cific circumstances. But what the plaintiffs have done in a number of the cases, and these are pending motions, is they've said is, well, we think C.M.A. cases is a good example, they've pled 30 separate counts of 2255 alleged violations. And they're saying under the circumstances is, therefore, we h

Entered on FLSD Docket 02/09/2009 Page 1 of 91 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRAMOHNSON C.M.A., Plaintiff(s), VS. TEIN and Defendant(s). FIRST AMENDED COMPLAINT Parties, Jurisdiction and Venue COMES NOW the Plaintiff, C.M.A., and brings

r the 9 agreement is supposed to be admitted. Now, as to the amount of 10 damages, there are legal issues that will be before you and 11 under the C.M.A. cases that are getting before you, as to 12 whether it is 50 or 150. That has nothing to do with the NPA. 13 There are legal issues that are befor

abuse of a minor child. The Defendant, JEFFREY EPSTEIN, at all times material to this cause of action, knew and should have known of the Plaintiff, C.M.A.'s minority. 17. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the Defendant, JEFFREY EPSTEIN, entered pleas of "g

uction of these confidential and private treatment records would only serve to further humiliate, embarrass, and victimize C.M.A . 9. Furthermore, C.M.A.'s treatment records from the Inc. and are protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee v.

ity under the agreement is supposed to be admitted. Now, as to the amount of damages, there are legal issues that will be before you and under the C.M.A. cases that are getting before you, as to whether it is 50 or 150. That has nothing to do with the NPA. There are legal issues that are before you a

xpert discovery must be completed on June 29, 2009 for C.M.A. 6. As to C.M.A., Jane Doe and Jane Does 2-7, each has objected to relevant discovery. C.M.A. has even refused to produce certain information that she agreed to produce in discovery. The foregoing delay tactics has prevented Epstein from co

e Bruce E. Reinhart, P.A. 250 South Australian Avenue Suite 1400 West Palm Beach, FL 33401 Tel: (561) 202-6360 Subject matter: Defendant 3. C.M.A.'s attorneys: Jack Scarola, Esq. and Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm B

Bruce E. Reinhart, P.A. 250 South Australian Avenue Suite 1400 West Palm Beach, FL 33401 Tel: (561) 202-6360 Subject matter: Defendant 3. do C.M.A.'s attorneys: Jack Scarola, Esq. and Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm B

is Court subsequently denied on December 12, 2008 (DE 28). The case was transferred from Judge Zloch to this division on September 3, 2008 (DE 21). C.M.A. filed her First Amended Complaint on February 10, 2009. (C.M.A. DE 39-40). Epstein's Motion to Dismiss same was filed on March 12, 2009. (C.M.A. DE

A/JOHNSON, in Defendant's Motion to Dismiss directed to Plaintiff C.M.A.'s Amended Complaint, Plaintiff C.M.A.'s Response, and Defendant's reply to C.M.A.'s response (which has yet to be filed). In this action, Plaintiffs Complaint attempts to allege a cause of action pursuant to 18 U.S.C. §2255 - Civ

r the 9 agreement is supposed to be admitted. Now, as to the amount of 10 damages, there axe legal issues that will be before you and 11 under the C.M.A. cases that are getting before you, as to 12 whether it is 50 or 150. That has nothing to do with the NPA. 13 There are legal issues that are befor

r the 9 agreement is supposed to be admitted. Now, as to the amount of 10 damages, there are legal issues that will be before you and 11 under the C.M.A. cases that are getting before you, as to 12 whether it is 50 or 150. That has nothing to do with the NPA. 13 There are legal issues that are befor

r the 9 agreement is supposed to be admitted. Now, as to the amount of 10 damages, there are legal issues that will be before you and 11 under the C.M.A. cases that are getting before you, as to 12 whether it is 50 or 150. That has nothing to do with the NPA. 13 There are legal issues that are befor

ity under the agreement is supposed to be admitted. Now, as to the amount of damages, there are legal issues that will be before you and under the C.M.A. cases that are getting before you, as to whether it is 50 or 150. That has nothing to do with the NPA. There are legal issues that are before you a

r the 9 agreement is supposed to be admitted. Now, as to the amount of 10 damages, there are legal issues that will be before you and 11 under the C.M.A. cases that are getting before you, as to 12 whether it is 50 or 150. That has nothing to do with the NPA. 13 There are legal issues that are befor

r the 9 agreement is supposed to be admitted. Now, as to the amount of 10 damages, there are legal issues that will be before you and 11 under the C.M.A. cases that are getting before you, as to 12 whether it is 50 or 150. That has nothing to do with the NPA. 13 There are legal issues that are befor

sponse in Opposition to Motion, filed by Jeffrey Epstein, 114 Motion for Protective Order filed by C.M.A., 121 Motion for Protective Order, filed by C.M.A., 137 Motion to Strike filed by Jeffrey Epstein. Signed by Magistrate Judge Linnea R. Johnson on 7/16/2009. (ail) (Entered: 07/17/2009) NOTICE of Co