Epstein Secrets

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

use 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 plaintiff’s dress, and that there was an ac

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

t 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 plaintiff's dress, and that there was an ac

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

t 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 plaintiff's dress, and that there was an ac

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

t 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 plaintiff's dress, and that there was an ac

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

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 plaintiff’s dress, and that there was an a