Epstein Secrets

m yours (USAO) or one of the many plaintiffs' attorneys as it relates to what I can do or assert in defense of Mr. Epstein. As I expressed to Judge Marra, my charge from Mr. Epstein is to take no action that could reasonably be considered to be a violation of the NPA. With that in mind, I am sending

E DOE, et al., 6 Plaintiffs, vs. JUNE 12, 2009 7 8 JEFFREY EPSTEIN, 9 Defendant. 10 11 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, 12 UNITED STATES DISTRICT JUDGE APPEARANCES: 13 14 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 18205 Biscayne Bou

ert in defense of Mr. Epstein. As I expressed to Judge Marra, my charge from Mr. Epstein is to take no action

statute of limitations. As to Count I, which is plead pursuant to state law, it is well settled that this Court is to apply Florida law. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o)., Fla. Stat. §95.11(3

m yours (USAO) or one of the many plaintiffs' attorneys as it relates to what I can do or assert in defense of Mr. Epstein. As I expressed to Judge Marra, my charge from Mr. Epstein is to take no action that could reasonably be considered to be a violation of the NPA. With that in mind, I am sending

laintiffs, vs. JEFFREY EPSTEIN, Defendant. WEST PALM BEACH, FLORIDA JUNE 12, 2009 9 10 TRANSCRIPT OF MOTION HEARING 11 BEFORE THE HONORABLE KENNETH A. MARRA, UNITED STATES DISTRICT JUDGE 12 13 14 15 16 APPEARANCES: FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 18205 Biscayne

ert in defense of Mr. Epstein. As I expressed to Judge Marra, my charge from Mr. Epstein is to take no action

statute of limitations. As to Count I, which is plead pursuant to state law, it is well settled that this Court is to apply Florida law. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o)., Fla. Stat. §95.11(3

09/23/2008 51 ORDER denying as moot 42 Motion to Dismiss; denying as moot 14 Motion for Extension of Time to Respond to Complaint. Signed by Judge Kenneth A. Marra on 9/23/08. (ir) (Entered: 09/23/2008) 09/25/2008 52 SCHEDULING REPORT- Rule 26(1). (Herman, Jeffrey) (Entered: 09/25/2008) 09/30/2008 53 SCHEDU

oe No. 4'. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson

o state a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a

oe No. 5'. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 9:08-cv-80119-KAM Member case: (View

09/23/2008 42 ORDER denying as moot 4.5 Motion to Dismiss; denying as moot 12 Motion for Extension of Time to Respond to Complaint. Signed by Judge Kenneth A. Marra on 9/23/08. (ir) (Entered: 09/23/2008) 09/25/2008 51). SCHEDULING REPORT- Rule 26(1). (Herman, Jeffrey) (Entered: 09/25/2008) 09/30/2008 51. SCH

o state a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a

AM Doe v. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson

:00 AM in West Palm Beach Division before Judge Kenneth A. Marra. Calendar Call set for 1/22/2010 10:00 AM in West Palm Beach Division before Judge Kenneth A. Marra., Amended Pleadings due by 12/1/2008. Discovery due by 8/3/2009. Motions due by 8/31/2009. ORDER REFERRING CASE to Magistrate Judge Linnea R. Johns

o state a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a

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

e not present a federal court should hesitate to exercise jurisdiction over state claims, even though bound to apply state law to them, Erie R. Co. I. Tompkins, 304 U.S. 64.Needless decisions of state law [by a federal court] should be avoided both as a matter of comity and to promote justice between the p