Epstein Secrets

010 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. --------------~/ Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656,

09-80802, 09-81092 ______________ ___:! EPSTEIN'S REPLY TO JANE DOE #3'S RESPONSE TO EPSTEIN'S MOTION FOR SANCTIONS Defendant, JEFFREY EPSTEIN ("Epstein"), submits this Reply to Plaintiffs, Jane Doe #3, Response to Epstein's Motion for Sanctions and states: I. On January 13, 2010, Epstein filed a M

chael J. Pike Florida Bar #617296 Attorneys for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a

1 [email protected] Co-Counsel for Defendant Jeffrey Epstein Respectfully submitted, By: Isl Michae

nowledge by any member of a law firm is imputed to all attorneys in the firm. See,'.,& In re Mortgage & Realty Trust, 195 B.R. 740, 754-55 (Bankr., C.D. Cal. 1996) (noting that the imputed knowledge theory holds that knowledge by any member of a law firm is knowledge by all of the attorneys in the firm, p

. Fla. 2007) (noting role of Attorneys General in class settlement approval process); True v. American Honda Motor Co., 749 F. Supp. 2d 1052, 1082 (C.D. Cal. 2010) (discussing views of state Attorneys General with respect to class action settlement grounded in products liability claims). Since the passage

, including any sovereign or government, relating to or arising from any Member of the Class's harm, injury, abuse, exploitation, or trafficking by Jeffrey Epstein or by any person who is in any way connected to or otherwise associated with Jeffrey Epstein, as well as any right to recovery on account thereof.

, abuse, exploitation, or trafficking by Jeffrey Epstein or by any person who is in any way connected to

, injury, abuse, exploitation, or trafficking by Jeffrey Epstein or by any person who is in any way conne

23 is whether the settlement, taken as a whole, is fair, adequate, and reasonable"). OBJECTOR'S STATUS AS A CLASS MEMBER Objector is a survivor of Jeffrey Epstein ("Epstein") and qualifies as a Class Member of the preliminarily certified class with standing to object to the proposed Stipulation as provided in

settlement, taken as a whole, is fair, adequate, and reasonable"). OBJECTOR'S STATUS AS A CLASS MEMBER Objector is a survivor of Jeffrey Epstein ("Epstein") and qualifies as a Class Member of the preliminarily certified class with standing to object to the proposed Stipulation as provided in the Stipu

ATUS AS A CLASS MEMBER Objector is a survivor of Jeffrey Epstein ("Epstein") and qualifies as a Class Memb

t guidelines tested by adversarial process and pit-trial discovery." Id. citing Chi v. Univ. of S. Cal., No. 2:18-cv-04258, 2019 WL 3064457, at *4 (C.D. Cal. Apr. 18, 2019) (holding that, in a sexual abuse class action, "the contemplated authority of the" non-judicial officer "to make all claims determina