Epstein Secrets

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

act, and Jane Doe was thereby put in such imminent apprehension. 17. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane Poe, creating a reasonable fear of imminent peril. 18. Epstein intentionally inflicted harmful or offensive contact on the person &Jane Doe, with the

ntiff's claims are barred by the applicable statute of limitations. WHEREFORE Defendant requests that this Court deny the roll sought by Plaintiff. Robert D. C on, Jr. Attorney fo efendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the

eges that "Epstein committed willful acts of child sexual abuse" on her, which resulted in "mental or sexual injury," and "caused or likely to cause Jane Doe's mental or emotional health to be significantly impaired." 2d Am. Complaint, ¶25. The information sought is dearly relevant to the injuries and dama

by letters in a good faith effort to resolve the discovery issues prior to the filing of this motion to compel. Some of the issues were resolved. Robert D. C on, Jr. Attorney fo Defendant Epstein EFTA00222132 Case 9:08-cv-80119-KAM Document 68 Entered on FLSD Docket 04/02/2009 Page 9 of 9 Doe 2 v.

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. 27. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had

ntiffs claims are barred by the applicable statute of limitations. WHEREFORE Defendant requests that this Court deny the rail .ought by Plaintiff. Robert D. C on, Jr. Attorney for P efendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with