Epstein Secrets

008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. I ---------------- MOTION TO DISMISS Defendant Jeffrey Epstein, pursuant to Rule 12(b) of the Federal Rules of Civil Procedure and Ru

COMPLAINT This action arises out of the alleged assault of the plaintiff. According to the allegations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary compensation" (Compl. ,r 12), where Mr. Epstein allegedly assaulted her "in violation of Chapter 800 of

legations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary comp

I ---------------- MOTION TO DISMISS Defendant Jeffrey Epstein, pursuant to Rule 12(b) of the Federal Ru

ments necessary to sustain a recovery under some viable legal theory." Snow v. DirectTV, Inc., 450 F.3d 1314, 1320 (11th Cir. 2006) (quoting Roe v. Aware Woman Ctr. For Choice, Inc., 253 F.3d 678, 684 (11th Cir. 2001)). Moreover, a court should dismiss a complaint "when, on the basis of a dispositive issue of l

ITED 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. JE

t 05/29/2009 Page 6 of 17 damages. For instance, witnesses may testify that Plaintiff was paid by others for similar sexual acts she claims Mr. Epstein forced upon her or that she willingly participated in certain acts(s) that would negate or lessen her damages”). Each of Defendant’s victims whom

aid by others for similar sexual acts she claims Mr. Epstein forced upon her or that she willingly participate

om [email protected] Counsel for Defendant, Jeffrey Epstein Jack Goldberger, Esq. Atterbury

, “have carved out a limited number of exceptions to the general requirement of disclosure, which permit plaintiffs to proceed anonymously.” Roe v. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 685 (11th Cir. 2001) (internal citation omitted). “The 4 Althoug

1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80119-CIV-MARRA Jane Doe No. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. _______________________________/ OPINION AND ORDER ON MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT THIS CAUSE is before the

ed as less likely to complain to authorities or have credibility if allegations of improper conduct were made. Id. This was an important element of Epstein’s plan. Id. Defendant’s plan and scheme reflected a particular pattern and method. Am. Compl. ¶ 11. Upon arrival at Defendant’s mansion, the underag

ENT THIS CAUSE is before the Court upon Defendant Jeffrey Epstein (“Defendant”)’s Motion to Dismiss and Mo

This is a liberal pleading requirement, one that does not require a plaintiff to plead with particularity every element of a cause of action. Roe v. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 683 (11th Cir. 2001). Instead, the complaint need only “contain either direct or inferential allegations respecting