Epstein Secrets

A NO. 08-80811-CIV-MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN and Defendants. ORDER AND OPINION THIS CAUSE is before the Court upon 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 (DE 47).

, 2009 by an Amended Complaint (DE 40). Plaintiff brings suit alleging Counts I-XXX - Cause of Action Pursuant to 18 U.S.C. § 2255 against Defendant Epstein; Count XXXI - Sexual Battery against Defendant Epstein; and Count XXXII - Conspiracy to Commit Tortious Assault Against Defendant 1 EFTA00731326

se of Action Pursuant to 18 U.S.C. § 2255 against Defendant Epstein; Count XXXI - Sexual Battery against Defendant E

NO. 08-80811-CIV-MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN and Defendants. ORDER AND OPINION THIS

eed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enu

cluding, but not limited to, those crimes designated in 18 U.S.C. §§ 2241, 2242, 2243, 2421, and 2423, criminal offenses outlined in Chapter 800 of the Federal Codes, as well as those designated in Florida Statutes §§ 796.03, 796.07, 796.045, 796.04, 39.01, and 827.04. Compl. ¶ 15. Defendant, at all material time

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

08-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 15 of 21 IS. v. Epstein, et al. Page 15 offenses outlined in Chapter 800 of the Federal Codes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01; and §827.04." In ¶203 Plaintiff also alleges that Def

ceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enu

iff to engage in sexual acts with another female in JEFFREY EPSTEIN'S presence. 11. The Plaintiff, C.M.A., was the first brought to the Defendant, JEFFREY EPSTEIN'S, mansion in late May or early June of 2002, when she was fifteen-years old and in middle school. 12. The Defendant, JEFFREY EPSTEIN, a wealthy fin

HIBIT 3 a pn oonitblib_ Duce Rpm EFTA00087853 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 2 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 4. At all times material to this cause of action, the Defendant, JEFFREY

First Amended Complaint against the Defendants, JEFFREY EPSTEIN an and states as follows: 1. This is

ncluding, but not limited to, those crimes designated in 18 USC §2241, §2242, §2243, §2421, and §2423, criminal offenses outlined In Chapter 800 of the Federal Codes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01; and §827.04. 16. The above-described acts took place

Plaintiff to engage in sexual acts with another female in JEFFREY EPSTEIN'S presence. 11. The Plaintiff,= was the first brought to the Defendant, JEFFREY EPSTEIN'S, mansion in late May or early June of when she was fifteen-years old and in middle school. 12. The Defendant, JEFFREY EPSTEIN, a wealthy financie

APHS 7, 8, 9, 10, 15, and 17 EFTA_00003349 EFTA00157731 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 2 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 4. At all times material to this cause of action, the Defendant, JEFFREY

8-CV-80811-CIV-MARRA/JOHNSON Plaintiff(s), vs. JEFFREY EPSTEIN and Defendant(s). FIRST AMENDED COMPLAI

ceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enu

ncluding, but not limited to, those crimes designated in 18 USC §2241, §2242, §2243, §2421, and §2423, criminal offenses outlined in Chapter 800 of the Federal Codes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01; and §827.04. 16. The above-described acts took place

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

-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 15 of 21 C.M.A. v. Epstein, et al. Page 15 offenses outlined in Chapter 800 of the Federal Codes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01; and §827.04." In ¶203 Plaintiff also alleges that Def

ident of Palm Beach County, Florida. EFTA00201298 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 2 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 4. At all times material to this cause of action, the Defendant, JEFFREY

Y EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A toi EPSTEIN, and to provide him with a massage. Defendant, JEFFREY of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN ihimself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess o

ceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enu

ncluding, but not limited to, those crimes designated in 18 USC §2241, §2242, §2243, §2421, and §2423, criminal offenses outlined in Chapter 800 of the Federal Codes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01; and §827.04. 16. The above-described acts took place