Epstein Secrets

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

ion to dismiss is not a “responsive pleading” and does not affect a plaintiff’s right to amend the pleading once as a matter of course. Williams v. Board of Regents, 477 F.3d 1282, 1291 (11th Cir. 2007). Case 9:08-cv-80119-KAM Document 41 Entered on FLSD Docket 09/22/2008 Page 1 of 4 Herma

From: "Pritzker, Tom" To: "'Jeffrey Epstein ([email protected])m <[email protected]> Subject: Date: Fri, 14 Nov 2014 17:58:18 +0000 Gave a speech to Board of CSIS about ISIS. Audienc

From: "Pritzker, Tom" To: "'Jeffrey Epstein ([email protected])m <[email protected]>

From: "Pritzker, Tom" To: "'Jeffrey Epstein ([email protected])m <jeevacation@gma

tzker, Tom" To: "'Jeffrey Epstein ([email protected])m <[email protected]> Subject: Date: Fri, 14 Nov 2014 17:58:18 +0000 Gave a speech to Board of CSIS about ISIS. Audience is senior military, national security advisors, DoD and State guys (ok, a few agency personnel as well). After I finished

From: Pritzker, Tom < Sent: Friday, November 14, 2014 5:58 PM To: 'Jeffrey Epstein ([email protected])' Gave a speech to Board of CSIS about ISIS. Audience is senior military, n=tional security advisors, DoD and State guys (ok

Friday, November 14, 2014 5:58 PM To: 'Jeffrey Epstein ([email protected])' Gave a speech to Board

< Sent: Friday, November 14, 2014 5:58 PM To: 'Jeffrey Epstein ([email protected])' Gave a speech t

From: Pritzker, Tom < Sent: Friday, November 14, 2014 5:58 PM To: 'Jeffrey Epstein ([email protected])' Gave a speech to Board of CSIS about ISIS. Audience is senior military, n=tional security advisors, DoD and State guys (ok, a few agency personnel a= well). After I finished

09/07/2014 20:45 IEG GmbH (FAX)00493030301636 P.001/054 To Jeffry from Nicole EFTA00283711 09/0712014 20:45 IEG GmbH TAX)00493030301636 P.0021054 Dear Nicole Junkermann I have known Nicole since her time at

context otherwise requires;:tWollowing words and expressions shall have the following meanini$: "Administrator" means any pers<si appointed to\the, Board of # • ... Administrators in accordance wi eStatuta\ \ ../ •, ' ,,, ' -1/2\ o "Assets" means the assets described in Artklkt of the Statute; "Ben

oard, Chief Financial Officer and Chairman-Elect, Board of Executive Directors Executive Managing Director

tlev Engel Klaus Engel Richard P. Eno David R. Epstein Mary Callahan Erdoes Charles W. Ergen Paula Esco