Epstein Secrets

the attached letter providing notice of a breach of the Non-Prosecution Agreement on attorneys for Jeffrey Epstein. On Friday, June 12, 2009, Judge Marra will be presiding ova a hearing on Jeffrey Epstein's motions to stay all of the civil lawsuits filed against him by victims identified through our i

Apr-el lo ()Writ( Judge from Magistrate Judgment VI. RELATED/RE-FILED (50C IsSINMONIO • CASE(S). word perk a) Re-filed Case OYES 9) NO JUDGE Kenneth A. Marra b) Related Cases OYES ONO DOCK MBETER See Attached NU VII. CAUSE OF ACTION CI e Ilse U.S. Civil Statute under Mikis you ere filing and Wnie a Br

s for Jeffrey Epstein. On Friday, June 12, 2009, Judge Marra will be presiding ova a hearing on Jeffrey Epstei

cases involving this defendant in this Court) involved a single count predicated on multiple alleged violations of predicate criminal statutes. See Tilton Playboy Entertainment Group. Inc., 554 F.3d 1371 (I lth Cir. Jan. 15, 2009); Smith, 428 F. Supp. 2d at 432; Doe, 478 F. Supp. 2d at 754; poc No. 2

ions to Epstein's Motion to Compel and/or Identify. This Notice should only be filed in 08-80119, not in all of the Epstein cases.. Signed by Judge Kenneth A. Marra on 5/20/2009. Associated Cases: 9:08-cv-80119-KAM et al. (1c3) (Entered: 05/20/2009) 05/22/2009 15 Clerks Notice of Docket Correction and Instruc

No. 102 v. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 9:08-cv-80119-KAM Member case: (View

mphasis added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appropriate United States District Court." Id, at 1189. In Tilton v. Playboy Entertainment Group, Inc 554 F.3d 1371 (11th Cir. Jan. 15, 2009), the District Court granted plaintiff "the minimum 'actual damages' pre

t 06/26/2009 Page 2 of 10 CASE NO.: 09-CV-80591-MARRA/JOHNSON First Amended Complaint ("FAC') [D.E. 9]

e violations, all counts and violations must be lumped together as one with a single penalty. Multiple counts are proper, as shown, for example, in Tilton v. Playboy Entertainment Group, Inc., 554 F.3d 1371, 1375 (11th Cir. 2009), on which Defendant relies in his Motion. (Motion 34). In Tilton, the co

UTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRA/JOHNSON C.M. A., Plaintiff, v. EPSTEIN and D

added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appropriate United States District Court.'" Id, at 1189. See also Tilton v. Playboy Entertainment Group, Inc., 554 F.3d 1371 (11th Cir. Jan. 15, 2009)(District Court granted plaintiff "the minimum 'actual damages' prescr

utory text.2 See also this Court's recent orders on motions to dismiss in other actions filed against EPSTEIN by "Jane Does," Case Nos: 08-CV-80119- MARRA/JOHNSON; 08-CV-80232-MARRA-JOHNSON; and 08-CV-80380-MARRA- JOHNSON; requiring sufficient allegations of predicate acts. A reading of §2422(b) shows

phasis added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appropriate United States District Court.'" Id, at 1189. In Tilton v. Playboy Entertainment Group Inc 554 F.3d 1371 (11th Cir. Jan. 15, 2009), the District Court granted plaintiff "the minimum 'actual damages' pres

EIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S AMENDED'

violation is different. There is no language in the statute that prohibits the Plaintiff from suing for each violation, and the dicta set forth in Tilton v. Playboy Entertainment Group, Inc., 554 F. 3d 1371 (11th Cir. 2009), vaguely noting that the District Court awarded the Plaintiff "the minimum 'a