Epstein Secrets

21 LRJ, MEDREQ, REF_DISCOV U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80119-1CAM Doe v. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson Member case: (View Member Case) Case: 9:09-cv-80802-KAM Caus

ON Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No- Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply to Defendant Jeffrey Epstein's Response to Plaintiffi Jane Doe No. 101 and Jane Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101, Jane Doe No. 102. Associate

red: 02/08/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe. (Herman, Jeffrey) (Entered: 05/22/2008) 05/22/2008 5 SUMMONS Returned Executed by Jane Doe. Jeffrey Epstein served on 5/7/2008, Answer due 5/27/2008. (Ik) (Entere

FTA00175604 CM/ECF - Live Database - flsd Page 17 of 21 05/20/2009 Ma NOTICE be. of Filing Withdrawal of Previously Raise Lions to Defendant. Jetey Epstein's Motion to Ag And/Or IdentifyMf. in the Style of This Case and Motion to Identi . in Third-Party Subpoenas for Purposes of Discovery, Or, Alternati

. 2 I JEFFREY EPSTEIN, Plaintiff, Defendant. DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES TO PLAINTIFF'S S

legations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary comp

underlying elements of her claims. Supporting Memorandum of Law Standard on Rule 12(b)(6) Motion To Dismiss As established by the Supreme Court in Bell Atlantic Corp.'. Twombly, 127 S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead EFTA00175634 Case 9:08-cv-L .19-KAM Docur

llegations" each describes the plan and scheme of Defendant Epstein to recruit underage girls to his Palm Beach mans

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

federal statutory claim "as she would have had if Mr. Epstein had been tried federally and 7 EFTA00188269 C

008 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARFtA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, CASE NO.: 08-CV-

e all similarly structured and assert the same claims. In the section entitled "Factual Allegations" each describes the plan and scheme of Defendant Epstein to recruit underage girls to his Palm Beach mansion for "massages". (Jane Doe No. 2 Amd. Compl. 10-11; Jane Doe No. 3 Amd. Comp. ¶ I 0-11; Jane Doe

ort of their claims in Counts I and Ill. According to Defendant, the pleadings in this case do not satisfy "the standard of pleading" established in Bell Atlantic Corp.'. Twombly 127 S.Ct. 1955 (2007). In making this argument, Defendant would extend Twombly well beyond its intended scope. Twombly was an antitrust c

se - flsd Page 1 of 17 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80380-KAM Doe No. 4'. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson Lead case: 9:08-ev-80111-.KAM Member case• (View Member Case)

ON Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No- Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply to Defendant Jeffrey Epstein's Response to Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101, Jane Doe No. 102. Associate

4/21/2008) 05/22/2008 6 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 4. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 7. Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 4. (Attachments: # 1 Exhib

. 4 1. Plaintiff, JEFFREY EPSTEIN Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS AND MOTION FOR MORE DEFINITE

underlying elements of her claims. Supporting Memorandum of Law Standard on Rule 12(b)(6) Motion To Dismiss As established by the Supreme Court in Bell Atlantic Corp.'. Twombly 127 S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead EFTA00175793 Case 9:08-cv-8( 3-KAM Docume

lsd Page 1 of 15 LRJ U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80232-KAM Doe No. 3 v. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 2:flasaAhd Member case: (View Member Case) Case: 9:09-cv-80802-KAM Cause: 28:1332 Diversity-Perso

file this document. (Is) (Entered: 05/20/2009) 05/20/2009 2.$ NOTICE by C.M.A. of Filing Withdrawal of Previously Raised Objections to Defendant, Jeffrey Epstein's Motion to Compel And/Or Identify C.M.A. in the Style of This Case and Motion to Identify C.M.A. in Third-Party Subpoenas for Purposes of Discovery,

3/11/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 3. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 3. (Attachments: # 1 Exhibi

plicable statute of limitations. WHEREFORE Defendant requests that this Court deny the re ' f sought by Plaintiff. Robert D. C itton, Jr. Attorney f. Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also

underlying elements of her claims. SupportIna Memorandum of Law Standard on Rule 12(b)(6) Motion To Dismiss As established by the Supreme Court in Bell Atlantic Corp.'. Twomblv 127 S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead "enough facts to state a claim to relief that

- flsd ( Page 1 of 14 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80381-KAM Doe No. 5'. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 9:08-cv-80119-KAM Member case: (View Member Case] Case: 9:09-cv-80802-KAM Cause: 28:1332 Diversit

eth A. Marra on 5/20/2009. (1c3) (Entered: 05/20/2009) 05/20/2009 9B NOTICE by of Filing Withdrawal of Previously RaisedObjections to Defendant, Jeffrey Epstein's Motion to ConaitAnd/Or Identify . in the Style of This Case and Motion to IdentlfrM. in Third-Party Subpoenas for Purposes of Discovery, Or, Alter

4/17/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 5. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 5. (Attachments: # I Exhibi

5 1. JEFFREY EPSTEIN, Plaintiff, Defendant. DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES TO PLAINTIFF'S S

in the light most favorable to the plaintiff. . DeKalb County Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006). Significantly, the Supreme Court in Bell Atlantic Corp.'. Twombly abrogated the often cited observation that "a complaint should not be dismissed for failure to state a claim unless it appears beyond doub