Second) of Torts Assault, § 21 (1965) (stating that an assault occurs when a person "acts intending to cause a harmful or offensive contact with the person of the other, or

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 Doc. Epstein knew or had

la. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease); see also Restatement (Second) of Torts Assault, § 21 (1965) (stating that an assault occurs when a person "acts intending to cause a harmful or offensive contact with the person of the other, or