Epstein Secrets

11, Plaintiff "demands judgment against Defendant Jeffrey Epstein for all damages available under 28 U.S.C

0/06/2008 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. --------------'' DEFENDANT'S. EPSTEIN. MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT DIRECTED TO PLAINTIFF'S AMENDED COMPL

------------'' DEFENDANT'S. EPSTEIN. MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT DIRECTED TO PLAINTIFF'S AMENDED COMPLAINT Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves to dismiss and for more definite statement of Plaintiff JANE DOE NO. 2's Amended Complaint. Rules 12

ntiff "demands judgment against Defendant Jeffrey Epstein for all damages available under 28 U.S.C. §2255(

ntitle[ment] to relief' requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do, see Papasan v. Allain, 478 U.S. 265, 286, 106 S.Ct. 2932, 92 L.Ed.2d 209 (1986} (on a motion to dismiss, courts "are not bound to accept as true a legal conclu

age 11 of 50 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80811-MARRA/JOHNSON CAROLYN MARGARET ANDRIANO Plaintiff, V. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, NOTICE OF TAKING DEPOSITION PLEASE TAKE NOTICE that the undersigned attorney will take the deposition duces tecum

or use at trial, or for such other purposes as are permitted under the applicable Statutes of Rules~ Robert D. Critton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing document is being served this day on all counsel of record identified on

6 of 50 8. Presently pending before the Court is Defendant EPSTEIN's Motion to Compel Plaintiff C.M.A. to Respond t

8691 [email protected] Counsel tor Defendant Jeffrey Epstein Searcy Denney Scarola Barnhart & Sh

ntitle[ment] to relief' requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do, see Papasan v. Allain, 478 U.S. 265, 286, 106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are not bound to accept as true a legal conclu

lsd Page 1 of 15 LRJ U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80232-KAM Doe No. 3 v. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 2:flasaAhd Member case: (View Member Case) Case: 9:09-cv-80802-KAM Cause: 28:1332 Diversity-Perso

file this document. (Is) (Entered: 05/20/2009) 05/20/2009 2.$ NOTICE by C.M.A. of Filing Withdrawal of Previously Raised Objections to Defendant, Jeffrey Epstein's Motion to Compel And/Or Identify C.M.A. in the Style of This Case and Motion to Identify C.M.A. in Third-Party Subpoenas for Purposes of Discovery,

3/11/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 3. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 3. (Attachments: # 1 Exhibi

plicable statute of limitations. WHEREFORE Defendant requests that this Court deny the re ' f sought by Plaintiff. Robert D. C itton, Jr. Attorney f. Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also

entitle[ment] to relief' requires more than labels and conclusions, and a formuiic recitation of the elements of a cause of action will not do, see Papasan . Allain, 478 U.S. 265, 286, 106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are not bound to accept as true a legal conclus

- flsd ( Page 1 of 14 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80381-KAM Doe No. 5'. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 9:08-cv-80119-KAM Member case: (View Member Case] Case: 9:09-cv-80802-KAM Cause: 28:1332 Diversit

eth A. Marra on 5/20/2009. (1c3) (Entered: 05/20/2009) 05/20/2009 9B NOTICE by of Filing Withdrawal of Previously RaisedObjections to Defendant, Jeffrey Epstein's Motion to ConaitAnd/Or Identify . in the Style of This Case and Motion to IdentlfrM. in Third-Party Subpoenas for Purposes of Discovery, Or, Alter

4/17/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 5. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 5. (Attachments: # I Exhibi

5 1. JEFFREY EPSTEIN, Plaintiff, Defendant. DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES TO PLAINTIFF'S S

entitle[ment] to relief" requires more than labels and conclusions, and a formuiic recitation of the elements of a cause of action will not do, see Papasan . Allain, 478 U.S. 265, 286, 106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are not bound to accept as true a legal conclus

O PLAINTIFF JANE DOE N0.6'S COMPLAINT Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves t

/515-3148 Fax ( Co-Counsel for Defendant Jeffrey Epstein)

!h day of October, 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 1

e elements of a cause of action will not do, see Papasan v. Allain, 478 U.S. 265, 286, 106 S.Ct. 2932, 92