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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
5363 Case 9:08-cv-80811-KAM Document 78 Entered on FLSD Docket 05/08/2009 Page 15 of 25 v. Epstein, et al. 1,15 Plaintiff's reliance on In re Hawaiian Airlines, Inc. (Konop v. Hawaiin Airlines, Inc.I 355 B.R. 225 (D. Hi. 2006), is misplaced. Unlike the Stored Communications Act, 18 U.S.C. §2707(c), endnote
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
e 9:08-cv-80811-KAM Document 78 Entered on FLSD Docket 05/08/2009 Page 15 of 25 C.M.A. v. Epstein, et al. Page 15 Plaintiff's reliance on In re Hawaiian Airlines, Inc. (Konop v. Hawaiin Airlines, Inc.), 355 B.R. 225 (D. Hi. 2006), is misplaced. Unlike the Stored Communications Act, 18 U.S.C. §2707(c), endnot
To: From: Jeffrey Epstein Sent: Mon 8/17/2009 10:52:04 PM Subject: Re: Travel Itinerary 21AUGI do it On Mon, Aug 17, 2009 at 6:05 PM, wrote: Here is the itinerary we wo
To: From: Jeffrey Epstein Sent: Mon 8/17/2009 10:52:04 PM Subject: Re: T
To: From: Jeffrey Epstein Sent: Mon 8/17/2009 10:52:04 PM Subjec
AUGI do it On Mon, Aug 17, 2009 at 6:05 PM, wrote: Here is the itinerary we worked out with the travel agent guy. We decided to nix Las Vegas as Hawaiian Airlines is the only airline to fly direct from Vegas to Honolulu and it's not part of the "alliance". It would have to be a separate add on and would be S12
IN THE NEWS • Declassified Report Fuels Dispute Over Origins of Trump-Russia Probe • Continued Reporting: amily Expresses Shock Over Trump Saying Epstein 'Stole' Her • Continued Reporting: FBI Opens New Zealand Office to 'Counter the CCP,' Says Director Patel COUNTERTERRORISM • Migrants Not Properly
r Video Reveals Mystery 'Orange Shape' Independent (07/31, Liddell) reported that a mysterious "orange shape" was seen on surveillance footage near Jeffrey Epstein's cell before his death, sparking debate over what or who it may be. Forensic experts argue that the shape could be a person wearing an orange prison
pstein Mess Creates a 'Ticking Time Bomb' The Rolling Stone (07/31, Suebsaeng) reported that the Trump administration's attempt to distract from the Jeffrey Epstein investigation by accusing former President Barack Obama of treason is not working, with many seeing it as a weak attempt at distraction. Ac
new ways to evade existing security measures. The group's targets have included companies in the insurance, retail, and airline industries, such as Hawaiian Airlines, Marks & Spencer, and Qantas, and it is advised that organizations develop multichannel verification methods and require multiple layers of approval
peka • Continued Reporting: FBI Task Force Heading To Memphis, Tennessee • Continued Reporting: FBI Officials Rip Through Conspiracy Theories About Epstein's Death COUNTERTERRORISM • Flight At San Diego Airport Evacuated And One Arrested Following Reports Of A Bomb Threat • Official Pushed to Rewrite
the story. Continued Reporting: FBI Officials Rip Through Conspiracy Theories About Epstein's Death The New York Post (05/20, Reilly) reported that Jeffrey Epstein's brother, Mark Epstein, refuses to accept that his brother died by suicide, contradicting Director Patel's statement. Mark Epstein criticized Directo
The New York Post (05/20, Reilly) reported that Jeffrey Epstein's brother, Mark Epstein, refuses to accep
Flight At San Diego Airport Evacuated And One Arrested Following Reports Of A Bomb Threat The Associated Press (05/20, Staff Writer) reported that a Hawaiian Airlines flight at San Diego International Airport was evacuated due to a reported bomb threat. According to the article, a 35-year-old man was arrested for
e visit virginatlantic.com/flyingclub Activity pRline dale 941F/M' Payment Recerve4"lhenlyYou,Saat Armont$ t19593.96 Due in Full Activity for JEFFREY E EPSTEIN Card )0O3E>XOX4 3103S Amount $ 03/29/07 AMAZON.COM AMZN.COMIBILL WA 98101 AMAZON.COM MERCHANDISE ROC No. 0098143801 18.66 03/31/07 MINSKOFF TH
DUPLICATE COPY PreparolFor JEFFREY E EPSTEIN Account Muster Clain° Oolo XXXX•XXXXX4
Cardmembers who meet certain qualifying criteria. By responding you will be disclosing to the merchant that you meet these criteria. EFTA01705056 Epstein, Jeffrey E EFTA01705057 QEBRD REPOSITORY DETAILED RESULTS R030QEBRD 1300884 S-GCSA-10 06/20/07 371565781438 0000000000000000000000000100 9999
enew Orceste Card. Bans poet W1 be a edded to your Verbees. Rewards emoted 68 weekly der eaves appear on your bierg atement Gams ID:7914. Fly with Hawaiian Airlines Hawaii starts with Hawaiian Airlines offering daily nonstop flights to the islands from nine western U.S. gateways. Enjoy award-winning service in
08 12/14/06 BLOOMINGDALES NEW YORK CREME DE LA MER NY 211.33 12/15/06 POLO RETAIL CORPORATDALLAS APPAREUACCESSORIES TX 1,624.00 01/06/07 JEFFERY #0002 NEW YORK •GODDS AND SERVICES NY 312.12 Total of S&T and/or JxPO Activity New Charges Payments/Credits 3,691.53 -3,610.34 Important Si
vaida• program apply. Foe mom Idanaacet slat marbothhronrch corn. Dom .Stela we not indulad. Tomo red oorolfora d to Ptrirg lorgoro *PTY. Fly with Hawaiian Airlines Hawaii starts with Hawaiian Airlines offering daily nonstop flights to the islands from nine western U.S. gateways. Enjoy award-winning service In
W YORK NY GOODS AND SERVICES 432.42 07/01/06 JEFFREY 80002 NEW YORK NY 03 CLOTHING 561 28 07/03/0
ings on Hawaiian Airlines@ Special offer for Membership Rewards@ enrollees, receive 10% off Fall web fares between the Mainland U.S. and Hawaii on Hawaiian Airlines.* Book now through October 31, 2006, and travel between August 28-December 14, 2006. *Some restrictions apply. • Terms act cottons d the Islentos
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Entities connected to both Jeffrey Epstein and Hawaiian Airlines

Marc Rich
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
John F. Kennedy
PERSON
NEW YORK NY
LOCATION
Joi Ito
PERSON
Eric Trump
PERSON
George Mitchell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSON
Joe Biden
PERSON
Prince Charles
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Julie K. Brown
PERSON