Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CV-80802-MARRA-JOHNSON JANE DOE NO. 8 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO MOTION TO DISMISS PLAINTIFFS COMPLAINT, dated 08/12/09 De

ICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CV-80802-MARRA-JOHNSON JANE DOE NO. 8 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO MOTION TO DISMISS PLAINTIFFS COMPLAINT, dated 08/12/09 Defendant EPSTEIN, by and through

8 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM OF LAW IN OPPO

02-MARRA-JOHNSON JANE DOE NO. 8 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY T

1996)("[A] cause of action cannot be said to have accrued, within the meaning of the statute of limitations, until an action may be brought."); and Florida Power & Light Co. v. Allis Chalmers Corp., 85 F.3d 1514, §95.031, Fla.Stat., provides in relevant part : ... the time within which an action shall be begun under any

9-CIV-MARRA/JOHNSON JANE DOE II, Plaintiff, v. JEFFREY EPSTEIN and Defendants. ORDER AND OPINION THIS CAUSE is before the Court upon Defendant Jeffrey Epstein's Motion to Dismiss Plaintiff's Complaint (DE 13), filed May 6, 2009. The motion is now fully briefed and ripe for review. The Court has carefully re

Complaint, are as follows: During the events giving rise to this claim, Plaintiff was a minor but has now reached majority. Compl. ¶ 4. Defendant Epstein has a history of enticing young women, who are minors, and soliciting them to engage in prostitution for his own sexual gratification. Compl. 8. Eps

minor but has now reached majority. Compl. ¶ 4. Defendant Epstein has a history of enticing young women, who are m

-CIV-MARRA/JOHNSON JANE DOE II, Plaintiff, v. JEFFREY EPSTEIN and Defendants. ORDER AND OPINION THIS

split causes of action to bring state claims in one suit and then file a second suit with federal causes of action); Aquatherm Industries, Inc. v. Florida Power & Light Co. 84 F.3d 1388 (11' Cir. 1996) (holding that a Federal Lanham Act claim was barred in federal court after the plaintiff elected to bring only its sta

ion"). One does not need to engage in complex analysis to understand what has happened here: the government has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimately exceeding—the bounds of the law. Yet, it is in precisely this setting—involving a defendant who, despit

en short of its obligations here. The indictment must be dismissed. The government's sudden zeal to prosecute Ms. Maxwell for alleged conduct with Epstein in the 1990s—conduct for which the government never even charged Epstein—follows a history that is both highly unusual and deeply troubling. The gov

ohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

05) 15 Own St v. Street Beat Sportswear; Inc., 226 F. Supp. 2d 355 (E.D.N.Y. 2002) 15 Crutsinger v. Hess, 408 F. Supp. 548 (D. Kan. 1976) 24 Florida Power & Light Co. v. Mid-Valley, Inc., 763 F.2d 1316 (11th Cir. 1985) 15 Giglio v. United States, 405 U.S. 150 (1972) 13 In re Wild, 955 F.3d 1196 (I I th Cir

ion"). One does not need to engage in complex analysis to understand what has happened here: the government has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimately exceeding—the bounds of the law. Yet, it is in precisely this setting—involving I defendant who, despit

en short of its obligations here. The indictment must be dismissed. The government's sudden zeal to prosecute Ms. Maxwell for alleged conduct with Epstein in the 1990s—conduct for which the government never even charged Epstein—follows I history that is both highly unusual and deeply troubling. The gov

overnment has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimat

05) 15 Own St v. Street Beat Sportswear; Inc., 226 F. Supp. 2d 355 (E.D.N.Y. 2002) 15 Crutsinger v. Hess, 408 F. Supp. 548 (D. Kan. 1976) 24 Florida Power & Light Co. v. Mid-Valley, Inc., 763 F.2d 1316 (11th Cir. 1985) 15 Giglio v. United States, 405 U.S. 150 (1972) 13 In re Wild, 955 F.3d 1196 (I I th Cir

enzinger Duane Morris Earthjustice Edelson PC Epstein Becker Green Evans & Dixon Faegre Baker Fenwic

Comcast Corp. Companhia Siderurgica Nacional Edgeworth Economics LLC Electronic Frontier Foundation Essendant Inc. Exxon Mobil Corp. Facebook Florida Power & Light Co. Food Marketing Institute GVC Holdings PLC Geico General Re Corp. Google Inc. HSBC Holdings PLC Hologic Inc. Intel Corp. International Brothe