Epstein Secrets

Case 9:08-cv-80119-KAM Document 16-2 Entered on FLSD Docket 07/01/2008 Page 2 of 4 : tiP • ' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rtnivz•zrt : . • . 7 'Crt. Rep. lun,L__ Date : • -17 vcri J „Asir )----=-- • / PD e--P:9fot Pres, D

events or omissions giving rise to the claim occurred in this District. Factual Allegations 7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is hims

, represented by Assistant United States , and Mr. Epstein, entered into a deferred- prosecution agreement (

' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"r

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 jgoldberger®agwpa.com Attorneys for Defendant Jay Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 711.A.3 While defense counsel admittedly did not confer with plaintiffs' counsel prior to filing the moti

l distress based on the same factual allegations. Defendant Epstein has moved to dismiss only Count I of the Complai

' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rt

Twombley 127 5. Ct. 1955, 1965 (2007). Here, the factual allegations establish an intentional tort claim for sexual assault and battery.3 See Paul . Holbrook, 696 So.2d 1311 (Fla. 5th DCA 1997) ("[a] battery consists of the infliction of a harmful or offensive contact upon another with the intent to caus

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY E

all similarly structured and assert the same claims. In the section entitled “Factual Allegations” each describes the plan and scheme of Defendant Epstein to recruit underage girls to his Palm Beach mansion for “massages”. (Jane Doe No. 2 Amd. Compl. ¶¶ 10-11; Jane Doe No. 3 Amd. Comp. ¶ 10-11; Jane

federal statutory claim “as she would have had if Mr. Epstein had been tried federally and 7 Case 9:08-cv-80

llegations” each describes the plan and scheme of Defendant Epstein to recruit underage girls to his Palm Beach mans

Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 5

a harmful or offensive contact upon another with the intent to cause such contact or the apprehension that such contact is imminent”. See Paul v. Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta v. Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegati

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ PLAINTIFF’S MEMORANDUM IN RESPONSE TO DEFENDANT’S MOTION TO DISMISS Plaintiff, Jane

ions of Jeffrey Epstein; Count II alleges the tort of intentional infliction of emotional distress based on the same factual allegations. Defendant Epstein has moved to dismiss only Count I of the Complaint, contending that Plaintiff has failed to state a claim. Simultaneously herewith, Plaintiff inte

distress based on the same factual allegations. Defendant Epstein has moved to dismiss only Count I of the Complai

o Dismiss, and states as follows: 1. Defendant, Jeffrey Epstein is alleged to have sexually abused Jane D

bley, 127 5. Ct. 1955, 1965 (2007). Here, the factual allegations establish an intentional tort claim for sexual assault and battery.3 See Paul v. Holbrook, 696 So.2d 1311 (Fla. 5th DCA 1997) (“[a] battery consists of the infliction of a harmful or offensive contact upon another with the intent to caus

2008 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT'S MOTION TO DISMISS Plaintiff, Jane Doe No. 2, ("Jane" or "Jane Doe"), by and through

tions of Jeffrey Epstein; Count II alleges the tort of intentional infliction of emotional distress based on the same factual allegations. Defendant Epstein has moved to dismiss only Count I of the Complaint, contending that Plaintiff has failed to state a claim. Simultaneously herewith, Plaintiff inten

l distress based on the same factual allegations. Defendant Epstein has moved to dismiss only Count I of the Complai

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MEMORANDUM IN R

Twombley 127 5. Ct. 1955, 1965 (2007). Here, the factual allegations establish an intentional tort claim for sexual assault and battery.3 See Paul . Holbrook, 696 So.2d 1311 (Fla. 5th DCA 1997) ("[a] battery consists of the infliction of a harmful or offensive contact upon another with the intent to caus

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

tion of a harmful or offensive contact upon another with the intent to cause such contact or the apprehension that such contact is imminent. Paul v. Holbrook, 696 So.2d 1311, 1312 (Fla. 5th DCA 1997); Sullivan v. Atlantic Fed. Sav. & Loan Ass'n, 454 So.2d 52, 54 (Fla. 4th DCA 1984), review denied, 461 So.2

TIEFEL,WILLIAM SMITH,HAROLD B COLE,JEFFREY A BRAUER,CAMILLA T LUBOTTA,JACK

OBERT A THE BREAKERS PALM BEACH INC EPSTEIN,JEFFREY TIEFEL,WILLIAM R MCCLOSKEY,

SHIPMAN,ROBERT ROSENBERG,STEVEN P HOLBROOK,CHRISTOPHER SULLIVAN,MELISSA FALKOF

From: Jeffrey Epstein [[email protected]] Sent: 1/12/2010 12:28:25 AM To: Peggy Siegal (i | Subject: Re: My Wall Street 2 Story terrific. i want to hear more about t

From: Jeffrey Epstein [[email protected]] Sent: 1/12/2010 12:28:25

the culture of Wall Street, Stone has said that part of the film is a defense of capitalism, his father's vision of finance (as seen through the Hal Holbrook character) and an homage to his father. At the time Oliver was also fascinated with the connection between the psyche of Latino Miami drug dealers f

From: Sent: To: Subject: Jeffrey Epstein [[email protected]] 1/12/2010 12:28:25 AM Peggy Siegall Re: My Wall Street 2 Story terrific. i want to hear more about the trip On Mon, Jan 11, 2

From: Sent: To: Subject: Jeffrey Epstein [[email protected]] 1/12/2010 12:28:25 AM Peg

the culture of Wall Street, Stone has said that part of the film is a defense of capitalism, his father's vision of finance (as seen through the Hal Holbrook character) and an homage to his father. At the time Oliver was also fascinated with the connection between the psyche of Latino Miami drug dealers fr

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From: Richard Kahn • To: "Jeffrey E." <[email protected]> Subject: trump makin

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