Epstein Secrets

009 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CIV- 80469 - MARRA/JOHNSON JANE DOE II, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY TO & MOTION TO STRIKE PORTIONS OF PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT'S MOTION TO DISMI

T COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CIV- 80469 - MARRA/JOHNSON JANE DOE II, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY TO & MOTION TO STRIKE PORTIONS OF PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT'S MOTION TO DISMISS Defendant, JEFFREY EPSTEIN,

I, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY TO & MOTION TO STRIKE PORTIONS OF PLAINTI

69 - MARRA/JOHNSON JANE DOE II, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY T

ct at the time of the underlying conduct unless there is a clear statement that an amendment is to apply retroactively to prior conduct. See, e.g., Hughes Aircraft Co. v. U.S. ex rel Schumer, 520 U.S. 939, 952 (1997)("Given the absence of a clear statutory expression of congressional intent to apply the 1986 amend

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

time of the underlying conduct unless there is a clear statement that an amendment should apply retroactively to pre-enactment conduct. See, e.g., Hughes Aircraft Co. v. United States ex rel. Schumer, 520 U.S. 939, 952 (1997) ("Given the absence of a clear statutory expression of congressional intent to apply the

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

time of the underlying conduct unless there is a clear statement that an amendment should apply retroactively to pre-enactment conduct. See, e.g., Hughes Aircraft Co. v. United States ex rel. Schumer, 520 U.S. 939, 952 (1997) ("Given the absence of a clear statutory expression of congressional intent to apply the

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

time of the underlying conduct unless there is a clear statement that an amendment should apply retroactively to pre-enactment conduct. See, e.g., Hughes Aircraft Co. v. United States ex rel. Schumer, 520 U.S. 939, 952 (1997) ("Given the absence of a clear statutory expression of congressional intent to apply the

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

time of the underlying conduct unless there is a clear statement that an amendment should apply retroactively to pre-enactment conduct. See, e.g., Hughes Aircraft Co. v. United States ex rel. Schumer, 520 U.S. 939, 952 (1997) ("Given the absence of a clear statutory expression of congressional intent to apply the

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

time of the underlying conduct unless there is a clear statement that an amendment should apply retroactively to pre-enactment conduct. See, e.g., Hughes Aircraft Co. v. United States ex rel. Schumer, 520 U.S. 939, 952 (1997) ("Given the absence of a clear statutory expression of congressional intent to apply the