Epstein Secrets

ket 06/05/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff, VS. Y EPSTEIN and Defendants. PLAINTIFF, M.'S, CONDITIONAL NOTICE OF INTENT TO EXCLUSIVELY RELY ON STATUTORY DAMAGES PROVIDED BY 18 U.S.C. 42255 Plaintiff, ,

Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, files his reply to Plaintiffs Memorandum in Response to Defendant, JEFFREY EPSTEIN's, Motion to Dismiss First Amended Complaint For Failure to State A Cause of Action; And Motion for More Definite Statement; Motion to Strike, And Sup

tion either under statutory or common law against Defendant EPSTEIN. Count I fails to plead any requisite elements o

tion to recover money damages against Defendant, JEFFREY EPSTEIN, for acts of sexual abuse and prostitutio

eed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enum

mpanion case are closed). Here, Epstein is not required to "contemplate an in haec verba iron-clad comparison of separate issues by direct proof." St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct at 516. Instead, a reading of the complaint, the NPA (in camera), the pleadings in support of and ag

With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his unde

eal, substantial and not remote possibility that Epstein may face criminal prosecution by the United State

intiff, Defendant. ______________ / Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposi

it is clear that Epstein has met the elements of St. Paul Fire necessary for this Court to enter a stay: 1. E

2009 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA C.M. A., CASE NO.: 08-CIV-80811-MARRAIJOHNSON Plaintiff, r lEEEREIY EPSTEIN and■ Defendants, v. Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition To Defendant's Motion To Stay And/Or Continue Action

COURT SOUTHERN DISTRICT OF FLORIDA C.M. A., CASE NO.: 08-CIV-80811-MARRAIJOHNSON Plaintiff, r lEEEREIY EPSTEIN and■ Defendants, v. Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition To Defendant's Motion To Stay And/Or Continue Action For Time Certain With Incorporated Memorandum Of La

EEEREIY EPSTEIN and■ Defendants, v. Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposi

dicial Circuit Court, Palm Beach County). When an ongoing criminal investigation exists, courts have granted motions to stay civil proceedings. In St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct 513 (1991), the court held that staying a civil action for 6-9 months was reasonable in light of a pe

CT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV- 80893 — MARRA/JOHNSON Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition To Defendant's Motion To Stay And/Or Continue Action For Time Certain With Incorporated Memorandum Of La

To Defendant's Motion To Stay And/Or Continue Action For Time Certain With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby files his Reply to Plaintiffs Response In Opposition to Defendant's Motion to Stay Complaint (SI

N DISTRICT OF FLORIDA JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV- 80893 —

dicial Circuit Court, Palm Beach County). When an ongoing criminal investigation exists, courts have granted motions to stay civil proceedings. In St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct 513 (1991), the court held that staying a civil action for 6-9 months was reasonable in light of a pe