frey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed February 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, s

frey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed February 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, s

o allow suit by any person who, "while a minor," was a victim of a violation. PRIVILEGED AND CONFIDENTIAL 9 ATTORNEY WORK PRODUCT EFTA00189795 First Amended Complaint or, in the Alternative, for a More Definite Statement (which is attached hereto): A. The applicable version of § 2255 only permits "minor" to sue:

he Plaintiff, for the purpose of sexually assaulting the girls and/or coercing them to engage in prostitution in return for the payment of monies. (First Amended Complaint, ¶ 9). The scheme was motivated by the Defendant's sexual preference and obsession for minor girls. Id. Pursuant to the scheme, minor girls, includ

8-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 35 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-C IV-MARRA/JOH NSON First Amended Complaint 84. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses

EFTA00310009 DEFENDANT'S REPLY TO PLAINTIFFS' OPPOSITION TO MOTION TO DISMISS Epstein. et aL v. Fanelli Paneling. Inc. Page 7 statute within its First Amended Complaint. Nevertheless, this statute is lustily utilized in opposing Defendant's Motion to Dismiss on point, to the extend that 5 V.I.C. § 4903(a)(I) & (2)

Defendants prays as follows: 2 1. That judgment be entered in favor of Defendant and against Plaintiff. 3 2. That Plaintiff take nothing by his First Amended Complaint and that 4 said First Amended Complaint be dismissed in its entirety, with prejudice. 5 3. That Defendant be awarded costs of suit herein. 6 4.

king relief from a protective order issued in the Gee v. Maxwell matter ("Protective Order" and "Giuffre Matte?) and ii) to dismiss the plaintiff's First Amended Complaint ("FAC") in the above-captioned matter ("Jane Doe Matter"), and b) your request for an opportunity to depose Jeffrey Epstein. As a preliminary matte

pstein, through counsel, moves to set-aside the default, which motion is never ruled upon (Res.App. 4, pp.34-36).3 April 13, 2011 Epstein files his First Amended Complaint (App.6) and never moves to default Rothstein. August 22, 2011 Epstein filed the Second Amended Complaint (App.8) which included a claim against E

fs are contractually prohibited from suing or initiating, prosecuting, participating in or otherwise pursuing a suit against Molyneux. l A copy of First Amended Complaint filed in J.P. Molynex Studio, Ltd. and Juan Pablo Molyneux v. Jeffrey Epstein and L.S.J., LLC filed in the District Court of the Virgin Islands, Div

11. Defendant maintains that the Court Granted, in part, its Motion to Dismiss, pursuant to Fed. R. Civ. P. 12(b)0, with dismissal of the existing First Amended Complaint as the appropriate remedy for the relief requested. 12. Defendant acknowledges, however, that the Court may exercise its discretion to join parti

s i) seeking relief from a protective order issued in the v. Maxwell matter ("Protective Order" and "M Matte?) and ii) to dismiss the plaintiff's First Amended Complaint ("FAC") in the above-captioned matter ("Jane Doe Matter"), and b) your request for an opportunity to depose Jeffrey Epstein. As a preliminary matte

ase 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 63 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-C IV-MARRA/JOH NSON First Amended Complaint 147. For the second time in April of 2003, again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directe