Epstein Secrets

IN THE CIRCUIT COURT FOR THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CP003626XXXXMB • Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF tits RESPONSE TO DEFENDANT EPSTEIN'S MOTION FOR PARTI UMMARY JUDGMENT ON COUNT I OF PLAINTIFF'S SECOND AMENDED COMPLAINT

FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CP003626XXXXMB • Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF tits RESPONSE TO DEFENDANT EPSTEIN'S MOTION FOR PARTI UMMARY JUDGMENT ON COUNT I OF PLAINTIFF'S SECOND AMENDED COMPLAINT Plaintiff ■ hereby responds to defendant Epstein's Motion

N COUNT I OF PLAINTIFF'S SECOND AMENDED COMPLAINT Plaintiff ■ hereby responds to defendant Epstein's Motion for Partial Summary judgment on Count I. Epstein claims that he is entitled to summary judgment on Count 1 because there is no private right of action under various criminal statutes. Epstein simp

EPSTEIN, Defendant. PLAINTIFF tits RESPONSE TO DEFENDANT EPSTEIN'S MOTION FOR PARTI UMMARY JUDGMENT ON COUNT I O

CASE NO. 502008CP003626XXXXMB • Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF tits RESPONSE TO

penal statutes that were designed to protect a class of persons, of which Plaintiff is a member, against a particular type of harm. Particularly, the Florida Statutes which Epstein violated include, but may not be limited to: A. Chapter 800.04(4-7) — Lewd or lascivious offenses; Defendant Epstein engaged in sex

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502008CA028051XXXXMB AB L.M. Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF L.M.'s RESPONSE TO DEFENDANT EPSTEIN'S MOTION FOR PARTIAL SUMMARY JUDGMENT ON COUNT I OF PLAINTIFF'S SECOND AMENDED COMPLAI

BEACH COUNTY, FLORIDA CASE NO: 502008CA028051XXXXMB AB L.M. Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF L.M.'s RESPONSE TO DEFENDANT EPSTEIN'S MOTION FOR PARTIAL SUMMARY JUDGMENT ON COUNT I OF PLAINTIFF'S SECOND AMENDED COMPLAINT Plaintiff L.M. hereby responds to defendant Epstein's Mot

COUNT I OF PLAINTIFF'S SECOND AMENDED COMPLAINT Plaintiff L.M. hereby responds to defendant Epstein's Motion for Partial Summary judgment on Count I. Epstein claims that he is entitled to summary judgment on Count 1 because there is no private right of action under various criminal statutes. Epstein simp

PSTEIN, Defendant. PLAINTIFF L.M.'s RESPONSE TO DEFENDANT EPSTEIN'S MOTION FOR PARTIAL SUMMARY JUDGMENT ON COUNT I

O: 502008CA028051XXXXMB AB L.M. Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF L.M.'s RESPONSE T

penal statutes that were designed to protect a class of persons, of which Plaintiff is a member, against a particular type of harm. Particularly, the Florida Statutes which Epstein violated include, but may not be limited to: A. Chapter 800.04(4-7) — Lewd or lascivious offenses: Defendant Epstein engaged in sex

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

riminal offenses in any "Chapter 800 of the Federal Codes" which give rise to a civil cause of action. The same is true for Plaintiffs reference to the Florida Statutes. Not one of the statutes referenced creates a private cause of action or affords a civil remedy on behalf of the alleged victim of the criminal off

03/12/2009 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRA/JOHNSON C.M. A., Plaintiff, v. EPSTEIN and Defendants, DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS FIRST AMENDED COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION, AND MOTION FOR MORE

ATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRA/JOHNSON C.M. A., Plaintiff, v. EPSTEIN and Defendants, 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 SU

adopted." Id. Plaintiffs position would subject Defendant EPSTEIN to a punishment that is not clearly prescribed —

aintiff, v. EPSTEIN and Defendants, DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS FIRST AMENDED COMPLA

riminal offenses in any "Chapter 800 of the Federal Codes" which give rise to a civil cause of action. The same is true for Plaintiffs reference to the Florida Statutes. Not one of the statutes referenced creates a private cause of action or affords a civil remedy on behalf of the alleged victim of the criminal off

ants, developed a plan, scheme, and criminal enterprise that included an elaborate system wherein the then minor Plaintiff was brought to Defendant Jeffrey Epstein's residence by the Defendant's employees, recruiters, and assistants. When the assistants and employees left the then minor Plaintiff and other minor

ned to protect a class of persons, of which Plaintiff is a member, against a particular type of harm. 20. Particularly, the Florida Statutes which Epstein violated include, but may not be limited to: A. Chapter 800.04(4-7) — Lewd or lascivious offenses; Defendant Epstein engaged in sexual activity w

1 through 15 above. 41. On numerous occasions, Defendant Epstein did in fact intentionally touch plaintiff, E.W.,

2008 CA 028058 XXXXMB AB E.W., Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S THIRD AMENDED C

l statutes that were designed to protect a class of persons, of which Plaintiff is a member, against a particular type of harm. 20. Particularly, the Florida Statutes which Epstein violated include, but may not be limited to: A. Chapter 800.04(4-7) — Lewd or lascivious offenses; Defendant Epstein engaged in sex

ants, developed a plan, scheme, and criminal enterprise that included an elaborate system wherein the then minor Plaintiff was brought to Defendant Jeffrey Epstein's residence by the Defendant's employees, recruiters, and assistants. When the assistants and employees left the then minor Plaintiff and other minor

ned to protect a class of persons, of which Plaintiff is a member, against a particular type of harm. 20. Particularly, the Florida Statutes which Epstein violated include, but may not be limited to: A. Chapter 800.04(4-7) — Lewd or lascivious offenses; Defendant Epstein engaged in sexual activity w

1 through 15 above. 41. On numerous occasions, Defendant Epstein did in fact intentionally touch Plaintiff, L.M.,

2008 CA 028051 XXXXMB AB L.M., Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S THIRD AMENDED C

l statutes that were designed to protect a class of persons, of which Plaintiff is a member, against a particular type of harm. 20. Particularly, the Florida Statutes which Epstein violated include, but may not be limited to: A. Chapter 800.04(4-7) — Lewd or lascivious offenses; Defendant Epstein engaged in sex