Epstein Secrets

nt in this case. In this Court's Opinion and Order on Motion to Dismiss and Motion for More Definite Statement in the case styled Jane Doe No. 6 v. Jeffrey Epstein Case No. 08-80994-CIV-Marra ("Jane Doe No. 6) this Court rejected any contention by the Defendant that the Supreme Court's decision in Bell Atlantic Corp

civious, and sexual acts, including, EFTA00201211 Case 9:08-cv-80811-KAM Document 58 Entered on FLSD Docket 04/13/2009 Page 2 of 18 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-C1V-MARRA/JOHNSON Plaintiffs Memorandum in Response to Defendant Jeffrey Epstein's Motion to Dismiss First Amended Co

12, 2009, this Court entered the Opinion and Order on Motion to Dismiss and Motion for More Definite Statement in the case styled Jane Doe No. 6 v. Jeji-ey Epstein, Case No. 08-80994-UV-Marra.' In that Order, the Court granted the Defendant's Motion for More Definite Statement with respect to allegations conce

The interpretation of Section 2255 urged by the Defendant Epstein implicates the same concerns EFTA00201218 Case

0811-CIV-MARRA/JOHNSON C.M.A., Plaintiff, vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. PLAINTIFF

atement in the case styled Jane Doe No. 6 v. Jeji-ey Epstein, Case No. 08-80994-UV-Marra.' In that Order, the

de justice for any injury contemplated by the Alien Tort Statute and the TVPA or treated these dealings with the protection of human rights." The Tachiona court, therefore, ruled that with respect to the TVPA the federal common law concerning damage awards allows for both compensatory and punitive dama

claim does not specifically provide for punitive damages, the remedy of punitive damages can be supplied through federal common law. For example, in Tachiona v. Mugabe, 216 F.Supp.2d 262 (S.D.N.Y. 2002) the court upheld an award of compensatory damages and punitive damages under the Torture Victim Protec

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

equest for punitive damages under §2265 is required to be dismissed or stricken. (Plaintiffs Response, Part III, p. 11-18). Plaintiff's reliance on Tachiona v. Mugabe, 216 F.Supp.2d 262 (S.D.N.Y. 2002), is misplaced as the federal statute at issue, the Torture Victim Protection Act (TVPA), is clearly di

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

quest for punitive damages under §2255 Is required to be dismissed or stricken. (Plaintiff's Response, Part III, p. 11-18). Plaintiff's reliance on Tachiona v. Mugabe, 216 F.Supp.2d 262 (S.D.N.Y. 2002), is misplaced as the federal statute at issue, the Torture Victim Protection Act (TVPA), is clearly di