Epstein Secrets

). B. Personal Jurisdiction 5] The Plaintiff has the burden of establishing personal jurisdiction by a pre- ponderance of the evidence. Combs v. Bakker, 886 F2d 673 (4th Cir.1989). A two-prong test governs an analysis of in personam jurisdiction. The first prong re- quires that the activiti,te defe

ave re- fused to recognize breach of fiduciary duty claims brought against priests or dioceses because such claims offend the First Amendment- See Gaines, 354 F.Supp2d at 583 (citing Dausch v. Rykse, 52 F.3d 1426, 1438 (7th Cir.1994)); Teadt v. St. John's Evangelical Church. of Burr Oak Mick, 237 M

ligion- neutral as they "involve) I purely secular conduct that is analogous to an intentional tort and does not hinge on ecclesiastical matters." Gaines, 354 F.Supp2d at 583. A court also need not define a reasonable standard of care or inquire as to whether EFTA00226241 DOE v. 1,1DERATORE cue a

m contact and will get back with you. Thanks again. From: Sloane, Carmen [mailto Sent: Wednesday, September 23, 2009 5:19 PM To: Barbara Bums Cc: Baker, Rosalyn; Gaines, Willie Subject: Jeffrey Epstein «P154Scanner20090923170423.pdf>> Mrs. Bums, FYI - This is Mr. Epstein response to Attorney Horo

ll get back with you. Thanks again. From: Sloane, Carmen [mailto Sent: Wednesday, September 23, 2009 5:19 PM To: Barbara Bums Cc: Baker, Rosalyn; Gaines, Willie Subject: Jeffrey Epstein «P154Scanner20090923170423.pdf>> Mrs. Bums, FYI - This is Mr. Epstein response to Attorney Horowitz declaration.

e Info or can't offer any more assistance. From: Sloane, Carmen [mailtplIMIIIMIMIal Sent: Friday, October 09, 2009 8:45 AM To: Barbara Burns Cc: Baker, Rosalyn; Gaines, Willie Subject: Jeffrey Esptein <<P154Scanner20091009075059.pdf>> Mrs. Bums, I sent an email on September 23 regarding "No cont

offer any more assistance. From: Sloane, Carmen [mailtplIMIIIMIMIal Sent: Friday, October 09, 2009 8:45 AM To: Barbara Burns Cc: Baker, Rosalyn; Gaines, Willie Subject: Jeffrey Esptein <<P154Scanner20091009075059.pdf>> Mrs. Bums, I sent an email on September 23 regarding "No contact with the vict

no victim contact and will get back with you. Thanks again. From: Sloane, Carmen Sent: Wednesday, September 23, 2009 5:19 PM To: Barbara Bums Cc: Baker, Rosalyn; Gaines, Willie Subject: Jeffrey Epstein «P154Scanner20090923170423.pdf>> Mrs. Bums, FYI - This is Mr. Epstein response to Attorney Horo

t and will get back with you. Thanks again. From: Sloane, Carmen Sent: Wednesday, September 23, 2009 5:19 PM To: Barbara Bums Cc: Baker, Rosalyn; Gaines, Willie Subject: Jeffrey Epstein «P154Scanner20090923170423.pdf>> Mrs. Bums, FYI - This is Mr. Epstein response to Attorney Horowitz declaration.

m sorry that I don't have more Info or can't offer any more assistance. From: Sloane, Carmen Sent: Friday, October 011 AM To: Barbara Burns Cc: Baker, Rosalyn; Gaines, Willie Subject: Jeffrey Espteln <<P154Scanner20091009075059.pdf>> Mrs. Bums, I sent an email on September 23 regarding "No cont

on't have more Info or can't offer any more assistance. From: Sloane, Carmen Sent: Friday, October 011 AM To: Barbara Burns Cc: Baker, Rosalyn; Gaines, Willie Subject: Jeffrey Espteln <<P154Scanner20091009075059.pdf>> Mrs. Bums, I sent an email on September 23 regarding "No contact with the vict