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

al. 1,15 Plaintiff's reliance on In re Hawaiian Airlines, Inc. (Konop v. Hawaiin Airlines, Inc.I 355 B.R. 225 (D. Hi. 2006), is misplaced. Unlike the Stored Communications Act, 18 U.S.C. §2707(c), endnote', at issue in the Hawaiian Airlines case, the presumptive minimum is tied to the minor or person proving that she or h

Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, files his reply to Plaintiff's 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

UTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS FIRST AMEDNED COMPLAINT FOR FAIURE TO STATE A CAUS

JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE TO

CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDAN

Page 15 Plaintiff's reliance on In re Hawaiian Airlines, Inc. (Konop v. Hawaiin Airlines, Inc.), 355 B.R. 225 (D. Hi. 2006), is misplaced. Unlike the Stored Communications Act, 18 U.S.C. §2707(c), endnote', at issue in the Hawaiian Airlines case, the presumptive minimum is tied to the minor or person proving that she or h

ttorneys for Respondent Sharon Churcher BY: ERIC J. FEDER LAW OFFICES OF Attorneys BY: GREGORY L. RACHEL S. GREGORY L. POE PLLC for Respondent Jeffrey Epstein POE LI WAI SUEN SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA_R1_00024108 EFTA01737512 2 G6ndgium 4 5 6 7 8 9 10 11 12 13

on. We need to see what they're specifically talking about here. THE COURT: Thank you very much. I will reserve decision. The motion to quash the Epstein -- MR. POE: May I approach the podium, your Honor? THE COURT: Yes. Of course. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA_R1_00024133

N AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY PAGLIUCA LAURA A. MENNINGER DAVIS WRIGHT TREMAI

s whether in fact an undue burden would exist if Mr. Epstein were subjected at this point to a deposition. Th

a hopelessly broad subpoena. It is abusive civil discovery and on the face of it appears to violate the Electronic Communications Privacy Act and the Stored Communications Act, federal laws. The email seeks -- excuse me. The subpoena seeks every email that has ever been sent to that account or sent from that account. Tha