Epstein Secrets

2'2009 Page 1 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Doe's Amended Complaint,

Plaintiff. . .was called on the telephone by. . .Epstein and other employees. . ., and transported to. . .

Florida Civil Rico action is, at this time, only defendant Epstein. . . ." However, the RICO enterprise must be dis

.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Moti

ourt have required proof of a RICO "enterprise" that is separate and distinct from the person charged with the RICO violation. See United States v. Turkette, 452 U.S. 576. 583. 101 S.Ct. 2524. 69 L.Ed.2d 246 (1981); Gross v. State. 765 So.2d 39. 43 (Fla.2000) (adopting Turkette as a matter of Florida RI

Docket 03/03;2010 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before the Court upon Defendant Jeffrey Epstein ("Defendant")'s Motion to Dismiss, for More Definite Statement &

stein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to Jane Doe). See DE 38-2 at ¶ 4. Finally, Defendant argues, and Plaintiff concedes, that punitive damages are not available under 18 U.S

ICO statement that the "enterprise" consisted of Defendant Epstein, and his paid employees and . See Am. Comp. ¶

. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before

ourt have required proof of a RICO "enterprise" that is separate and distinct from the person charged with the RICO violation. See United States v. Turkette, 452 U.S. 576, 583 (1981); Gross v. State, 765 So.2d 39, 43 (Fla. 2000) (adopting Turkette as a matter of Florida RICO law). "The distinction betwe

The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern

stein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to Jane Doe). See DE 38-2 at ¶ 4. Finally, Defendant argues, and Plaintiff concedes, that punitive damages are not available under 18 U.S

ICO statement that the "enterprise" consisted of Defendant Epstein, and his paid employees Sarah Kellen and Nadia Ma

. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before

ourt have required proof of a RICO "enterprise" that is separate and distinct from the person charged with the RICO violation. See United States v. Turkette, 452 U.S. 576, 583 (1981); Gross v. State, 765 So.2d 39, 43 (Fla. 2000) (adopting Turkette as a matter of Florida RICO law). "The distinction betwe

The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern

stein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to Jane Doe). See DE 38-2 at ¶ 4. Finally, Defendant argues, and Plaintiff concedes, that punitive damages are not available under 18 U.S

ICO statement that the "enterprise" consisted of Defendant Epstein, and his paid employees and Sec Am. Comp. 1 43

. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before

ourt have required proof of a RICO "enterprise" that is separate and distinct from the person charged with the RICO violation. See United States v. Turkette, 452 U.S. 576, 583 (1981); Gross v. State, 765 So.2d 39, 43 (Fla. 2000) (adopting Turkette as a matter of Florida RICO law). "The distinction betwe