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

right to relief above the speculative level, see 5 . Wright & A. Miller Federal Practice and EFTA00175819 Case 9:08-cv-t... j80-KAM Documc . 54 Enterer.. A FLSD Docket 10/...2008 Page 4 of 10 Case No. CV-80380-Marra-Johnson Page No. 4 Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright

roperly respond. Accordingly, under applicable law, Plaintiff has failed to state a claim for EFTA00175821 Case 9:08-cv-b..080-KAM Docume... 54 Enterer., ...1 FLSD Docket 10/G 1008 Page 6 of 10 Case No. CV-80380-Marra-Johnson Page No. 6 "sexual assault and battery" has Plaintiff has failed to ple

led by Jeffrey Epstein. (Tein, Michael) (Entered: 09/05/2008) 09/15/2008 22 r 3" KB REPLY to Response to Motion re 11 MOTION to Remand filed by Jane Doe. (Kuvin, Spencer) (Entered: 09/15/2008) 09/16/2008 21 r 893 KB NOTICE of Substitution of Counsel by Theodore Jon Leopold on behalf ofJane Doe (

hway Safety and motor vnhicl es, the Deportmeni of Corrections, the Departierau of ./us,.. win EFTA00175579 Case 9:08-cv-80... .-KAM DocileT , - Enterer, . FLSD Docil18/ ,_ A Page 13 of 21 Justice, the personnel of those departments, or any individual or ontity acting at the request or upon the di

e 200 Palm Beach Gardens. FL 33410 Telephone: Facsimile: Counsel for Plaintiff Jane Doe 10 EFTA00175566 Case 9:08-cv-‘_ov4-KAM Document . . Enterer ,.. .-LSD Docket 08/18/2 Page 11 of 11 SERVICE LIST Doe'. Epstein, et. al. CASE NO: 08-80804-Civ-MARRA/JOHNSON United States District Court, Sou

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

this action. However, for purposes of this motion, the relevant statutory language is the same. EFTA00175855 Case 9:08-cv-' 81-KAM Document 52 Enterer FLSD Docket 10/ ?008 Page 8 of 10 Case No. CV-80381-Marra-Johnson Page No. 8 the case of a person under a legal disability, not later than thre

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

torneys for Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: Fax: - 6 - EFTA00175649 Case 9:08-cv-L .19-KAM Docuri. 142 Enterer .1 FLSD Docket 09,.. i2008 Page 7 of 8 CERTIFICATE OF SERVICE I hereby certify that on September 22, 2008, I electronically filed the foregoing do

a right to relief above the speculative level, see 5 Wright & A. Miller, Federal Practice and EFTA00175635 Case 9:08-cv-i„ .19-KAM Docuri, 146 Enterer, ...i FLSD Docket 10i„,2008 Page 4 of 10 Case No. CV-80119-Marra-Johnson Page No. 4 Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wrigh

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

74. Although the complaint need not provide detailed factual allegations, the basis for relief EFTA00175733 Ca'Se 9:08-cv-t. 2-KAM Document 41 Enterer FLSD Docket 10/0 )8 Page 3 of 10 Case No. CV-80232-Marra-Johnson Page No. 3 in the complaint must state "more than labels and conclusions, and