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

d Assault §1. An assault and battery are intentional acts. See generally, Spivey'. Battaglia, 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co.'. PCR, Inc., 889 So.2d 779 (Fla. 2004). On the face of the Complaint, the applicable four year statute of limitations has expired, and accordingly, Count I is

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

.2d Assault §1. An assault and battery are intentional acts. See generally, Spivey. Battaglia 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co... PCR, Inc., 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawful offer of corporal injury to another by force, or exertion of force directed t

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

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 statute of limitations has expired, and accordingly, Count I is