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(

a legally cognizable right of action"}, on the assumption that all the allegations in the complaint are true (even if doubtful in fact}, see, e.g., Swierkiewicz v. Sorema N. A., 534 U.S. 506, 508, n. 1, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002}; Neitzke v. Williams, 490 U.S. 319, 327, 109 S.Ct. 1827, 104 L.Ed.2d

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

a legally cognizable right of action"), on the assumption that all the allegations in the complaint are true (even if doubtful in fact), see, e.g., Swierkiewicz v. Sorema N. A., 534 U.S. 506, 508, n. 1, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002); Neitzke v. Williams, 490 U.S. 319, 327, 109 S.Ct. 1827, 104 L.Ed.2d

Docket 03/03;2010 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before the Court upon Defendant Jeffrey Epstein ("Defendant")'s Motion to Dismiss, for More Definite Statement &

stein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to Jane Doe). See DE 38-2 at ¶ 4. Finally, Defendant argues, and Plaintiff concedes, that punitive damages are not available under 18 U.S

ICO statement that the "enterprise" consisted of Defendant Epstein, and his paid employees and . See Am. Comp. ¶

. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before

ot contain enough information to allow a responsive pleading to be framed, the proper motion to be filed is a motion for a more definite statement. Swierkiewicz v. Sorema N.A., 534 U.S. 506, 514 (2002); Sisk v. Texas Parks and Wildlife Dep't, 644 F.2d 1056, 1059 (5'h Cir. 1981).' Courts typically grant motio

The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern

stein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to Jane Doe). See DE 38-2 at ¶ 4. Finally, Defendant argues, and Plaintiff concedes, that punitive damages are not available under 18 U.S

ICO statement that the "enterprise" consisted of Defendant Epstein, and his paid employees Sarah Kellen and Nadia Ma

. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before

ot contain enough information to allow a responsive pleading to be framed, the proper motion to be filed is a motion for a more definite statement. Swierkiewicz v. Sorema N.A., 534 U.S. 506, 514 (2002); Sisk v. Texas Parks and Wildlife Dep't 644 F.2d 1056, 1059 (5' Cir. 1981)) Courts typically grant motions

The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern

stein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to Jane Doe). See DE 38-2 at ¶ 4. Finally, Defendant argues, and Plaintiff concedes, that punitive damages are not available under 18 U.S

ICO statement that the "enterprise" consisted of Defendant Epstein, and his paid employees and Sec Am. Comp. 1 43

. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before

ot contain enough information to allow a responsive pleading to be framed, the proper motion to be filed is a motion for a more definite statement. Swierkiewicz v. Sorema N.A., 534 U.S. 506, 514 (2002); Sisk v. Texas Parks and Wildlife Dep't 644 F.2d 1056, 1059 (5' Cir. 1981)) Courts typically grant motions

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

are true (even if doubtful in fact), see, e.g., Swierkiewicz v. Sorema N. A., 534 U.S. 506, 508, n. 1, 122 S.

1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80119-CIV-MARRA Jane Doe No. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. _______________________________/ OPINION AND ORDER ON MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT THIS CAUSE is before the

ed as less likely to complain to authorities or have credibility if allegations of improper conduct were made. Id. This was an important element of Epstein’s plan. Id. Defendant’s plan and scheme reflected a particular pattern and method. Am. Compl. ¶ 11. Upon arrival at Defendant’s mansion, the underag

ENT THIS CAUSE is before the Court upon Defendant Jeffrey Epstein (“Defendant”)’s Motion to Dismiss and Mo

entitlement to relief, and the statement must “give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests.” Swierkiewicz v. Sorema N.A., 534 U.S. 506, 512 (2002) (citing Fed. R. Civ. P. 8); see also Bell Atlantic Corp. v. Case 9:08-cv-80119-KAM Document 54 Entered o

02/12/2009 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80119-CIV-MARRA Jane Doe No. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT THIS CAUSE is before the Court upon Defendant Jeffrey E

ed as less likely to complain to authorities or have credibility if allegations of improper conduct were made. Id. This was an important element of Epstein's plan. Id. Defendant's plan and scheme reflected a particular pattern and method. Am. Compl. ¶ 11. Upon arrival at Defendant's mansion, the undera

0119-CIV-MARRA Jane Doe No. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION

e on its face."). As a general matter, I am loath to assume that the Supreme Court circumvented the normal channels for amending the Federal Rules. Swierkiewicz I Sorema, 534 U.S. 506, 515 (2002) ("A requirement of greater specificity for particular claims is a result that must be obtained by the process of

02/12/2009 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80119-CIV-MARRA Jane Doe No. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT THIS CAUSE is before the Court upon Defendant Jeffrey E

ed as less likely to complain to authorities or have credibility if allegations of improper conduct were made. Id. This was an important element of Epstein's plan. Id. Defendant's plan and scheme reflected a particular pattern and method. Am. Compl. ¶ 11. Upon arrival at Defendant's mansion, the undera

0119-CIV-MARRA Jane Doe No. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION

e on its face."). As a general matter, I am loath to assume that the Supreme Court circumvented the normal channels for amending the Federal Rules. Swierkiewicz I Sorema, 534 U.S. 506, 515 (2002) ("A requirement of greater specificity for particular claims is a result that must be obtained by the process of