Epstein Secrets

nt in this case. In this Court's Opinion and Order on Motion to Dismiss and Motion for More Definite Statement in the case styled Jane Doe No. 6 v. Jeffrey Epstein Case No. 08-80994-CIV-Marra ("Jane Doe No. 6) this Court rejected any contention by the Defendant that the Supreme Court's decision in Bell Atlantic Corp

civious, and sexual acts, including, EFTA00201211 Case 9:08-cv-80811-KAM Document 58 Entered on FLSD Docket 04/13/2009 Page 2 of 18 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-C1V-MARRA/JOHNSON Plaintiffs Memorandum in Response to Defendant Jeffrey Epstein's Motion to Dismiss First Amended Co

12, 2009, this Court entered the Opinion and Order on Motion to Dismiss and Motion for More Definite Statement in the case styled Jane Doe No. 6 v. Jeji-ey Epstein, Case No. 08-80994-UV-Marra.' In that Order, the Court granted the Defendant's Motion for More Definite Statement with respect to allegations conce

The interpretation of Section 2255 urged by the Defendant Epstein implicates the same concerns EFTA00201218 Case

0811-CIV-MARRA/JOHNSON C.M.A., Plaintiff, vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. PLAINTIFF

atement in the case styled Jane Doe No. 6 v. Jeji-ey Epstein, Case No. 08-80994-UV-Marra.' In that Order, the

t specifically provide for punitive damages, the remedy of punitive damages can be supplied through federal common law. For example, in Tachiona v. Mugabe, 216 F.Supp.2d 262 (S.D.N.Y. 2002) the court upheld an award of compensatory damages and punitive damages under the Torture Victim Protection Act (T

ket 06/05/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff, VS. Y EPSTEIN and Defendants. PLAINTIFF, M.'S, CONDITIONAL NOTICE OF INTENT TO EXCLUSIVELY RELY ON STATUTORY DAMAGES PROVIDED BY 18 U.S.C. 42255 Plaintiff, ,

Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, files his reply to Plaintiffs Memorandum in Response to Defendant, JEFFREY EPSTEIN's, Motion to Dismiss First Amended Complaint For Failure to State A Cause of Action; And Motion for More Definite Statement; Motion to Strike, And Sup

tion either under statutory or common law against Defendant EPSTEIN. Count I fails to plead any requisite elements o

tion to recover money damages against Defendant, JEFFREY EPSTEIN, for acts of sexual abuse and prostitutio

eed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enum

unitive damages under §2265 is required to be dismissed or stricken. (Plaintiffs Response, Part III, p. 11-18). Plaintiff's reliance on Tachiona v. Mugabe, 216 F.Supp.2d 262 (S.D.N.Y. 2002), is misplaced as the federal statute at issue, the Torture Victim Protection Act (TVPA), is clearly distinguisha

e rollecled in the myoice amount. Tracking ID 828034210503 Sen1ce Tkge Fg0Ex SU/WM OvOMICIM Package Typo FedEx Box Sender Recioieni J EPSTEIN JEFFREY E EPSTEIN Zone PleceS Weighl Delivered 3 1 5.0 lbs. 2.3 kgs Met 18.200214:43 457 MADISON AVE NEW YORK NY 100224643 US Transco:Main Charge 20.00 Somme D

MICIM Package Typo FedEx Box Sender Recioieni J EPSTEIN JEFFREY E EPSTEIN Zone PleceS Weighl Deliver

.2081.6 Page: 1 ol 12 FedEx Tax ID 71.0127007 JEFFREY E EPSTEIN 457 MADISON AVE NEW YORK NY 10022.6843

Package Type FedEx Box 457 MADISON AVE BMSTA JEFFREY E. EPSTEIN 358 El BRIU.0 WAY PALM BEACH FL 33480 U

Number: 4-157-35704 Invooce Date: Apr 01.2002 Accctem Number: 1144.2081.6 Page: 3 of 12 FedEx Express Payment Type Summary Shipper OdgInal Mugabe of *Weals IT Transportation Charges 398.06 Base Discount -05.24 Special Handling Chuges 25 28 Chen, -14.86 TOTAL USD S 363.23 Number of

Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, files his reply to Plaintiff's Memorandum in Response to Defendant, JEFFREY EPSTEIN's, Motion to Dismiss First Amended Complaint For Failure to State A Cause of Action; And Motion for More Definite Statement; Motion to Strike, And Sup

UTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS FIRST AMEDNED COMPLAINT FOR FAIURE TO STATE A CAUS

JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE TO

CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDAN

nitive damages under §2255 Is required to be dismissed or stricken. (Plaintiff's Response, Part III, p. 11-18). Plaintiff's reliance on Tachiona v. Mugabe, 216 F.Supp.2d 262 (S.D.N.Y. 2002), is misplaced as the federal statute at issue, the Torture Victim Protection Act (TVPA), is clearly distinguisha

From: Joi Ito Sent: Friday, June 12, 2015 2:48 PM To: Jeffrey Epstein Subject: Re: fertile land for exploration You mean Mugabe? Are you buddies? On Jun 12, 2015, at 10:31 AM, =effrey E. <[email protected] <mail

pproach him and provide a new currency / =cnomy On Fri, Jun 12, 2015 at 7:58 AM, Joi Ito mailto wrote: Ha! Amazing. On Jun 12, 2015, at 6:29 AM, jeffrey E. <[email protected]> wrote: http://www.theguardian.com/world/2015/jun/12/zimbabwe-offers-ne=-exchange-rate-1-for- 35000000000000000-old-dollars pl

ent: Friday, June 12, 2015 2:48 PM To: Jeffrey Epstein Subject: Re: fertile land for exploration You

i Ito Sent: Friday, June 12, 2015 2:48 PM To: Jeffrey Epstein Subject: Re: fertile land for explorati

From: Joi Ito Sent: Friday, June 12, 2015 2:48 PM To: Jeffrey Epstein Subject: Re: fertile land for exploration You mean Mugabe? Are you buddies? On Jun 12, 2015, at 10:31 AM, =effrey E. <[email protected] <mailto:[email protected]> wrote: we sshould approach him and

en's Soccer Team-Equal Pay; New York-In Vitro Babies Switched; Robocall Scam; Wimbledon-15-Year-Old's Run Comes To An End. Network TV At A Glance: Jeffrey Epstein - 10 minutes, 40 seconds California-Earthquake - 6 minutes, 10 seconds US Women's Soccer Team-Equal Pay - 5 minutes, 10 seconds D.C.-Flash Flood Eme

fter they were accused of letting [him] off the hook." US Attorney Geoffrey Berman of New York "said that the non-prosecution agreement that spared Epstein from a heavy prison sentence a decade ago is binding only on federal prosecutors in Florida, where the deal was made, not on authorities in New Yor

lot of fun to be with. It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it - Jeffrey enjoys his social life." The Washington Post (7/8, Fahrenthold, Reinhard, Kindy, 14.2M) says that in 2002, "being friendly with (Epstein] was some

'Trial Lawyer' Alexandria Ocasio-Cortez Turns Hearings Into Appointment Viewing Zimbabweans' Fear Of Currency Comeback Casts Doubt On Changes Since Mugabe Federal Minimum Wage Hike Would Cost Millions Of Jobs: CBO Report Story Lineup From Last Night's Network News: ABC: Jeffrey Epstein; D.C.-Flash Fl

very much for your quick reply and your answer. I highly highly appreciate it. I get back to you on Sunday! • On Wed, Nov 5, 2014 at 11:25 AM, jeffrey E. <[email protected]> wrote: not a bother . you should be able to sublet one. I do not have any . email me on sunday i might be back in ny wro

From• To: "Jeffrey E." <[email protected]> Subject: Re: Thank you, Date: Wed, 26 Nov 2014 23:02:32 +0000 Dear Jeffrey, I hope that you have had a good day! First of all, I am very sorry that I could not get back to you sooner. I do realize that this email is quite

I can help you with. On Sat, Nov 15 2014 at 1:33 PM, wrote: EFTA00641099 Dear Jeffrey, THANK YOU. I will get back to you later today (if OK?). Jeffrey: from the bottom of my heart- THANK YOU. On Saturday, November 15, 2014, jeffrey E. <[email protected]> wrote: you choose On Sat Nov 15 2014 a

are living there (mostly diplomats or people working at NGOs) to whom I spoke. Obviously, I was not out after the sundown; I did not take photos of Mugabe's policemen, and, of course, I was cautious. Nevertheless, I was surprised at how safe I felt: indeed, in contrast to everything I had read. The pe

should approach him and provide a new currency / ecnomy On Fri, Jun 12, 2015 at 7:58 AM, Joi Ito Ha! Amazing. wrote: On Jun 12, 2015, at 6:29 AM, Jeffrey E. <jeevacation(ii;gmail.com> wrote: http://www.theguardian.com/world/2015/jun/12/zimbabwe-offers-new-exchange-rate-l-for- 35000000000000000-old-dollars

a! Amazing. wrote: On Jun 12, 2015, at 6:29 AM, Jeffrey E. <jeevacation(ii;gmail.com> wrote: http://www.

sily get his attention, zimbabwe would be a great petrie dish, its also supposed to be beautiful On Fri, Jun 12, 2015 at 10:48 AM, Joi Ito You mean Mugabe? Are you buddies? wrote: On Jun 12, 2015, at 10:31 AM, jeffrey E. lea@grian> wrote: we sshould approach him and provide a new currency / ecnomy