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

nfliction of a harmful or offensive contact upon another with the intent to cause such contact or the apprehension that such contact is imminent"); Scelta Delicatessen Support Services. Inc. 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plainti

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

ntent 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) (allegation that defendant attempted to put his hands down pla

008 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, CASE NO.: 08-CV-8

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. '111 10-11; Jane Doe No. 3 Amd. Comp.1 10-11; Jane

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

NO.: 08-CV-80119-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

federal statutory claim "as she would have had if Mr. Epstein had been tried federally and 7 EFTA00221185 C

he intent to cause such contact or the apprehension that such contact is imminent". See Paul Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plaint

008 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, CASE NO.: 08-CV-8

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. '111 10-11; Jane Doe No. 3 Amd. Comp.1 10-11; Jane

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

NO.: 08-CV-80119-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

federal statutory claim "as she would have had if Mr. Epstein had been tried federally and 7 EFTA00222011 C

he intent to cause such contact or the apprehension that such contact is imminent". See Paul Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plaint

008 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, CASE NO.: 08-CV-8

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. '111 10-11; Jane Doe No. 3 Amd. Comp.1 10-11; Jane

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

NO.: 08-CV-80119-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

federal statutory claim "as she would have had if Mr. Epstein had been tried federally and 7 EFTA00222472 C

he intent to cause such contact or the apprehension that such contact is imminent". See Paul Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plaint

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

nfliction of a harmful or offensive contact upon another with the intent to cause such contact or the apprehension that such contact is imminent”); Scelta v. Delicatessen Support Services, Inc., 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plai

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

nfliction of a harmful or offensive contact upon another with the intent to cause such contact or the apprehension that such contact is imminent"); Scelta Delicatessen Support Services. Inc. 57 F.Supp. 2d 1327, 1358-59 (M.D. Fla. 1999) (allegation that defendant attempted to put his hands down plainti