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

ed in State Court under Florida RICO alleging they were terminated because they refused to participate in alleged RICO violations. O'Malley v. St.. Thomas Univ.. Inc., 599 So.2d at 1000. The Court adopted the 1 1 th Circuit's reasoning, and stated that any injuries sustained (e.g., by virtue of being terminated) w

CT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO.: 08-C1V- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition to Defendant's Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Do

as requested. Plaintiff filed her Response in Opposition to the Motion to Dismiss. As to Count II, Plaintiff conceded in her opposition motion that Epstein correctly argued that punitive damages EFTA00729110 Doe v. Epstein Page No. 2 are not recoverable under 18 U.S.C. §2255. Therefore Plaintiff "ag

.: 08-C1V- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant, Jeffrey Epstein

Federal authority regarding the interpretation and application of its Acts, citing 18 U.S.C. 1961, et seq. and Fla. Stat. 772.104); O'Malley v. St.. Thomas Univ.. Inc., 599 So.2d 999, 1000 (Ha. 3d DCA 1992)("Since Florida Rico is patterned after Federal RICO. . . .[f]ederal decisions should be accorded great weigh

CT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO.: 08-C1V- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition to Defendant's Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Do

as requested. Plaintiff filed her Response in Opposition to the Motion to Dismiss. As to Count II, Plaintiff conceded in her opposition motion that Epstein correctly argued that punitive damages EFTA00729105 Doe v. Epstein Page No. 2 are not recoverable under 18 U.S.C. §2255. Therefore Plaintiff "ag

.: 08-C1V- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant, Jeffrey Epstein

Federal authority regarding the interpretation and application of its Acts, citing 18 U.S.C. 1961, et seq. and Fla. Stat. 772.104); O'Malley v. St.. Thomas Univ.. Inc., 599 So.2d 999, 1000 (Ha. 3d DCA 1992)("Since Florida Rico is patterned after Federal RICO. . . .[f]ederal decisions should be accorded great weigh