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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
ginning of an act which, if consummated, constitutes battery." 3A FIa.Jur.2d Assault §1. An assault and battery are intentional acts. See generally, Spivey I. Battaglia 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co. I. PCR, Inc. 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawful offer of corp
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
ginning of an act which, if consummated, constitutes battery." 3A Fla.Jur.2d Assault §1. An assault and battery are intentional acts. See generally, Spivey I. Battaglia, 258 So.2d 815 (Fla. 1972); and Travelers Indem. PCR Inc., 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawful offer of corporal
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
ginning of an act which, if consummated, constitutes battery." 3A FIa.Jur.2d Assault §1. An assault and battery are intentional acts. See generally Spivey I. Battaglia, 258 So.2d 815 (Fla. 1972); and Travelers Indem. PCR, Inc., 889 So.2d 779 (Fla. 2004). On the face of the Complaint, the applicable four year stat
Entities connected to both Jane Doe and Spivey I. Battaglia

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
Alan Dershowitz
PERSONRobert D. Critton
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSONSouthern District
LOCATIONRobert C. Josefsberg
PERSONStuart S. Mermelstein
PERSON
United States District Court
ORGANIZATIONAtterbury Goldberger & Weiss
ORGANIZATION
Jeffrey Marc Herman
PERSON
Supreme Court
ORGANIZATION
Wilbur Ross
PERSONLuttier & Coleman
ORGANIZATIONCoconut Grove
LOCATIONFL Bar No.
ORGANIZATIONthe State of New York
LOCATION