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Y EPSTEIN RALD LEFCO r RT ESQ. COUNSEL TO JEFFR Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EP
in the woe position as they would have been had Mr. Epstein been convicted al trial. No more; no less. From
hearing shall be limited to the issue of whether Defendant Epstein's defense of the civil actions filed against him
of Breach USAO No. 2006R0 181 June 9, 2009 To Jeffrey H. Sloman Acting United States Attorney Robert
TATES ATTORNEY Dated: By: Dated: Dated: Dated: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY JEFFREY EPSTEIN RALD LEFCO r RT ESQ. COUNSEL TO JEFFR Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Case No. 08-80736-CV-MARRA P-011815 EFTA00192861 By signing this Addendum, Epstein assert
e of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. Solimino 501 U.S. 104, 108 (1991), 'the courts may take it as given that Congress has legislated with an expectation that the pr
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
e of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. v. Solimino, 501 U.S. 104, 108 (1991), "the courts may take it as given that Congress has legislated with an expectation that th
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
e of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. v. Solimino, 501 U.S. 104, 108 (1991), "the courts may take it as given that Congress has legislated with an expectation that th
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
e of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. v. Solimino, 501 U.S. 104, 108 (1991), "the courts may take it as given that Congress has legislated with an expectation that th
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
e of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. v. Solimino, 501 U.S. 104, 108 (1991), "the courts may take it as given that Congress has legislated with an expectation that th
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
e of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. v. Solimino, 501 U.S. 104, 108 (1991), "the courts may take it as given that Congress has legislated with an expectation that th
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