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11, Plaintiff "demands judgment against Defendant Jeffrey Epstein for all damages available under 28 U.S.C
0/06/2008 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. --------------'' DEFENDANT'S. EPSTEIN. MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT DIRECTED TO PLAINTIFF'S AMENDED COMPL
------------'' DEFENDANT'S. EPSTEIN. MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT DIRECTED TO PLAINTIFF'S AMENDED COMPLAINT Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves to dismiss and for more definite statement of Plaintiff JANE DOE NO. 2's Amended Complaint. Rules 12
ntiff "demands judgment against Defendant Jeffrey Epstein for all damages available under 28 U.S.C. §2255(
ginning of an act which, if consummated, constitutes battery." 3A Fla.Jur.2d Assault §1. An assault and battery are intentional acts. See generally, Spivey v. Battaglia, 258 So.2d 815 (Fla. 1972}; and Travelers lndem. Co. v. PCR. Inc., 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawfu
lsd Page 1 of 15 LRJ U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80232-KAM Doe No. 3 v. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 2:flasaAhd Member case: (View Member Case) Case: 9:09-cv-80802-KAM Cause: 28:1332 Diversity-Perso
file this document. (Is) (Entered: 05/20/2009) 05/20/2009 2.$ NOTICE by C.M.A. of Filing Withdrawal of Previously Raised Objections to Defendant, Jeffrey Epstein's Motion to Compel And/Or Identify C.M.A. in the Style of This Case and Motion to Identify C.M.A. in Third-Party Subpoenas for Purposes of Discovery,
3/11/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 3. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 3. (Attachments: # 1 Exhibi
plicable statute of limitations. WHEREFORE Defendant requests that this Court deny the re ' f sought by Plaintiff. Robert D. C itton, Jr. Attorney f. Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also
ginning of an act which, if consummated, constitutes battery." 3A Fla.Jur.2d Assault §1. An assault and battery are intentional acts. See generally, Spivey. Battaglia 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co... PCR, Inc., 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawful of
O PLAINTIFF JANE DOE N0.6'S COMPLAINT Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves t
/515-3148 Fax ( Co-Counsel for Defendant Jeffrey Epstein)
!h day of October, 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 1
and battery are intentional acts. See generally, Spivey v. Battaglia, 258 So.2d 815 (Fla. 1972); and Tra
other State Program • California Man Charged With Conspiracy for Alleged Role in Anti-ICE Protest • Florida Man Threatened to Kill Politicians Over Epstein Client List, FBI Says EFTA00163724 • Former Deputy Sentenced To 16 Months In Prison For Beating Inmate In Georgia • FBI Agent Found Guilty of Rap
Maxwell in Florida on Thursday The New York Times (07/24, Thrush, Feuer) reported that Justice Department officials interviewed Ghislaine Maxwell, Jeffrey Epstein's associate, in a Florida prison as part of an effort to address criticism over the handling of Epstein's case. According to the article, Maxwell answ
hington Times (07/24, Ferrechio) reported that AG Bondi informed President Trump in May that his name was among hundreds of people identified in the Jeffrey Epstein files that the president's MAGA base and Democrats want released to the public. The news, first reported by The Wall Street Journal, fueled
ging in any unsolicited external devices. Continued Reporting: FBI Warns Arkansans of Rising Scam Threats Amid Al Advancements KATV (ABC-7) (07/24, Spivey) reported that the FBI is warning Arkansans of rising scam threats, particularly those using artificial intelligence to exploit victims. According t
Entities connected to both Jeffrey Epstein and Spivey

United States
LOCATIONJack Goldberger
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONMichael J. Pike
PERSON
Adam D. Horowitz
PERSON
United States District Court
ORGANIZATION
Jeffrey Marc Herman
PERSONStuart S. Mermelstein
PERSONFlorida Bar
ORGANIZATIONWright
PERSONSullivan
PERSON
Lewis Tein
PERSONCoconut Grove
LOCATIONGibson
PERSON
Rhodes
PERSONTwombly
PERSONTompkins
PERSONScheuer
PERSON