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marker2/court-doe-6-v-epstein/EFTA02742589/EFTA02742589.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 6,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant. /
+
+CASE NO.:
+
+08-CV-80994-Hurley
+
+![](_page_0_Picture_8.jpeg)
+
+# COMPLAINT
+
+Plaintiff, Jane Doe No. 6 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey Epstein, as follows:
+
+## Parties, Jurisdiction and Venue
+
+- 1. Jane Doe No. 6 is a citizen and resident of the State of Florida, and is sui juris.
+- 2. This Complaint is brought under a fictitious name to protect the identity of the Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a minor.
+  - 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+  - 4. This is an action for damages in excess of \$50 million.
+- 5. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. §1332(a), as the matter in controversy (i) exceeds \$75,000, exclusive of interest and costs; and (ii) is between citizens of different states.
+- 6. Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
+
+jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein which form part of the same case or controversy.
+
+7. This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as <sup>a</sup> substantial part of the events or omissions giving rise to the claim occurred in this District.
+
+#### Factual Allegations
+
+8. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, approximately 52 years old. Epstein is afinancier and money manager with asecret clientele limited exclusively to billionaires. He is himself aman of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, St. and Palm Beach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
+
+9. Upon information and belief, Epstein has asexual preference and obsession for underage minor girls. He engaged in a plan and scheme in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave them money. In or about 2004, Jane Doe, then approximately 13 years old, fell into Epstein's trap and became one of his victims.
+
+10. Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted <sup>g</sup>irls in Florida, New York and on his private island, known as Little St. James, in St.
+
+11. Epstein's scheme involved the use of young girls to recruit underage girls. These underage girls were recruited ostensibly to give a wealthy man <sup>a</sup>massage for monetary compensation in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically disadvantaged underage girls from western Palm Beach County who would be enticed by the money
+
+being offered - generally \$200 to \$300 per "massage" session - and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made. This was an important element of Epstein's plan.
+
+12. Epstein's plan and scheme reflected a particular pattern and method. The underage victim would be brought or directed to Epstein's mansion, where she would be led up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. The girl would then find herself alone in the room with Epstein, who would be wearing only a towel. He would then remove his towel and lie naked on the massage table, and direct the girl to remove her clothes. Epstein would then perform one or more lewd, lascivious and sexual acts, including masturbation.
+
+13. Consistent with the foregoing plan and scheme, when Jane Doe was only 13 years old, she was recruited by another girl to give Epstein a massage for monetary compensation. Jane was brought to Epstein's mansion in Palm Beach. Once there, she was led up the flight of stairs to the room with the massage table. Epstein came into the room and directed Jane to remove her clothes and give him a massage. As directed by Epstein, Jane stripped to her underwear. Epstein then sexually assaulted Jane during the massage. hi addition, Epstein masturbated during the massage. Epstein then paid Jane money.
+
+14. As a result of this encounter with Epstein, Jane experienced confusion, shame, humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+
+#### COUNT I Sexual Assault and Batten
+
+15. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+
+16. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane Doe, creating a reasonable fear of imminent peril and sexual assault.
+
+17. Epstein intentionally inflicted harmful or offensive sexual contact on the person of Jane Doe.
+
+18. Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts were intentional, unlawful, offensive and harmful.
+
+19. Epstein's plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously.
+
+20. As a direct and proximate result of Epstein's assault on Jane, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages.
+
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this Court deems just and proper.
+
+#### COUNT 11 Intentional Infliction of Emotional Distress
+
+21. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+
+22. Epstein's conduct was intentional or reckless.
+
+23. Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds of decency.
+
+24. Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired.
+
+25. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional distress and
+
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing severe emotional distress to Jane Doe.
+
+26. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, has suffered and will continue to suffer severe mental anguish and pain.
+
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper.
+
+#### COUNT HI Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. 42422
+
+27. Plaintiff Jane Doe repeats and realleges paragraphs I through 14 above.
+
+28. Epstein used a facility or means of interstate commerce to knowingly persuade, induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or sexual activity for which any person can be charged with a criminal offense.
+
+29. Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
+
+30. As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal injury, including mental, psychological and emotional damages.
+
+31. Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a reasonable attorneys' fee.
+
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual and compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as this Court deems just and proper.
+
+### JURY TRIAL DEMAND
+
+Plaintiff demands a jury trial in this action on all claims so triable.
+
+Dated: September 0( , 2008
+
+Respectfully submitted,
+
+By: Yw
+
+J rcy M. Herman (FL Bar No. 521647)
+
+jherman@hermanlaw.com
+
+Stuart S. Merrnelstein (FL Bar No. 947245)
+
+ssm@hermanlaw.com
+
+Adam D. Horowitz (FL Bar No. 376980)
+
+ahorowitzahermanlaw.com
+
+HERMAN & MERMELSTEIN, P.A.
+
+Attorneys for Plaintiff
+
+18205 Biscayne Blvd., Suite 2218
+
+Miami, Florida 33160
+
+Tel: 305-931-2200
+
+Fax: 305-931-0877
+
+08-C \489994-titsrlef -Hopkins-lama COMERISHEETD Docket 09/11/2008 Page 7 of <sup>7</sup> The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service of pleading or other papers as required by law. except as provided by local rules of court. This form• approved by the Judicial Conference of the United States in September 1974. is required for the use of the Clerk of the Court for the purpose of initiating the civil docket sheet (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
+
+1(a) PLAINTIFFS JANE DOE NO. 6, (b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF PALM BEACH COUNTY (EXCEPT IN U.S. PLAINTIFF CASES) (c) ATTORNEYS (FIRM NAME. ADDRESS, AND TELEPHONE NUMBER) Herman & Mermebteln, PA, 18205 Biscayne Blvd., Suite 2218 Miami, FL 33160, (305) 931-2200
+
+DEFENDANTS JEFFREY EPSTEIN COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK (IN U.S. PLAINTIFF CASES ONLY) ATTORNEYS (IF KNOWN)
+
+(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH
+
+#### 11. BASIS OF JURISDICTION (PLACE AN X ONE BOX ONLY)
+
+O 1. U.S. Goverment X 3 Federal Question (U.S. Government Not aParty) 0 4. Diversity (Indicate Citizenship 01 Parties in Item Plaintiff O 2. U.S. Government Defendant Ill)
+
+evne97V-birki-4v045
+
+#### III. CITIZENSHIP OF PRINCIPAL PARTIES PLACE AN X IN ONE BOX FOR PLAINTIFF
+
+(For Diversity Case Only) PTF DEF Citizen of This State 01 0 Citizen of Another State 0 2 0 2 Citizen or Sutriect of a Foreign Country U 3 O <sup>3</sup> AND ONE FOR DEFENDANT PTF DEF Incorporated of Rincipal Place of O 4 <sup>0</sup> Business in This State Incorporated and Prince3al Ptece of 0 5 0 <sup>5</sup> Business in Another State Foreign Nation 0 6 0 <sup>6</sup>
+
+#### IV. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE. DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.) ACTION FOR SEXUAL ASSAULT UNDER 18 U.S.C. \$2422 AND STATE LAW
+
+<sup>N</sup>a. j\_ days estimated (for both sides) to try entire case
+
+| V. NATURE OF SUIT                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | (PLACE AN X IN ONE BOX ONLY)                                                                                                                                                                                                                                                                                                                                                                                                                                            |                                                                                                                                                                                                                                                                                                                                                                                                               |                                                                                                                                                                                                                                          |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
+|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| A CONTRACT                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | A TORTS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             | B FORFEITURE PENALTY                                                                                                                                                                                                                                                                                                                                                                                                                                                    | A BANKRUPTCY                                                                                                                                                                                                                                                                                                                                                                                                  | A OTHER STATUS                                                                                                                                                                                                                           |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
+| <input type="checkbox"/> 110 Insurance<br><input type="checkbox"/> 120 Marine<br><input type="checkbox"/> 130 <input checked="" type="checkbox"/> Act<br><input type="checkbox"/> 140 Negotiable Instrument<br><input type="checkbox"/> 150 Recovery of Overpayment & Enforcement of Judgment<br><input type="checkbox"/> 151 Medicare Act<br><input type="checkbox"/> 152 Recovery of Defaulted Student Loans (Excl. Veterans) B<br><input type="checkbox"/> 153 Recovery of Overpayment of Veteran's Benefits B<br><input type="checkbox"/> 160 Stockholder's Suits<br><input type="checkbox"/> 190 Other Contract<br><input type="checkbox"/> 195 Contract Product Liability | <b>PERSONAL INJURY</b><br><br><input type="checkbox"/> 310 Airplane<br><input type="checkbox"/> 315 Airplane Product Liability<br><input type="checkbox"/> 320 Assault, Libel & Stander<br><input type="checkbox"/> 330 Federal Employers' Liability<br><input type="checkbox"/> 340 Marine<br><input type="checkbox"/> 345 Marine Product Liability<br><input type="checkbox"/> 350 Motor Vehicle<br><input type="checkbox"/> 355 Motor Vehicle Product Liability<br><input checked="" type="checkbox"/> 360 Other Personal Injury | <input type="checkbox"/> 362 Personal Injury-Med Malpractice<br><input type="checkbox"/> 365 Personal Injury-Product Liability<br><input type="checkbox"/> 368 Asbestos Personnel Injury Product Liability<br><b>PERSONAL PROPERTY</b><br><input type="checkbox"/> 370 Other Fraud<br><input type="checkbox"/> 371 Truth in Lending B<br><input type="checkbox"/> 380 Other Personnel Property Damage<br><input type="checkbox"/> 385 Property Damage Product Liability | <input type="checkbox"/> 610 Agriculture<br><input type="checkbox"/> 620 Other Food & Drug<br><input type="checkbox"/> 625 Drug Related Seizure of Property 21 USC 881<br><input type="checkbox"/> 630 Liquor Laws<br><input type="checkbox"/> 640 R.R. & Truck<br><input type="checkbox"/> 650 Airline Regs<br><input type="checkbox"/> 660 Occupational Safety/Health<br><input type="checkbox"/> 660 Other | <input type="checkbox"/> 422 Appeal 28 USC 158<br><input type="checkbox"/> 423 Withdrawal 26 USC 157                                                                                                                                     | <input type="checkbox"/> 400 Status Reappointment<br><input type="checkbox"/> 410 Antitrust<br><input type="checkbox"/> 430 Banks and Banking<br><input type="checkbox"/> 450 Commerce/KCC Rates/etc. B<br><input type="checkbox"/> 460 Deportation<br><input type="checkbox"/> 470 Racketeer Influenced and Corrupt Organizations<br><input type="checkbox"/> 810 Selective Service<br><input type="checkbox"/> 850 Securities/Commodities/Exchange<br><input type="checkbox"/> 875 Customer Challenge 12/USC3410<br><input type="checkbox"/> 891 Agricultural Acts<br><input type="checkbox"/> 892 Economic Stabilization Act<br><input type="checkbox"/> 893 Environmental Matters<br><input type="checkbox"/> 894 Energy Allocation Act<br><input type="checkbox"/> 895 Freedom of Information Act<br><input type="checkbox"/> 900 Appeal of Fee Determination Under Equal Access to Justice<br><input type="checkbox"/> 960 Constitutionality of State Statutes<br><input type="checkbox"/> 890 Other Statutory Actions" " A or B |
+| A REAL PROPERTY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | A CIVIL RIGHTS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | B PRISONER PETITIONS                                                                                                                                                                                                                                                                                                                                                                                                                                                    | A LABOR                                                                                                                                                                                                                                                                                                                                                                                                       | B SOCIAL SECURITY                                                                                                                                                                                                                        |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
+| <input type="checkbox"/> 210 Land Condemnation<br><input type="checkbox"/> 220 Forebreakure B<br><input type="checkbox"/> 230 Rent Lease & Ejectment<br><input type="checkbox"/> 240 Torts to Land<br><input type="checkbox"/> 245 Tort Product Liability<br><input type="checkbox"/> 290 All Other Real Property                                                                                                                                                                                                                                                                                                                                                               | <input type="checkbox"/> 441 Voting<br><input type="checkbox"/> 442 Employment<br><input type="checkbox"/> 443 Housing/Accommodations<br><input type="checkbox"/> 444 Welfare<br><input type="checkbox"/> 440 Other Civil Rights                                                                                                                                                                                                                                                                                                    | <input type="checkbox"/> 510 Motions to Vacate Sentence Habeas Corpus<br><input type="checkbox"/> 530 General"<br><input type="checkbox"/> 535 Death Penalty<br><input type="checkbox"/> 540 Mandamus & Other"<br><input type="checkbox"/> 550 Civil Rights "A or B                                                                                                                                                                                                     | <input checked="" type="checkbox"/> 710 Fair Labor Standards Act<br><input type="checkbox"/> 720 Labor Management Relations B<br><input type="checkbox"/> 730 Labor Management Reporting & Disclosure Act<br><input type="checkbox"/> 740 Railway Labor Act<br><input type="checkbox"/> 750 Other Labor Litigation<br><input type="checkbox"/> 791 Employee Ret. Inc. Security Act B                          | <input type="checkbox"/> 861 HIA (1366ff)<br><input type="checkbox"/> 862 Black Lung (923)<br><input type="checkbox"/> 863 DNW/DIWW (405(g))<br><input type="checkbox"/> 864 SSID Title XVI<br><input type="checkbox"/> 865 RSI (405(g)) | <input type="checkbox"/>                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |
+
+VI. ORIGIN <sup>x</sup>1. Original O 2. Removed from Proceeding State Court O 3. Remanded from Appellate Court (Specify) O 4. Refilled O 6. Multidisbict Litigation O 7. Appeal to Diable\* Judge from O 5. Transferred from another district Magistrate Judgment
+
+VII. REQUESTED IN COMPLAINT CHECK IF THIS IS A D CLASS ACTION O UNDER F.R.C.P. 23 DEMAND \$ O Check YES only if demanded in X YES compleint JURY DEMAND: D NO
+
+VIII. RELATED CASE(S) IF ANY Jane Doe 2 v. Jeffrey Epstein Jane Doe 3 v. Jeffrey Epstein Jane Doe 4 v. Jeffrey Epstein Jane Doe 5 v. Jeffrey Epstein (See Instructions): (SEE ATTACHED) JUDGE KENNETH A. MARRA JUDGE KENNETH A. MARRA JUDGE KENNETH A MARRA JUDGE KENNETH A MARRA DOCKET NUMBER 08-CV-80119-MARRA-DOCKET NUMBER 08-CV-80232-MARRA DOCKET NUMBER 08-CV-80380-MARRA DOCKET NUMBER 08:80381 --MARRA
+
+DATE Sep~ (o IA E UNITED STATES DISTRICT COURT S/F 1-2 REV. 954 SIGNATURE OF ATTORNEY OF RECORD / Receipt No. Amount Date Paid: ^ M.410: FOR OFFICE USE ONLY:

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marker2/court-doe-6-v-epstein/EFTA02742596/EFTA02742596.md

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+## United States District Court
+
+Southern DISTRICT OF Florida
+
+## SUMMONS
+
+JANE DOE NO. 6,
+
+Plaintiff, CASE NO. 08-CV-80994-Hurley-IME
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+TO: JEFFREY EPSTEIN, individually:
+
+Palm Beach County Sheriff's Office Stockade
+
+673 Fairgrounds Road
+
+West Palm Beach, Florida
+
+YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF'S ATTORNEY,
+
+Jeffrey M. Herman, Esq.
+
+Stuart S. Mermelstein, Esq.
+
+Herman & Mermelstein, P.A.
+
+18205 Biscayne Boulevard, Suite 2218
+
+Miami, Florida 33160
+
+(305) 931-2200
+
+an answer to the complaint which is herewith served upon you, within 20 days after service of this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief demanded in the complaint. You must also file your answer with the Clerk of this Court within areasonable period of time after service.
+
+![](_page_0_Picture_24.jpeg)
+
+Steven M. Larimore Clerk of Court
+
+SUMNIONS DATE
+
+s/Vernice
+
+Deputy Clerk
+
+U.S. District Courts
+
+September 10, 2008

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marker2/court-doe-6-v-epstein/EFTA02742597/EFTA02742597.md

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+**UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF FLORIDA**
+
+**CASE NO.: 08-CV-80994-HURLEY** [REDACTED]
+
+JANE DOE NO. 6
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+\_\_\_\_\_/
+
+**NOTICE OF APPEARANCE**
+
+Burman, Critton, Luttier & Coleman, LLP file their appearance as co-counsel for Defendant, JEFFREY EPSTEIN, in the above-styled matter.
+
+**Certificate of Service**
+
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 16<sup>th</sup> day of September, 2008:
+
+Adam D. Horowitz, Esq.  
+Jeffrey Marc Herman, Esq.  
+Stuart S. Mermelstein, Esq.  
+18205 Biscayne Boulevard  
+Suite 2218  
+Miami, FL 33160  
+305-931-2200  
+Fax: 305-931-0877  
+[ahorowitz@hermanlaw.com](mailto:ahorowitz@hermanlaw.com)  
+[jherman@hermanlaw.com](mailto:jherman@hermanlaw.com)  
+[lrivera@hermanlaw.com](mailto:lrivera@hermanlaw.com)  
+*Counsel for Plaintiff Jane Doe #6*
+
+Jack Alan Goldberger  
+Atterbury Goldberger & Weiss, P.A.  
+250 Australian Avenue South  
+Suite 1400  
+West Palm Beach, FL 33401-5012  
+561-659-8300  
+Fax: 561-835-8691  
+[jagesq@bellsouth.net](mailto:jagesq@bellsouth.net)  
+*Counsel for Defendant Jeffrey Epstein*  
+  
+Michael R. Tein, Esq.  
+[REDACTED] Tein, P.L.  
+3059 Grand Avenue, Suite 340  
+Coconut Grove, FL 33133  
+305-442-1101
+
+Jane Doe No. 6 v. Epstein Page 2
+
+Fax: 305 442 6744
+
+Counsel for Defendant Jeffrey Epstein
+
+teinelewistein.com
+
+Respectfully submitted,
+
+BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
+
+515 N. Flagler Drive, Suite 400
+
+West Palm Beach, FI.,y33401
+
+(561) 842-2820
+
+By:
+
+Robert Critton, Jr.
+
+Florid ar #224162
+
+Michael J. Pike
+
+Florida Bar #617296
+
+Co-counsel for Defendant Jeffrey Epstein
+
+rcritabc1claw.com
+
+mpike@bciclaw.com

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marker2/court-doe-6-v-epstein/EFTA02742599/EFTA02742599.md

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+JEFFREY EPSTEIN
+
+FLORIDA  
+Court  
+Case # US DISTRICT  
+FL/EPSTEIN  
+1
+
+SERVE  
+ADOR  
+ATTD  
+VEEY
+
+PALM BEACH COUNTY SHERIFF'S OFFICE  
+STOCKADE  
+673 FAIRGROUNDS RD  
+WEST PALM BEACH, FL  
+HERMAN & MERMELSTEIN PA  
+18205 BISCAYNE BL STE 2218  
+MIAMI FL 33160
+
+T Y P E  
+O F  
+W R I T
+
+SUMMONS & COPY & COPY OF COMPLAINT  
+(CASE NO. 08-CV-80994)
+
+PLAINTIFF: JANE DOE, NO. 6
+
+COST  
+SERVICE \$ 20.00  
+CHECK 16077
+
+DEFENDANT: JEFFREY EPSTEIN
+
+PD  
+AT: 12:05:19 pm
+
+Received this writ the 22nd Day of September A.D. 20 08 and served the same on the within named person at 1221 AMPM on the 27 day of Sept A.D. 2001 in Palm Beach County Florida, a true copy of this Writ, endorsed thereon by me, \* with a copy of the Complaint, Petition, or other Pleadings (\*not applicable to service of Subpoena.)
+
+ INDIVIDUAL SERVICE
+
+ SERVICE TO PERSON IN REPRESENTATIVE CAPACITY / designated recipient of process/records custodian/parent or guardian of a minor, to wit:  
+\_\_\_\_\_ as \_\_\_\_\_ (name) (capacity)
+
+ SUBSTITUTE SERVICE at usual place of abode with any person residing therein who is 15 years of age or older and informing the person of their contents, to wit: \_\_\_\_\_ as \_\_\_\_\_ (name) (relationship)
+
+ CORPORATE SERVICE  
+To \_\_\_\_\_ holding corporate office of \_\_\_\_\_  
+To \_\_\_\_\_ as registered agent of said corporation.  
+To \_\_\_\_\_ as employee of said corporation, due to failure to comply with F.S. 48.091. Attempts to serve officer or registered agent: date \_\_\_\_\_ time \_\_\_\_\_, date \_\_\_\_\_ time \_\_\_\_\_
+
+ SOLE PROPRIETORSHIP (D. / A)  
+To \_\_\_\_\_ as owner.  
+To \_\_\_\_\_ as manager. Attempts to serve owner at place of business: date \_\_\_\_\_ time \_\_\_\_\_, date \_\_\_\_\_ time \_\_\_\_\_
+
+ PARTNERSHIP  
+To \_\_\_\_\_ as partner.  
+To \_\_\_\_\_ as designated employee or agent for service.
+
+ POSTING by attaching a copy to a conspicuous place on the property described by the complaint or summons. If applicable:  
+Attempts to serve resident/tenant in action for possession: date \_\_\_\_\_ time \_\_\_\_\_, date \_\_\_\_\_ time \_\_\_\_\_  
+Posted per map, property description: \_\_\_\_\_
+
+ NON-SERVICE: Person notified \_\_\_\_\_, date \_\_\_\_\_ time \_\_\_\_\_. (See remarks below.)
+
+ SUPPLEMENTAL INFORMATION \_\_\_\_\_
+
+\_\_\_\_\_  
+\_\_\_\_\_  
+\_\_\_\_\_  
+\_\_\_\_\_  
+\_\_\_\_\_  
+\_\_\_\_\_  
+\_\_\_\_\_  
+\_\_\_\_\_
+
+By \_\_\_\_\_ Deputy Sheriff 274 Ric L. Bradshaw  
+Sheriff of Palm Beach County, Florida
+
+Note: Only that service indicated by the X is applicable to this return - all other portions should not be considered.

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marker2/court-doe-6-v-epstein/EFTA02742600/EFTA02742600.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 08-80994--CIV-HURLEY
+
+A.N E DOE NO. 6, plaintiff,
+
+JEFFREY EPSTEIN, defendant.
+
+## ORDER OF TRANSFER
+
+THIS CAUSE is before the court upon its own motion. pursuant to Local Rule 3.9(C). It is herewith ORDERED and ADJUDGED that this case is transferred to the calendar of The Honorable Kenneth A. Marra.
+
+DONE and SIGNED in )1 October. 2008. at West Palm Beach, Florida, this A lc-
+
+(Deasj t i p Daniel T. K. ur y United States Disttict Judge
+
+Alter review of the court file. the undersigned hereby accepts the transfer of
+
+It is therefore ORDERED AND ADJUDGED that all pleadings shall herea tier bear Case No. 08-80994-CIV- MARRA, indicating the Judge to whose calendar the case is now assigned.
+
+DONE and SIGNED at Fort Lauderdale, Florida, this at lejlay of October, 2008.
+
+> F Kenneth A. Marra United States District Judge
+
+Copy furnished to:
+
+lion. Daniel T.K. Hurley 1.ticy Lara, Case Assignment Administrator all counsel

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marker2/court-doe-6-v-epstein/EFTA02742602/EFTA02742602.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+Case No.08-80994-CIV-Marra
+
+JANE DOE No. 6,
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## CERTIFICATION AND ORDER OF TRANSFER TO MAGISTRATE JUDGE
+
+This matter comes before the undersigned on an Order of Transfer to United States District Court Judge Kenneth A. Marra signed by United States District Court Judge Daniel T. I. Hurley. (DE 5). The undersigned certifies that the above-styled case presently has no referred, fully briefed pending motions and is therefore ready to be transferred to Judge Marra's paired Magistrate Judge.
+
+The Clerk of Court shall hereby transfer the Magistrate Judge assignment for the instant case to United States Magistrate Judge Linnea R.
+
+DONE and ORDERED in this 8 day of October, 2008, at West Palm Beach in the Southern District of Florida.
+
+JAMES M. UNITED STATES MAGISTRATE JUDGE
+
+Copies to:
+
+United States District Judge Kenneth A. Marra United States Magistrate Judge Linnea R. Counsel of Record

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marker2/court-doe-6-v-epstein/EFTA02742603/EFTA02742603.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 08-80994-CIV-MARRA
+
+JANE DOE NO. 6,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendants.
+
+## ORDER REQUIRING COUNSEL TO CONFER, FILE JOINT SCHEDULING REPORT AND FILE JOINT DISCOVERY REPORT
+
+THIS ORDER has been entered upon the filing of the complaint. Plaintiff's counsel is hereby ORDERED to forward to all defendants, upon receipt of either an answer or a motion pursuant to Fed. R. Civ. P. 12(b), a copy of this order.
+
+It is further ORDERED:
+
+- I. Every motion when filed shall be accompanied by a proposed order, except that motions to dismiss and motions for summary judgment need not be accompanied by a proposed order.
+- 2. Pretrial discovery in this case shall be conducted in accord with Local Rule 16.1 and Rule 26 of the Federal Rules of Civil Procedure.
+- 3. Pursuant to Rule 26(f) of the Federal Rules of Civil Procedure, unless this action is excluded under Rule 26(a)(I)(E), the parties must confer within twenty-one (21) days after the last responding party either files an answer or a motion pursuant to Fed. R. Civ. P. 12(b), whichever is earlier, to consider the nature and basis of their claims and defenses and the possibilities for a prompt settlement or resolution of the case, to make or arrange for the disclosures required by Rule 26(a)( I), and to develop a proposed discovery plan that indicates the
+
+parties' views and proposals concerning the matters listed in Rule 26(t).
+
+4. The parties are jointly responsible for submitting a written report of this conference outlining the proposed discovery plan within 14 days after the conference.
+
+5. Counsel for the parties shall hold a scheduling conference either at the same time as the discovery conference described in Rule 26(f) or within fourteen (14) calendar days thereafter. See Local Rule 16.1(B).
+
+6. Within fourteen (14) days of the scheduling conference, counsel shall file a joint scheduling report pursuant to Local Rule 16.1(B)(2). This report shall indicate the proposed month and year for the trial plus the estimated number of trial days required, as well as an indication of whether the trial is to be a jury trial or bench trial.
+
+7. The parties may submit a single report combining the discovery plan report and the scheduling conference report.
+
+8. Failure of counsel or unrepresented parties to file a discovery plan report or joint scheduling report may result in dismissal, default, and the imposition of other sanctions including attorney's fees and costs.
+
+DONE AND SIGNED in at West Palm Beach, Palm Beach County, Florida, this 8th day of October, 2008.
+
+> KENNETH A. MARRA United States District Judge
+
+Copies furnished to:
+
+All counsel

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marker2/court-doe-6-v-epstein/EFTA02742605/EFTA02742605.md

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+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FL CASE NO.: 08-CV-80994-Marra/iiii
+
+JANE DOE NO. 6
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+#### DEFENDANT'S, EPSTEIN, MOTION TO DISMISS & FOR MORE DEFINITE STATEMENT DIRECTED TO PLAINTIFF JANE DOE NO.6'S COMPLAINT
+
+Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves to dismiss and for more definite statement of Plaintiff JANE DOE NO. 6's Complaint. Rules 12(b)(6) and 12(e), Fed.R.Civ.P. (2008). In support of his motion, Defendant states:
+
+## Introduction
+
+Defendant previously filed motions to dismiss and for more definite statement directed to the Amended Complaints filed against Defendant in this Court in JANE DOE NO. 2 (Case No. 08-CV-80119-Marra), JANE DOE NO. 3 (Case No. 08-CV-80232-Marra, ), JANE DOE NO. 4 (Case No. 08-CV-80380-Marra ), and JANE DOE NO. 5 (Case No. 08-CV-80381-Marra). Defendant is also filing similar motions in the actions filed by JANE DOE NO. 6 (Case No. 08-CV-80994- Marra/Johnsn), and JANE DOE NO. 7 (Case No. 08-CV-80993-Hurley. ). The motions are directed to the Counts for Count I - "Sexual Assault and Battery," andCount III - "Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422" in each
+
+of the respective complaints. However, there are distinctions in the six motions filed based on the complaint allegations. For example, in the previously filed four motions (Jane Doe Nos. 2 through 5), Defendant challenged the Plaintiffs' allegations as to assault in all four actions, and challenged the battery allegations in JANE DOE NOS. 2 and 3, but not in JANE DOE NOS. 4 and 5. Defendant moved to dismiss the §2422 count in all four of the JANE DOE Nos. 2 through 5 actions. As to JANE DOE NO. 6, Defendant challenges the battery allegations, but does not as to JANE DOE NO. 7 as the underlying facts of the requisite "touching" are alleged. Defendant challenges the 18 U.S.C. §2422 count in both JANE DOE NO. 6 and NO. 7.
+
+## Motion
+
+1. Counts I and III of JANE DOE NO. 6's Complaint are required to be dismissed for failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has failed to allege sufficient factual allegations in the Counts and instead alleges labels and conclusions, and an attempted formulaic recitation of the elements in each Count.
+
+2. In the alternative or in conjunction with, Defendant seeks more definite statement of Count I and III. In Count I, the Plaintiff is required to more definitely allege what was done to her; what EPSTEIN said and did, if anything, to create fear and apprehension in Plaintiff; what was the intentional offensive or harmful contact in pleading the elements of assault and battery. In Count III, Plaintiff is required to more definitely state the underlying factual allegations to support her claim as set forth in the statute, 18 U.S.C. §2422(b) and §2455. Rule 12(e). See discussion of law below herein.
+
+WHEREFORE, Defendant respectfully requests that this Court dismiss Counts I and III, and require Plaintiff to more definitely plead the underlying elements of her claims.
+
+#### Supporting Memorandum of Law Standard on Rule 12(b)(6) Motion To Dismiss
+
+As established by the Supreme Court in Bell Atlantic Corp. V. Twombly, 127 S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead "enough facts to state a claim to relief that is plausible on its face." Id, at 1974. Although the complaint need not provide detailed factual allegations, the basis for relief in the complaint must state "more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do." Id, at 1965. Further, "[f]actual allegations must be enough to raise a right to relief above the speculative level ... on the assumption that all the allegations in the complaint are true (even if doubtful in fact)." Id. On a motion to dismiss, the well pleaded allegations of plaintiff's complaint are taken as true and construed in the light most favorable to the plaintiff. M.T.V. v. DeKalb County Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006).
+
+Significantly, the Supreme Court in Bell Atlantic Corp. V. Twombly abrogated the often cited observation that "a complaint should not be dismissed for failure to state a claim unless it appears beyond doubt that the plaintiff can prove not set of facts in support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme Court rejected the notion that "a wholly conclusory statement of claim [can] survive a motion to dismiss whenever the pleadings le[ave] open the possibility that a plaintiff might later establish some 'set of [undisclosed] facts' to support recovery." Id. As explained by the Supreme Court in Bell Atlantic Corp. supra at 1664-65:
+
+While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations ibid: Sanivan v. American Bd. of Psychiatry and Neurology, Inc. 40 F.3d 247, 251 (C.A.7 1994), a plaintiff's obligation to provide the "grounds" of his "entitle[ment] to relief" requires
+
+> more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do, see Papasan v. Allain, 478 U.S. 265, 286, 106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are not bound to accept as true a legal conclusion couched as a factual allegation"). Factual allegations mu§Lbgjnougbja raise a right to relief above the speculative level, see 5 C. & A. , Fed cti Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter & ) ("ripe pleading must contain something more ... than ... a statement of facts that merely creates a suspicion (of] a legally cognizable right of action"), on the assumption that all the allegations in the complaint are true (even if doubtful in fact), see, e.g., Swierkiewicz v. Sorema Nisai ug U.S. 506, 508, n. 1, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002); Neitzke v.MM 490 U.S. 319, 327, 109 S.Ct. 1827, 104 L.Ed.2d 338 (1989) (" Rule 12(b)(6) does not countenance ... dismissals bas judge's disbelief of a complaint's factual allegations"). Scheuer v. 416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it appears "that a recovery is very remote and unlikely").
+
+Pursuant to Rule 12(e), a party may move for more definite statement of a pleading to which a responsive pleading is allowed where the pleading "is so vague or ambiguous that the party cannot reasonably frame a response." The motion is required to point out the defects and the desired details. Id.
+
+#### Count I — "Sexual Assault and Battery" is subject to dismissal as Plaintiff has failed to 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. v. 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 single concept, "assault and battery are separate and distinct legal concepts, assault being the beginning of an act which, if consummated, constitutes battery." 3A FIa.Jur.2d Assault §1. An assault and battery are intentional acts. See generally, Spivey v. Battaglia 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co. v. PCR, Inc., 889 So.2d 779 (Fla. 2004).
+
+An "assault" is an intentional, unlawful offer of corporal injury to another by force, or exertion of force directed toward another under such circumstances as to create a reasonable fear of imminent peril. See Lay v. Kremer, 411 So.2d 1347 (Fla. 1st DCA 1982). It must be premised upon an affirmative act - a threat to use force, or the actual exertion of force. See 3A Fla.Jur.2d Assault §1("The essential element of the tort of assault is the violence offered, and not actual physical contact.").
+
+Tort of "battery" consists of the infliction of a harmful or offensive contact upon another with the intent to cause such contact or the apprehension that such contact is imminent. Quilling v. Price, 894 So.2d 1061 (Fla. 5th DCA 2005); v. Atlantic Federal Savings & Loan 454 So.2d 52 (Fla. 4th DCA 1984)("a battery consists of the intentional infliction of a harmful or offensive contact upon the person of another"). See 3A FIa.Jur.2d Assault §1.
+
+With the standard of pleading established in Twomblv, supra, in the context of the elements for assault and battery, Plaintiff has failed to state a claim upon which relief can be granted. Rule 12(b)(6). As to the elements of assault, here are no factual allegations as to what was said or done to Plaintiff such that it constituted an "intentional, unlawful offer of corporal injury to another by force, or exertion of force directed toward another under such circumstances as to create a reasonable fear of imminent peril." See ¶13 of Comp. The same is true for the claim of battery. Plaintiff makes the general allegation that "he (Defendant) sexually assaulted Jane." The other allegations in ¶13 pertain to what Plaintiff allegedly did. Under applicable law, Plaintiff is required to give more than labels and conclusions, and a formulaic recitation of the elements of a cause of action. Twomblv supra. Plaintiff is required to allege the facts
+
+of what was done to her; what EPSTEIN said and did, if anything, to create fear and apprehension in Plaintiff; what was the intentional offensive or harmful contact?
+
+As noted in the introduction and as this Court is well aware, there is more than one action brought against this Defendant attempting to allege similar sounding claims. The details as to a particular claim asserted by a particular Plaintiff are important to give this Defendant fair notice of Plaintiffs claim so he may properly respond. Accordingly, under applicable law, Plaintiff has failed to state a claim for sexual assault and battery.
+
+In the alternative to dismissing Count I, Defendant requests that Plaintiff be required to give more definite statement as to what was done to her; what EPSTEIN said and did, if anything, to create fear and apprehension in Plaintiff; what was the intentional offensive or harmful contact in pleading the elements of assault and battery. Rule 12(e).
+
+Count III — "Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. 62422" - is subject to dismissal as Plaintiff has failed to state a claim upon which relief can be wanted. Rule 12(b)(6).
+
+Count III of Plaintiffs Complaint attempts to assert a claim for "Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422." In her prayer for relief, Plaintiff demands judgment against EPSTEIN "for all damages available under 18 U.S.C. §2255(a), ." Count III is required to be dismissed as Plaintiff has failed to state a claim under the statutes for which relief can be granted.
+
+The applicable version of these statutory provisions, (pre-2006 Amendments, as the Amended Complaint alleges a time period of "in or about 2004," ¶9), provides:
+
+## CHAPTER 117-TRANSPORTATION FOR ILLEGAL SEXUAL ACTIVITY AND RELATED CRIMES § 2422. Coercion and enticement
+
+> (a) Whoever knowingly persuades, induces, entices, or coerces any individual to travel in interstate or foreign commerce, or in any Territory or Possession of the United States, to engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall be fined under this title or imprisoned not more than 20 years, or both.
+
+> (b) Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall be fined under this title and imprisoned not less than 5 years and not more than 30 years.
+
+## CHAPTER 110-SEXUAL EXPLOITATION AND OTHER ABUSE OF CHILDREN
+
+# § 2255. Civil remedy for personal injuries
+
+(a) Any minor who is a victim of a violation of section 2241(c), 2242 2243 2251, 2251A, 2252, 2252A, 2260, 2421 2422, or 2423 of this title and who suffers personal injury as a result of such violation may sue in any appropriate United States District Court and shall recover the actual damages such minor sustains and the cost of the suit, including a reasonable attorney's fee. Any minor as described in the preceding sentence shall be deemed to have sustained damages of no less than \$50,000 in value.
+
+(b) Any action commenced under this section shall be barred unless the complaint is filed within six years after the right of action first accrues or in the case of a person under a legal disability, not later than three years after the disability.
+
+Relevant to Plaintiffs complaint, 18 U.S.C. 2255(a) creates a civil remedy for "a minor who is a victim of a violation of section ... 2422 ... of this title and who suffers personal injury as a result of such violation ... ." Plaintiff has failed to plead any factual allegations whatsoever pertaining to violations of 18 U.S.C. 2422. Rather, Plaintiff has alleged conclusory allegations simply attempting to track parts of the statutory language in the statute without underlying factual allegations pertaining to the Plaintiff and any conduct by Defendant. See ¶28 of Comp. Plaintiffs allegations, (or lack of factual
+
+allegations), are precisely what the standard set forth by the Supreme Court in Bell Atlantic Corp. prohibits — Plaintiffs complaint alleges only "labels and conclusions, and a (partial) formulaic recitation of the elements."
+
+First, the Complaint fails to designate whether Plaintiff is relying on §2422(a) or §2422(b). Second, although the complaint does contain a partial tracking of the language in 18 U.S.C. §2422(b), it contains absolutely no factual allegations conceming the requisite "using the mail or any facility or means of interstate or foreign commerce" by Plaintiff to state a cause of action based on a violation of 18 U.S.C. 2422(b). As well, there are no underlying factual allegations involving this Plaintiff as to the requisite elements that a defendant knowingly persuaded, induced, enticed, or coerced any individual (Plaintiff in this case) who has not attained the age of 18 years, to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, or attempted to do so. See 18 U.S.C. 2422(b); i.e. with what criminal offense could Plaintiff and Defendant have been charged. Again, a Plaintiff cannot simply track the language of a statute without some underlying factual allegations to state a claim upon which relief can be granted. Accordingly, Count III is required to be dismissed.
+
+In the alternative, Plaintiff should be required to more definitely state the underlying factual allegations to support her claim as set forth in the statute, 18 U.S.C. §2422(b) and §2455.
+
+## Conclusion
+
+As discussed above herein, under the pleading standard established in Twombly supra, and law concerning the elements of Count I and III, Plaintiff has failed to state claims upon which relief can be granted. Rule 12(b)(6). Plaintiffs complaint lacks
+
+underlying factual allegations and, thus, in the alternative to dismissal or in conjunction with, Plaintiff is required to more definitely state the requisite factual allegations.
+
+**Certificate of Service**
+
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 14<sup>th</sup> day of October, 2008:
+
+Adam D. Horowitz, Esq.  
+Jeffrey Marc Herman, Esq.  
+Stuart S. Mermelstein, Esq.  
+18205 Biscayne Boulevard  
+Suite 2218  
+Miami, FL 33160  
+305-931-2200  
+Fax: 305-931-0877  
+[ahorowitz@hermanlaw.com](mailto:ahorowitz@hermanlaw.com)  
+[jherman@hermanlaw.com](mailto:jherman@hermanlaw.com)  
+[lrivera@hermanlaw.com](mailto:lrivera@hermanlaw.com)  
+*Counsel for Plaintiff Jane Doe #2*
+
+Respectfully submitted,
+
+![]()

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marker2/court-doe-6-v-epstein/EFTA02742614/EFTA02742614.md

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+
+## U.S. Department of Justice
+
+United States Attorney Southern District of Florida
+
+500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 (561)820-8711 Facsimile: (561) 820-8777
+
+July 10, 2008
+
+## VIA FACSIMILE AND U.S. MAIL
+
+Jeffrey Herman, Esq. Herman & Mermelstein, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160
+
+> Re: Jeffrey Epstein NOTIFICATION OF IDENTIFIED VICTIM
+
+Dear Mr. Herman:
+
+By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client,
+
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered <sup>a</sup>plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454A3OOCMB and 2008-cf-<sup>00938</sup>IAX3O2v1B) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court.
+
+In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions.
+
+One such condition to which Epstein has agreed is the following:
+
+"Any person, who while a minor, was avictim of aviolation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same
+
+JEFFREY HERMAN, ESQ.
+
+NOTIFICATION OF IDENTIFIED VICTIM [REDACTED]
+
+JULY 10, 2008
+
+PAGE 2 OF 2
+
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less."
+
+Through this letter, this Office hereby provides Notice that your client, [REDACTED] is an individual whom the United States was prepared to name as a victim of an enumerated offense.
+
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401.
+
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide written documentation of that denial to the undersigned.
+
+Please thank your client for all of her assistance during the course of this investigation and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for the health and well-being of [REDACTED]
+
+R. ALEXANDER ACOSTA  
+UNITED STATES ATTORNEY
+
+By:
+
+![]()A. [REDACTED] VILLAFAÑA  
+ASSISTANT U.S. ATTORNEY
+
+cc: Jack Goldberger, Esq.

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marker2/court-doe-6-v-epstein/EFTA02742616/EFTA02742616.md

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+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA I
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARRA,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 5, CASE NO.: 08-CV-8038l-MARRA
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 6, CASE NO.: 08- 80994-CIV-MARRAMM
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 7, CASE NO.: 08- 80993-CIV-MARRa
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+# PLAINTIFFS' MEMORANDUM OF LAW IN OPPOSITION TO MOTIONS TO DISMISS
+
+Plaintiffs, Jane Does 2-7, by and through undersigned counsel, file this Memorandum of Law in Opposition to Motions to Dismiss, pursuant to S.D.Fla.L.R. 7.1(C), as follows:
+
+#### I. Introduction and Stinunars
+
+Defendant's Motions to Dismiss and for More Definite Statement filed in each of the abovecaptioned cases pursuant to Fed.R.Civ.P. 12(6)(6) and 12(e) essentially concede that Plaintiffs have alleged the elements of the claims asserted in Counts I and III of each pleading, but contend that more factual allegations are necessary for these claims. The pleadings at issue contain a short and plain statement of the claims showing that the Plaintiffs are entitled to relief in accordance with Fed.R.Civ.P. 8(a)(2). The specific facts sought by Defendant may properly be the subject of discovery, but are not necessary for purposes of pleading. Accordingly, Defendant's Motions are without merit and should be denied in their entirety.
+
+### II. Facts Plead
+
+The pleadings in these six cases are all similarly structured and assert the same claims. In the section entitled "Factual Allegations" each describes the plan and scheme of Defendant Epstein to recruit underage girls to his Palm Beach mansion for "massages". (Jane Doe No. 2 Amd. Compl. 10-11; Jane Doe No. 3 Amd. Comp.1 10-11; Jane Doe No. 4 Amd. Comp/.111-12; Jane Doe No. 5 Amd. Compl. 1 10-11; Jane Doe No. 6 Amd. Compl.111-12; Jane Doe No. 7 Amd. Comp1.1 11-12). The pleading then alleges that, consistent with this scheme, the Plaintiff was lured to Epstein's Palm Beach mansion to give a massage for monetary compensation. (Jane Doe No. 2 Amd. Compl. 1 12; (Jane Doe No. 3 Amd. Compl. 1 12; Jane Doe No. 4 Amd. Compl. 1 13; Jane Doe No. 5 Amd. Comp'. 1 12; Jane Doe No. 6 Amd. Comp!. 1 13; Jane Doe No. 7 Amd. Compl. 1 13). The Plaintiff was directed up a flight of stairs to a room where Epstein instructed the Plaintiff to remove her clothes and give him a massage. Epstein then masturbated and sexually assaulted the Plaintiff during this massage. (Jane Doe No. 2 Amd. Compl. 112; Jane Doe No. 3 Amd. Compl. 112; Jane Doe No. 4 Amd. Comp!. 113; Jane Doe No. 5 Amd. Compl. 112; Jane Doe No. 6 Amd. Compl. 113; Jane Doe No. 7 Amd. Compl. 113).
+
+Count I of the pleading in each case alleges a claim of sexual assault and battery. Count II alleges a claim for intentional infliction of emotional distress, which Defendant does not seek to dismiss in his Motions before the Court. Count HI alleges a claim for coercion and enticement to sexual activity in violation of 18 U.S.C. §2422. Defendant's Motions to Dismiss seek dismissal of Counts I and III for failure to state a claim under Fed.R.Civ.P. 12(bX6), or alternatively move for a more definite statement under Fed.R.Civ.P. 12(e) on these Counts. As discussed below, Plaintiffs' claims are sufficiently plead, and Defendant's Motions should be denied in their entirety.
+
+# III. Argument
+
+## A. THE STANDARD UNDER FED.R.CIV.P. 12(b)(6) DOES NOT SUPPORT DISMISSAL
+
+The gravamen of Defendant's Motion is that Plaintiffs' have not pled sufficient facts in support of their claims in Counts I and III. According to Defendant, the pleadings in this case do not satisfy "the standard of pleading" established in Bell Atlantic Corp. v. Twombly 127 S.Ct. 1955 (2007). In making this argument, Defendant would extend Twomblv well beyond its intended scope.
+
+Twombly was an antitrust conspiracy case, in which the Court abrogated the longstanding pronouncement first made in Con 355 U.S. 41 (1957), that a complaint should not be dismissed under Fed.R.Civ.P. 12(bX6) "unless it appears beyond doubt that the plaintiff can prove no set of facts in support of his claim that would entitle him to relief." 127 S.Ct. at 1969. The Court noted that it did "not require heightened fact pleading of specifics, but only enough facts to state a claim to relief that is plausible on its face." Id. at 1974 (emphasis supplied). The antitrust conspiracy claim before the Court was dismissed "[b]t:cause the plaintiffs here have not nudged their claims across the line from conceivable to plausible...." Id.
+
+Since Twombly, courts and commentators have grappled with the case's meaning and scope. Courts within the Eleventh Circuit have held that Twombly did not alter the standard for dismissal under Rule 12(bX6) in the typical case. See, e.g.,CBT Flint Partners, LLC v. Goodmail Systems, Inc 529 F.Supp. 2d 1376, 1379 (N.D. Ga. 2007); Coughlin v. Wal-Mart Stores East LP 2008 WL 2704381 (M.D. Fla. 2008); Capaz v. Whitaker, Weinstraub & Grizzard. M.D.S. P.A., 2007 WL 1655473 (M.D. Fla. 2007). In CBT Flint Partners the Court warned against reading the decision in Trombly too broadly:
+
+In my view, Trombly did not radically alter the elementary rules of civil procedure that have governed litigation in the federal courts for the past seventy years. The Court's forced retirement of Conley v. "no set of facts" language does not change the fundamental command of Rule 8 as to what a valid complaint must look like. Indeed, the Court made clear that it was not imposing a heightened pleading standard. As a general matter, I am loath to assume that the Supreme Court circumvented the normal channels for amending the Federal Rules. The Court's "new standard" was merely a specific way to articulate a solution to what it perceived to be a specific pleading problem, in a specific area of law that inflicted a high cost upon antitrust defendants. It was not a broad based new license for federal courts to ramp up pleading requirements.
+
+529 F.Supp. 2d at 1379 (citations omitted).
+
+The standard for pleading in the federal courts remains controlled by Fed.R.Civ.P. 8(a)(2), which "only requires a short and plain statement of the claim showing that the pleader is entitled to relief in order to give the defendant fair notice of what the claim is and the grounds upon which it rests." Capaz, 2007 WL 1655473 at \*1. While the scope of Twombly may not be entirely clear. It plainly cannot be read to turn pleadings into a discovery device, as Defendant advocates here in seeking dismissal for failure to plead detailed factual allegations.
+
+In Iqbal v. Hasty 490 F.3d 143 (2d Cir. 2007), the Court reviewed and analyzed in depth Twombly's "conflicting signals", and ultimately held that the Supreme Court did not impose "a universal standard of heightened fact pleading," but rather a "flexible 'plausibility standard' ". Id. at 157-158. This standard "obliges a pleader to amplify a claim with some factual allegations in those contexts where such amplification is needed to render the claim plausible." Id. (emphasis original). See also Sales v. All Florida Dialysis Services, Inc., 2007 WL 3231723 \*2 n.2 (S.D. Fla. 2007) (noting that Twomblv was inapplicable because the defendants did not raise the type of pleading deficiencies confronted in Twombly - lack of specific time, place or person involved in the alleged antitrust conspiracies).
+
+The instant allegations and claims cannot be compared to the speculative antitrust conspiracy alleged in Twombly. See 127 S.Ct. at 1965. There should be no doubt that the Plaintiffs' claims are plausible. Accordingly Twombley is not authority for dismissal of the pleadings in these cases.
+
+## II. THE ELEMENTS OF COUNT I FOR SEXUAL ASSAULT AND BATTERY ARE SUFFICIENTLY ALLEGED
+
+In each case, the claim in Count I is labeled "Sexual Assault and Battery." Assault and battery are closely related common law intentional torts that are often alleged together. See Herzfeld v. Herzfeld 781 So.2d 1070 (Fla.2001) (noting that plaintiff alleged intentional ton of "assault and battery" based on allegations of sexual abuse); v. Atlantic Federal Savings & Loan, 454 So.2d 52 (Fla. 4th DCA 1984) (holding that a cause of action for assault and battery cannot be based entirely on an omission). A common law assault occurs when a person "acts intending to cause a harmful or offensive contact with the person of the other, or an imminent apprehension of such contact, and the other is thereby put in such imminent apprehension". Restatement (Second) of Tons, Assault §21 (1965). "A battery consists of the infliction of a harmful or offensive contact upon another with the intent to cause such contact or the apprehension that such contact is imminent". See Paul v. Holbrook, 696 So.2d 1371 (Fla. 5th DCA 1997). See also Scelta v. Delicatessen Support Services. Inc. 57 F.Supp. 2d 1327, 1358-59 (M.D. Ha. 1999) (allegation that defendant attempted to put his hands down plaintiff's dress, and that there was an actual and intentional touching, sufficient to state a claim for battery); Hogan v. Tavzel 660 So.2d 350 (Ha. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease).
+
+Defendant does not contend that the Plaintiffs failed to allege these elements of the common law tons of assault and battery in Count I of their pleadings. Rather, Defendant argues that the pleadings fail to allege the specific facts of "what was said or done to Plaintiff". Defendant thus misconstrues Twombly. All of the Plaintiffs allege essentially the same plan and scheme of Defendant to lure underage girls to his Palm Beach mansion for "massages", leading to Defendant engaging in sexual activities with the Plaintiffs. The specific facts concerning what was said and done prior to and during the course of these "massages" is the proper subject of discovery, not the pleadings. Plaintiffs satisfy the pleading requirements of Fed.R.Civ.P. 8(a)(2), and Twombly does not require more specific fact pleading in these cases.
+
+## III. PLAINTIFFS SUFFICIENTLY ALLEGE A CLAIM IN COUNT III FOR VIOLATION OF 18 U.S.C. §2422
+
+The pleadings in Count III closely track the language of 18 U.S.C. §2422, and thus set forth the elements of a violation of this Statute, as follows:
+
+(i) Allegation in Complaint. Epstein used a facility or means of interstate commerce to knowingly persuade, induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or sexual activity for which any person can be charged with a criminal offense; and
+
+(ii) 18 U.S.C. §2422(b). Whoever, using the mail or any facility or means of interstate or foreign commerce, ... knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, or attempts to do so...
+
+18 U.S.C. §2455(b); Jane Doe 2 Amd. Compl. 1 29; Jane Doe 3 Amd. Comp1.1 29; Jane Doe 4 Amd. Comp1.1 30; Jane Doe 5 Amd. Compl.1 29; Jane Doe 6 Amd. Compl. 1 28; Jane Doe 7 Amd. Compl. 1 29. Defendant does not appear to contend that Plaintiffs have failed to allege the elements of a violation of 18 U.S.C. §2422 in Count III, but instead argues that further factual allegations are necessary. As with Count I, such specific facts are the proper subject of discovery, and need not be set forth in the pleadings under Rule 8(aX2). There is no issue of plausibility concerning the Plaintiffs' claims under 18 U.S.C. §2422. Indeed, the Plaintiffs in these cases were notified by the U.S. Attorney's office that the Defendant has agreed that each Plaintiff has the same right to proceed on her federal statutory claim "as she would have had if Mr. Epstein had been tried federally and convicted of an enumerated offense." ( July 10, 2008 letter from A. Villafafia, Assistant U.S. Attorney, attached hereto as Exhibit "A").
+
+Defendant also attempts to make much of a typographical error that appears in Count III in the "Wherefore" clause demanding a judgment for damages. There, the pleading inadvertently makes reference to 28 U.S.C. §2255(a) instead of 18 U.S.C. §2255(a). As is clear from the Defendants' Motions, Defendant is well aware that this is a typographical error and that the intent is to reference 18 U.S.C. §2255. In any event, this reference concerns the Plaintiffs' damages, not the elements of Plaintiff's claim set forth in the paragraphs above it.' Count III nonetheless satisfies Fed.R.Civ.P. 8(a)(3), as the "Wherefore" clause states that Plaintiff seeks actual and compensatory damages, costs of suit, attorneys' fees and such other and further relief as this Court deems just and proper. If deemed necessary, the typographical error in the "Wherefore" clause of Count III can be corrected by interlineation. It does not warrant a dismissal and repleading.
+
+## IV. THERE IS NO BASIS FOR DEFENDANT'S MOTION FOR MORE DEFINITE STATEMENT
+
+A motion for more definite statement under Fed.R.Civ.P. 12(e) may only be granted "if a pleading is so vague or ambiguous that a party cannot reasonably be required to frame a responsive pleading." v. Two Brothers Farm. LLC, 2008 WL 4405409 \*I (S.D. Fla. 2008) (quoting Betancourt v. Marine Cargo Mgmt., 930 F. Supp. 606, 608 (S.D. Fla. 1996)). Federal courts disfavor motions for more definite statement. Home Mgmt. Solutions. Inc. v. Prescient. Inc. 2007 WL 2412834 (S.D. Fla. 2007). Most importantly, "Defendants may not use a motion for more definite statement as a means of discovery regarding those claims." 2008 WL 4405409 at \*1. Yet that is exactly how Defendant Epstein uses his Motions for More Definite Statement. He
+
+<sup>&#</sup>x27; As a result, this reference in error to 28 U.S.C. 2255(a) is not set forth in a paragraph to which Defendant would be expected to frame an answer.
+
+seeks by these Motions specific facts which are the proper subject of discovery, not pleadings. Accordingly, Defendants Motions for More Definite Statement should be denied.
+
+# V. Conclusion
+
+For the foregoing reasons, Plaintiffs respectfully request that Defendant's Motion to Dismiss be denied in their entirety.
+
+Dated: October 31, 2008. Respectfully submitted,
+
+By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) iherman@hermanlaw.com Stuart S. Mermelstein (FL Bar No. 947245) ssm@herrnanlaw.com Adam D. Horowitz (FL Bar No. 376980) ahorowitz@hermanlaw.com HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs Jane Doe 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877
+
+#### CERTIFICATE OF SERVICE
+
+I hereby certify that on October 31, 2008, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing.
+
+s/ Jeffrey M. Herman
+
+#### SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida
+
+Jack Alan Goldberger, Esq. jgoldberger@agwpa.com
+
+Michael R. Tein, Esq. tein@lewistein.com
+
+Robert D. Critton, Esq. rcritton@bcIclaw.com
+
+Michael Pike, Esq. mpike@bciclaw.com
+
+s/ Jeffrey M. Herman

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marker2/court-doe-6-v-epstein/EFTA02742627/EFTA02742627.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CV-80994-MARRa
+
+JANE DOE NO. 6,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION TO DISMISS & FOR MORE DEFINITE STATEMENT
+
+Defendant, JEFFERY EPSTEIN, (EPSTEIN), by and through his undersigned attorneys, files his reply to Plaintiffs' Memorandum Of Law In Opposition To Motions To Dismiss, dated October 31, 2008, and states:
+
+Although Plaintiffs, Jane Doe Nos. 2 through 7, are separate and distinct persons, in separate and distinct actions, with separate and distinct facts and circumstances pertaining to the claims each is attempting to allege, Plaintiffs' counsel has filed a broad brush, identical response to Defendant's motions to dismiss and for more definite statement which were filed in each of the actions. As pointed out in Defendant's previously filed motions, there are factual distinctions in the actions and the allegations in Plaintiffs' attempts to assert the claims labeled as Count I — "Sexual Assault and Battery," and Count III - "Coercion and Enticement to Sexual Activity In Violation of 18 U.S.C. §2422." It is essential that each of the actions and the respective complaints filed therein are examined and treated as separate and distinct actions in deciding the respective legal issues and positions asserted.
+
+Jane Doe No. 6 v. Epstein Page 2
+
+As noted, Defendant's motion is directed to Count I and III of the respective complaints. Contrary to each Plaintiffs assertion, Defendant does not concede that Plaintiff has sufficiently plead the elements required to assert claims in Count I for "Sexual Assault and Battery" and in Count III pursuant to 18 U.S.C.§2422, and Defendant has not "misconstrued" the pleading standard formulated by the United States Supreme Court in Bell Atlantic Corp. v. Twomblv, 127 S.Ct. 1955 (2007). In discussing Twomblv the Eleventh Circuit in v. Fla. International Univ. 495 F.3d 1289, 1295 (11th Cir. 2007), noted - "The Supreme Court's most recent formulation of the pleading specificity standard is that 'stating such a claim requires a complaint with enough factual matter (taken as true) to suggest' the required element." In order to sufficiently allege the claim, the complaint is required to identify "facts that are suggestive enough to render [the element] plausible." 495 F.3d at 1296 (quoting Twombly , 127 S.Ct. at 1965). As stated in Defendant's motion to dismiss, Plaintiff has not met this standard requiring the pleading of facts to suggest the elements of the claims she is attempting to assert. In other words, Plaintiff is required to plead facts that suggest each element of the claim she is attempting to assert, as opposed to a generalized pleading. Accordingly, Defendant relies on the legal positions and argument in his motion, rather than reargue what has already been stated.
+
+Finally, the letter attached as an Exhibit to Plaintiffs response is not dispositive of the issue of whether the Plaintiff has sufficiently alleged a claim in Count III pursuant to 18 U.S.C. §2422.
+
+Jane Doe No. 6 v. Epstein  
+Page 3
+
+Wherefore, Defendant requests that this Court grant his motion to dismiss and for more definite statement directed to Plaintiff's Complaint.
+
+**Certificate of Service**
+
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 10<sup>th</sup> day of November, 2008:
+
+Adam D. Horowitz, Esq.  
+Jeffrey Marc Herman, Esq.  
+Stuart S. Mermelstein, Esq.  
+18205 Biscayne Boulevard  
+Suite 2218  
+Miami, FL 33160  
+305-931-2200  
+Fax: 305-931-0877  
+[ahorowitz@hermanlaw.com](mailto:ahorowitz@hermanlaw.com)  
+[jherman@hermanlaw.com](mailto:jherman@hermanlaw.com)  
+[lrivera@hermanlaw.com](mailto:lrivera@hermanlaw.com)  
+*Counsel for Plaintiff Jane Doe #6*
+
+Respectfully submitted,
+
+![]()

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marker2/court-doe-6-v-epstein/EFTA02742630/EFTA02742630.md

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+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARRS
+
+Plaintiff,
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+JANE DOE NO. 7, CASE NO.: 08- 80993-CIV-MARRAMM
+
+Plaintiff
+
+vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## JOINT SCHEDULING AND DISCOVERY REPORT
+
+Plaintiffs, Jane Doe No. 6 and Jane Doe No. 7, and Defendant Jeffrey Epstein, submit this Joint Scheduling and Discovery Report' in accordance with this Court's Order Requiring Counsel to Confer, file Joint Scheduling Report and file Joint Discovery Report, and S.D.Fla.L.R. 16.1(B)(2) and Fed.R.Civ.P. 26(f).
+
+#### DISCOVERY REPORT
+
+These cases are related to Jane Does 2-5 v. Epstein, case nos. 08-CV-80119- MARRAME,08-CV-80232-NIARRe,08-CV-80380-MARRAal. and
+
+The submission of one Joint Scheduling and Discovery Report for the two cases is not intended to be an agreement or admission regarding whether these cues should be consolidated for any purpose.
+
+08-CV-80381-MARRA/JOHNSON. The parties filed a Joint Scheduling and Discovery Report in those cases on September 25,2008, and an Order Setting Trial Date and Discovery Deadlines, et al. was issued by the Court on September 30, 2008, The parties have agreed to propose a schedule in the above-styled cases in which the dates are approximately two months behind those in Jane Doe 2- 5 v. Epstein.
+
+## A. Disclosures Under Rule 26(a)
+
+The parties propose to exchange initial disclosures under Fcd.R.Civ.P. 26(a) on or before December 12, 2008.
+
+## B. Conduct of Discovery
+
+#### 1. Discovery and Pretrial Deadlines
+
+The parties propose the following discovery and pre-trial deadlines:
+
+Joinder of parties and Amendment of pleadings February 2, <sup>2009</sup> Parties to exchange list of fact witnesses and expert witness summaries/reports required by S.D.Fla.L.R. 16.1E August 3, <sup>2009</sup> Mediation to be completed September 4, <sup>2009</sup> Completion of Discovery October 5, <sup>2009</sup> Dispositive Motions to be Filed October 23, <sup>2009</sup> Joint Pretrial Statement to be Filed pursuant to S.D.Fla.L.R. 16.1E November 25, <sup>2009</sup> Propose pre-trial conference December, <sup>2009</sup> Proposed Trial January, <sup>2010</sup> Number of days estimated for Jury trial <sup>10</sup>
+
+See §11(D) below.
+
+#### 2. Subjects of Discovery and Whether Discovery Should be Phased or Limited to Particular Issues
+
+Plaintiffs' Position: There are no unusual issues at this time which require bifurcation or special restrictions on the scope of discovery or the subjects of discovery. Such issues may arise, however, as discovery continues. It is suggested that no restrictions on discovery be imposed at the outset of discovery.
+
+Defendant's Position: Any financial discovery, if allowed, relating to apunitive damage should be postponed until July 15, 2009. As well, as set forth in §D below, Defendant will request an order approving a confidentiality agreement governing access to and use of said information by Plaintiff and her attorneys until such time as documents/testimony is admitted at trial.
+
+# C. Issues About Disclosure of Electronically Stored Information
+
+The parties do not know whether issues may arise concerning discovery of electronically stored information. At this time, such discovery may be produced in paper or electronic form, subject to further order of the Court as may be necessary as discovery proceeds.
+
+# D. Issues About Claims of Privilege or Confidentiality
+
+Plaintiffs' Position: Plaintiffs request that their identities remain anonymous in this proceeding because they have alleged that they were victims of sexual misconduct as minors. Papers and exhibits filed with the Court should redact the names of the Plaintiffs or otherwise be filed under seal.
+
+Defendant's Position: Defendant may oppose anonymity in that Defendant will be prejudiced in defending himself and conducting his discovery without the ability to disclose Plaintiff's name(s), such as at depositions, subpoenaing medical/health related information, school records, etc. As well, Defendant's counsel has found that disclosure of a Plaintiff's name (who
+
+previously filed anonymously) oftentimes produces invaluable and otherwise relevant and material discovery.
+
+Defendant will request a confidentiality agreement with restrictions on any financial discovery which this court may allow. Defendant may assert his Fifth Amendment privilege in this matter.
+
+# E. Limitations Imposed by the Discovery Rules
+
+Plaintiffs' Position: Plaintiffs request that the limitation of 10 depositions for each party under Fed.R.Civ.P. 30(a)(2) be removed. Plaintiffs intend to take the depositions of other minor victims of Defendant Epstein, who arc numerous. There is no need at this time to alter other limitations imposed by the discovery rules.
+
+Defendant's Position: Defendant would request that the number of 10 deposition limit be imposed, pending a motion by either side setting forth justification for additional depositions.
+
+## F. Other Orders that the Court Should Issue Under Rule 26(c) or Rule 16(b) and (el
+
+No other orders appear necessary at this time except as set forth above.
+
+## II. CONFERENCE REPORT
+
+## A. Likelihood of Settlement
+
+The parties have not to date engaged in settlement discussions. They are, however, willing to explore the prospects for settlement through mediation or otherwise as the case proceeds forward.
+
+# B. Likelihood of Appearance of Additional Parties
+
+It dots not appear that additional parties will appear in this case. However, the parties reserve the right to join additional parties within the deadline set forth in §I(B), if appropriate.
+
+### C. Proposed Time Limits
+
+Proposed time limits are set forth in the Discovery Plan, §I(B) above.
+
+# D. Proposals for the Formulation and Simplification of Issues
+
+Plaintiffs' Position: It would be in the interests of judicial economy and efficiency to consolidate these cases at least for purposes of discovery. Plaintiffs have no other proposals for the formulation and simplification of issues at this time.
+
+Defendant's Position: Defendant is opposed to consolidation of the cases for any purpose at this time. Should Plaintiff file amotion, Defendant will consider the request and respond.
+
+# E. Necessity or Desirability of Amendments to the Pleadings
+
+Plaintiff's filed Complaints in each case on September 10, 2008. Plaintiffs do not believe at this time that amendment will be necessary. The parties however reserve the right to amend <sup>p</sup>leadings within the deadline set forth in §I(B) above.
+
+### F. Possibility of Obtaining Admissions of Fact and of Documents; Stipulations; Need for Advance Ruling on Admissibility of Evidence
+
+Plaintiffs' Position: Plaintiffs believe that Defendant Epstein's plea agreement is an admission of liability as to all Counts of the Complaint. Plaintiff's request an early ruling by the Court on the affect of the plea agreement, which will simplify the issues. Additionally, Plaintiffs believe that it is appropriate to have an advance evidentiary ruling on similar fact evidence. If the parties know early in the case how similar fact evidence will be treated at trial, discovery can be more focused and efficient.
+
+Defendant's Position: Defendant expects that the parties will work together to arrive at admissions as the matter progresses. Defendant disagrees that Defendant's plea agreement is an admission as described by Plaintiff. Defendant does agree that having an advance ruling on similar fact evidence may be desirable, after motion and ability to brief and respond.
+
+#### G. Suggestions for the Avoidance of Unnecessary Proof and of Cumulative Evidence
+
+There arc no suggestions at this time for the avoidance of unnecessary proof or of cumulative evidence.
+
+#### H. Suggestion on the Advisability of Matters to a Magistrate Judge <sup>o</sup>
+
+It is suggested that discovery matters be referred to aMagistrate Judge.
+
+# 1. Preliminary Estimate of the Time Required for Trial
+
+It is estimated that the trial will require ten (10) days.
+
+## J. Requested Date or Dates for Pre Trial Conference and Trial
+
+Dates are set forth in the proposed discovery plan §I(B) above.
+
+#### K. Other Information
+
+There is no other information that might be helpful to the Court at this early date regarding setting the case for status conference or pre trial conference. Defendant will file amotion to bifurcate any determination of amount of punitive damages, if applicable. Plaintiff will oppose such <sup>a</sup>motion.
+
+Dated: December c+ , 2008.
+
+Respectfully bmitte
+
+By: Jeffr Marc Herman, Esq. Stuart S. Memielstein, Esq. Adam D. Horowitz, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ahorowitzahermanlaw.com ihermanc\$,hemtanlaw.com
+
+By: Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jages4bellsouth.net Counsel for Defendant Jeffrey Epstein
+
+**G. Suggestions for the Avoidance of  
+Unnecessary Proof and of Cumulative Evidence**
+
+There are no suggestions at this time for the avoidance of unnecessary proof or of cumulative evidence.
+
+**H. Suggestion on the Advisability of Referring  
+Matters to a Magistrate Judge or Master**
+
+It is suggested that discovery matters be referred to a Magistrate Judge.
+
+**I. Preliminary Estimate of the Time Required for Trial**
+
+It is estimated that the trial will require ten (10) days.
+
+**J. Requested Date or Dates for Pre Trial Conference and Trial**
+
+Dates are set forth in the proposed discovery plan §I(B) above.
+
+**K. Other Information**
+
+There is no other information that might be helpful to the Court at this early date regarding setting the case for status conference or pre trial conference. Defendant will file a motion to bifurcate any determination of amount of punitive damages, if applicable. Plaintiff will oppose such a motion.
+
+Dated: December 17, 2008,
+
+Respectfully submitted,
+
+By:  
+Jeffrey Marc Herman, Esq.  
+Stuart S. Mermelstein, Esq.  
+Adam D. Horowitz, Esq.  
+18205 Biscayne Boulevard  
+Suite 2218  
+Miami, FL 33160  
+305-931-2200  
+Fax: 305-931-0877  
+[ahorowitz@hermanlaw.com](mailto:ahorowitz@hermanlaw.com)  
+[iherman@hermanlaw.com](mailto:iherman@hermanlaw.com)
+
+![]()Irivera@benuandave.com
+
+Counsel for Plaintiff ane Doe #6 - #7
+
+By:
+
+Robert D. Cri , Jr., Esq
+
+Florida Bar N• 224162
+
+Michael J. Pike, Esq.
+
+Florida Bar #617296
+
+mnikeabciclaw.com
+
+Burman, Critton, Luther & Coleman,
+
+515 N. Hagler Drive, Suite 400
+
+West Palm Beach, FL 33401
+
+561/842-2820 Phone
+
+561/515-3148 Fax
+
+Counsel for Defendant Jeffrey Epstein
+
+By: i tick
+
+Sigel It. Mill, Esq.
+
+Tein, P.L.
+
+3059 Grand Avenue, Suite 340
+
+Coconut Grove, FL 33133
+
+305-442-1101
+
+Fax: 305 442 6744
+
+Counsel for Defendant Jeffrey Epstein
+
+teinalewistein.com

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marker2/court-doe-6-v-epstein/EFTA02742638/EFTA02742638.md

@@ -0,0 +1,103 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 08-80994-CIV-MARRA
+
+JANE DOE NO. 6,
+
+Plaintiff. vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## ORDER SETTING TRIAL DATE & DISCOVERY DEADLINES, REFERRING CASE TO MEDIATION & REFERRING DISCOVERY MOTIONS TO UNITED STATES MAGISTRATE JUDGE
+
+THIS CAUSE is before the Court upon receipt of the parties' joint scheduling report.
+
+It is thereupon, ORDERED AND ADJUDGED as follows:
+
+#### Trial Date & Location
+
+1. This case is set for trial on the two-week calendar commencing Monday February 8, 2010. Counsel for all parties shall appear at a calendar call commencing at 10:00 o'clock A.M. on Friday, February 5, 2010. Unless instructed otherwise by subsequent order, the trial and all other proceedings in this case shall be conducted at the U.S. Courthouse, 701 Clematis Street, Courtroom 4, Third Floor, West Palm Beach, Florida.
+
+### Motion Practice
+
+2. Every motion filed in this case will be accompanied by one proposed original order granting the motion. The order will contain an up-to-date service list of all attorneys in the case, including e-mail addresses.
+
+## Pretrial Schedule
+
+3. Pretrial discovery will be conducted in accordance with Local Rules 16.1 and 26.1 and the Federal Rules of Civil Procedure. No pretrial conference shall be held in this action, unless the Court determines, either sua sponte or upon motion and order, that a pretrial conference is necessary. In setting the following deadlines, the Court has considered the panics' suggested discovery schedule. Dates and other agreements between the panics not otherwise addressed herein shall be considered part of this Order. To the extent this Order conflicts with the Local Rules, this Order supercedes the Local Rules.
+
+Amend Pleadings/Add Parties -February 2, 2009
+
+Discovery Cutoff —October 5, 2009
+
+Substantive Pretrial Motions —October 23, 2009
+
+Mediation Cutoff — 60 days before calendar call
+
+Mandatory Pretrial Stipulation -Fifteen days before calendar call
+
+Motions in Limine — Fifteen days before calendar call
+
+Responses to Motions in Limine — Ten days before calendar call
+
+Jury Instructions — Five days before calendar call
+
+Proposed Findings & Conclusions — Five days before calendar call
+
+Voir Dire Questions — Calendar call
+
+Exhibit List for Court — First day of Trial (impeachment excepted)
+
+Witness List for Court — First day of Trial (impeachment excepted)
+
+## Mandatory Pretrial Stipulation
+
+4. Counsel must meet at least one month prior to the beginning of the trial period to confer on the preparation of a Pretrial Stipulation in accordance with Local Rule 16.1E.
+
+A Pretrial Stipulation lacking substance will not be accepted. Any party causing a unilateral pretrial stipulation to be filed will be required to show cause why sanctions should not be imposed. Each attorney and each self-represented party is charged with the duty of complying with this Order. A motion for continuance shall not stay the requirement for the filing of the Pretrial Stipulation and, unless an emergency situation arises, or good cause is shown, a motion for continuance will not be considered unless it is filed at least twenty (20) days prior to the calendar call. Failure to comply with the time schedule may result in dismissal or other sanctions.
+
+# Consent Jurisdiction
+
+5. In light of the benefits offered by a trial before a magistrate judge, e.g., trial on a date certain as opposed to placement on a trial calendar, the parties are urged to consider this option. Therefore, within twenty (20) days of the entry of this order each attorney is ordered to meet with his or her client and discuss this option. Plaintiff's counsel shall monitor this process. If there is not unanimity in favor of magistrate jurisdiction, plaintiff's counsel need do nothing further. If, however, there is unanimity in favor of magistrate jurisdiction, plaintiff's counsel shall execute the form (which can be retrieved from www.flsd.uscourts.gov) entitled "Notice of Right to Consent to Disposition of a Civil Case by a United States Magistrate Judge," and forward the original, executed form to defendants' counsel. After completion by all defendants or their counsel, the original form should be forwarded to the Clerk of the Court, West Palm Beach Division.
+
+## Mediation
+
+6. Pursuant to Federal Rule of Civil Procedure 16 and Local Rule 16.2, this case is referred to mediation, to the extent not excluded by Local Rule 16.2.C, as follows:
+
+a. The mediation shall be completed sixty (60) days prior to the scheduled calendar call;
+
+b. The panics shall, within sixty (60) days hereof, agree upon a mediator and advise the Clerk's office of their choice, failing which the Clerk will designate a mediator from the list of certified mediators on a blind random basis;
+
+c. Plaintiff's counsel shall be responsible for coordinating the mediation conference date and location agreeable to the mediator and all counsel of record;
+
+d. Within five (5) days following the mediation conference, the mediator shall tile a Mediation Report indicating who attended the mediation and the result thereof.
+
+## Discovery Referred to Magistrate Judge
+
+7. In accordance with 28 U.S.C. § 636 and the Magistrate Rules of the Local Rules of the Southern District of Florida, the above-captioned cause is referred to United States Magistrate Judge Linnea R. for appropriate disposition of all pretrial discovery motions, and all motions that relate directly to these motions, such as motions for extension of time, motions for reconsideration, motions for sanctions, and motions for mental or physical examinations. This Order does not refer any motion which requests a continuance or extension of the trial or pretrial scheduling dates.
+
+## Exhibits
+
+8. Exhibits must be pre-marked and exchanged prior to execution of the Pretrial Stipulation. Each exhibit should be marked with a sticker identifying the case number, exhibit number, and party offering the exhibit.
+
+## Jury Instructions and Proposed Findings of Fact and Conclusions of Law
+
+9. In cases tried before a jury, each party shall submit joint, stipulated proposed jury instructions and a joint, stipulated proposed verdict form in hard copy form and on 3.5" diskette. All requested instructions shall be typed on a separate page, and except for Eleventh Circuit Pattern instructions, must be supported by citations of authority. Any objections to the proposed
+
+instructions shall be stated clearly and concisely and also shall be supported by citations of authority.
+
+In cases tried before the Court, each party shall file proposed Findings of Fact & Conclusions of Law in hard copy form and on 3.5" diskette. Proposed Conclusions of Law must be supported by citations of authority.
+
+## Settlement
+
+10. If a case is settled, counsel are directed to inform the Court promptly at (561) 561-514- 3790 and to submit an appropriate Stipulation for Order of Dismissal, pursuant to Fed. R. Civ. P. 41(a)(1). Such an Order must be filed within ten (10) days of notification to the Court, or prior to the Calendar Call, whichever occurs first. Cases are not removed from the trial calendar unless a stipulation for dismissal is filed with the Court.
+
+DONE AND ORDERED in at West Palm Beach, Florida, this 17th day of December, 2008.
+
+> e — 2\_ KENNETH A. MARRA United States District Judge
+
+Copies furnished to:
+
+Magistrate Judge Linnea R. All counsel of record

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marker2/court-doe-6-v-epstein/EFTA02742643/EFTA02742643.md

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO. 08-80994-CIV-MARRA
+
+Jane Doe No. 6,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+# OPINION AND ORDER ON MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT
+
+THIS CAUSE is before the Court upon Defendant Jeffrey Epstein ("Defendant")'s Motion to Dismiss and Motion for More Definite Statement, Directed to Plaintiff's Jane Doe No. 6's Complaint (DE 8), filed October 14, 2008. Plaintiff Jane Doe No. 6 ("Plaintiff") filed a response to the motion (DE 9) and Defendant filed a Reply (DE 10). The Court has carefully reviewed the motion, response, and reply, and is otherwise fully advised in the premises.
+
+# Background
+
+On September 10, 2008, Plaintiff filed her Complaint against Defendant (DE 1). Plaintiff brings suit alleging Count I - Sexual Assault and Battery; Count II - Intentional Infliction of Emotional Distress; and Count III - Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. § 2422.
+
+The facts, as alleged in the Complaint, are as follows: At all relevant times, Defendant was an adult male. Comp/. 8. Defendant engaged in a plan and scheme in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave them money. Compl. 1 8. In or about 2004, Plaintiff, then approximately 13 years old, became one of Defendant's victims. Comp!. ¶ 9. Defendant carried out his scheme and assaulted girls in Florida, New York, and his private island in St. . Compl. ¶ 10.
+
+Defendant's scheme involved the use of young girls to recruit underage girls. Compl. ¶ II. Under Defendant's plan, underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Id. Defendant generally sought out economically disadvantaged underage girls from western Palm Beach County who would be enticed by the money being offered — generally \$200 to \$300 per "massage" session — and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made. Id. This was an important element of Epstein's plan. Id.
+
+Defendant's plan and scheme reflected a particular pattern and method. Compl. ¶ 12. The underage victim would be brought or directed to Defendant's mansion, where she would be led up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. Id. The victim would then find herself alone in the room with Defendant, who would be wearing only a towel. Id. Defendant would then remove his towel, lay down naked on the massage table, and direct the girl to remove her clothes. Id. Defendant would then perform one or more lewd, lascivious and sexual acts, including masturbation. Id.
+
+Consistent with the foregoing plan, when Plaintiff was approximately 13 years old, she was recruited by another girl to give Defendant a massage for monetary compensation. Compl. 13. Plaintiff was brought to Defendant's mansion in Palm Beach. Id. Once there, she was led up the stairs to the room with the massage table. Id. Defendant entered the room and directed Plaintiff to remove her clothes and to give him a massage. Id. As directed by Defendant, Plaintiff stripped to her underwear. Id. Defendant then sexually assaulted Plaintiff during the massage. M. In addition, Defendant masturbated during the massage. Id. Defendant then paid Plaintiff money. Id. As a result of this encounter with Defendant, Plaintiff experienced confusion, shame, humiliation, and embarrassment, and has suffered severe psychological and emotional injuries. Compl. ¶ 14.
+
+Under Count I - Sexual Assault and Battery, the Complaint alleges as follows: Defendant made an intentional, unlawful offer of offensive sexual contact toward Plaintiff, creating a reasonable fear of imminent peril and sexual assault. Compl. ¶ 16. Defendant intentionally inflicted harmful or offensive contact on the person of Plaintiff. Compl. ¶ 17. Defendant tortiously committed a sexual assault and battery on Plaintiff. Compl. ¶ 18. Defendant's acts were intentional, unlawful, offensive and harmful. Id. Defendant's plan and scheme in which he committed such acts upon Plaintiff were done willfully and maliciously. Compl. ¶ 19. As a direct and proximate result of Defendant's assault on Plaintiff, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. Compl. ¶ 20.
+
+Under Count II, Intentional Infliction of Emotional Distress, the Complaint alleges as follows:
+
+Defendant's conduct was intentional or reckless. Compl. ¶ 22. Defendant's conduct with a minor was extreme and outrageous, going beyond all bounds of decency. Compl. ¶ 23. Defendant committed willful acts of child sexual abuse on Plaintiff. Compl. ¶ 24. These acts resulted in mental or sexual injury to Plaintiff, that caused or were likely to cause Plaintiff's mental or emotional health to be significantly impaired. Compl. ¶ 24. Defendant's conduct
+
+caused severe emotional distress to Plaintiff. Compl. ¶ 25. Defendant knew or had reason to know that his intentional and outrageous conduct would cause emotional distress and damage to Plaintiff, or Defendant acted with reckless disregard of the high probability of causing severe emotional distress to Plaintiff. Id. As a direct and proximate result of Defendant's intentional or reckless conduct, Plaintiff has suffered and will continue to suffer severe mental anguish and pain. Compl. ¶ 26.
+
+Under Count III, Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. § 2422, the Complaint alleges as follows:
+
+Defendant used a facility or means of interstate commerce to knowingly persuade, induce or entice Plaintiff, when she was under the age of 18 years, to engage in prostitution or sexual activity for which any person can be charged with a criminal offense. Compl. ¶ 28. As a result of Defendant's violation of 18 U.S.C. § 2422, Plaintiff has suffered personal injury, including mental, psychological and emotional damages. Compl. ¶ 30.
+
+Defendant argues in his motion that Counts I and III of the Complaint must be dismissed for failure to state a claim upon which relief can be granted. Fed. R. Civ. P. 12(bX6). Alternatively, Defendant seeks a more definite statement of Counts 1 and W.
+
+Plaintiff responds that the Court should deny the motion because the pleadings at issue contain a short and plain statement of the claims showing that Plaintiff is entitled to relief in accordance with Fed. R. Civ. P. 8(aX2). Plaintiff contends that the specific facts sought by Defendant may properly be the subject of discovery, but are not necessary for purposes of pleading.
+
+## Standard of Review
+
+In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), a court must accept all factual allegations in a complaint as true and take them in the light most favorable to the plaintiff. See Erickson v. Pardus, 127 S.Ct. 2197, 2200 (2007). To satisfy the pleading requirements of Federal Rule of Civil Procedure 8, a complaint must contain a shop and plain statement showing an entitlement to relief, and the statement must "give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests." Swierkiewicz v. Sorema N.A., 534 U.S. 506, 512 (2002) (citing Fed. R. Civ. P. 8); see also Bell Atlantic Corp. v. Twombly, 127 S.Ct. 1955, 1964 (2007); Dura Pharm., Inc. v. Broudo 544 U.S. 336, 346 (2005). This is a liberal pleading requirement, one that does not require a plaintiff to plead with particularity every element of a cause of action. Roe v. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 683 (1 1th Cir. 2001). Instead, the complaint need only "contain either direct or inferential allegations respecting all the material elements necessary to sustain a recovery under some viable legal theory." Id. (internal citation and quotation omitted). "A complaint need not specify in detail the precise theory giving rise to recovery. All that is required is that the defendant be on notice as to the claim being asserted against him and the grounds on which it rests." v. United Food and Conun'l Workers hug Union, 866 F.2d 1380, 1384 ( 1 1th (jr. 1989).
+
+"While a complaint attacked by a Rule 12(bX6) motion to dismiss does not need detailed factual allegations, [ ] a plaintiff's obligation to provide the 'grounds' of his 'entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do." Bell Atlantic Corp. v. Twombly, 127 S.Ct. at 1964-65 (citations omitted). "Factual allegations must be enough to raise a right to relief above the speculative level on the assumption that all of the complaint's allegations are true." Id. at 1965. Plaintiff must plead enough facts to state a plausible basis for the claim. Id.
+
+### Discussion
+
+Counts I alleges a claim for sexual assault and battery. Under Florida law, It is customary to refer to the term "assault and battery" as if it were a legal unit, or a single concept; however, assault and battery are separate and distinct legal concepts, assault being the beginning of an act which, if consummated, constitutes battery. 3A Fla. Jur 2d Assault §1. "'The essential element of an assault is the violence offered, and not actual physical contact,' and 'a battery is defined as an unlawful touching or striking or the use of force against the person of another with the intention of bringing about a harmful or offensive contact or apprehension thereof.' McDonald 223 So.2d 553, 555 (Fla. 2nd DCA 1969), gait'Agi 3 Fla.Jur., Assault and Battery, § 3. Assault is defined as an intentional, unlawful offer of corporal injury to another by force, or force unlawfully directed toward another under such circumstances as to create a fear of imminent peril, coupled with the apparent present ability to effectuate the attempt. Lay v. Kremer, 411 So.2d 1347, 1349 (Fla. 1st DCA 1982). A battery consists of the infliction of a harmful or offensive contact upon another with the intent to cause such contact or the apprehension that such contact is imminent. Paul v. Holbrook, 696 So.2d 1311, 1312 (Fla. 5th DCA 1997); v. Atlantic Fed. Say. & Loan Ass'n, 454 So.2d 52, 54 (Fla. 4th DCA 1984), review denied 461 So.2d 116 (Fla.1985).
+
+Defendant does not contend that Plaintiff failed to allege the above-listed elements of the torts of assault and battery in Count I. Instead, Defendant argues that, under the standard of
+
+pleading established in Twombly,Plaintiff has failed to set forth sufficient factual allegations to support the pleading. Defendant's argument, in essence, is that in a post-Twombly pleading, a heightened fact pleading of specifics is required. However Twombly did not alter the standard for dismissal under Rule 12(b)(6) in the typical case. As the Court explained in CBT Flint
+
+# Partners, LLC v. Goodmail Systems, Inc:
+
+In my view, Twombly did not radically alter the elementary rules of civil procedure that have governed litigation in the federal courts for the past seventy years. The Court's forced retirement of Conley v. MI "no set of facts" language does not change the fundamental command of Rule 8 as to what a valid complaint must look like. Indeed, the Court made clear that it was not imposing a heightened pleading standard. Twombly, 127 S.Ct. at 1974 ("[W]e do not require heightened fact pleading of specifics, but only enough facts to state a claim to relief that is plausible on its face."). As a general matter, I am loath to assume that the Supreme Court circumvented the normal channels for amending the Federal Rules. Swierkiewicz v. Sorema, 534 U.S. 506, 515 (2002) ("A requirement of greater specificity for particular claims is a result that must be obtained by the process of amending the Federal Rules, and not by judicial interpretation.") (quotations omitted). Second, to the extent that Twombly might be plausibly read to alter the requirements for the sufficiency of a complaint, there should be a strong presumption in favor of narrowly confining the decision to its facts. Cohens v. Virginia, 19 U.S. 264 (1821) ( "It is a maxim not to be disregarded, that general expressions, in every opinion, are to be taken in connection with the case in which those expressions are used."). The Court's "new standard" was merely a specific way to articulate a solution to what it perceived to be a specific pleading problem, in a specific area of law that inflicted a high cost upon antitrust defendants. It was not a broad based new license for federal courts to ramp up pleading requirements.
+
+CBT Flint Partners, LLC v. Goodmail Systems, Inc., 529 F.Supp.2d 1376, 1379 (N.D. Ga. 2007).
+
+In this case, Defendant contends that the pleadings fail to allege the specific facts of "what was done to [Plaintiff];" "what Epstein said and did, if anything, to create fear and apprehension in Plaintiff'; and "what was the intentional or harmful contact?" (Mot. 5-6). As to these issues, the Complaint alleges as follows: Alone with Plaintiff in an upstairs room of
+
+Defendant's mansion, Defendant directed Plaintiff to remove her clothes and to give him a massage. Compl. 13. Defendant made an intentional, unlawful offer of offensive sexual contact toward Plaintiff, creating a reasonable fear of imminent peril and sexual assault. Comp!. ¶ 16. Defendant then sexually assaulted Plaintiff during the massage. Compl. 12. Defendant also masturbated during the massage. Id. Defendant intentionally inflicted harmful or offensive contact on the person of Plaintiff. Compl. ¶ 17. Defendant tortiously committed a sexual assault and battery on Plaintiff Compl. ¶ 18. Defendant's acts were intentional, unlawful, offensive and harmful. M.
+
+Plaintiff need not set forth more specific facts to support its allegations to satisfy the notice pleading standard under Rule 8, which requires only that a complaint must set forth a short and plain statement of the facts upon which the claim is based that is sufficient to give the defendant fair notice of what the plaintiff's claims are and the grounds upon which they rest. The parties will be afforded a liberal opportunity for discovery "to disclose more precisely the basis of both claim and defense and to define more narrowly the disputed facts and issues." Conley v. 355 U.S. 41, 48 (1957). Defendant's motion to dismiss or for a more definite statement is DENIED as to Count I.
+
+Counts Ill alleges a claim for coercion and enticement to sexual activity in violation of 18 U.S.C. § 2422. That statute states, in pertinent part,
+
+(b) Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall be fined under this title and imprisoned not less than 10 years or for life.
+
+18 U.S.C. § 2422(b).'
+
+The Complaint alleges: "Epstein used a facility or means of interstate commerce to knowingly persuade, induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or sexual activity for which any person can be charged with a criminal offense." Am. Compl.1 28.
+
+First, the Complaint sufficiently alleges the element of using a facility or means of interstate commerce. See ¶ 28. More specifics are properly the subject of discovery.
+
+Second, Defendant argues that the Complaint fails to set forth underlying factual allegations as to the requisite elements that Defendant knowingly persuaded, induced, enticed, or coerced Plaintiff, when she was under the age of 18 years, to engage in prostitution or sexual activity for which any person can be charged with a criminal offense. Specifically, Defendant claims that Plaintiff fails to allege with what criminal offense Defendant could have been charged. See 18 U.S.C. § 2422(b). The Complaint states a cause of action for violation of 18 U.S.C. § 2422. However, Defendant's position that Plaintiff must state what part of "to engage in prostitution or sexual activity for which any person can be charged with a criminal offense" upon which is relying Plaintiff is well-taken.
+
+Rule 12(e) permits a party to move for a "more definite statement of a pleading to which a responsive pleading is allowed but which is so vague or ambiguous that the party cannot reasonably prepare a response." Fed. R. Civ. P. 12(e). As explained by another court, "[t]he claim of the plaintiff in his complaint is sufficiently definite to enable the defendant to know with
+
+The allegations in the Complaint closely track the language of § 2422(b), making it clear that this is the subsection upon which Plaintiff is relying.
+
+what it is charged, and it is reasonably able therefrom to respond whether it did the thing charged." Dennis v. Begley Drug Co. of Tennessee, Inc., 53 F.R.D. 608, 609 (E.D. Tenn. 1971). As it is written, ¶ 28 is ambiguous as to whether Plaintiff claims prostitution or another criminal offense (and if so, what offense) with which Defendant could have been charged.' The Court finds that Defendant is entitled to a more definite statement as to ¶ 28 in order to provide Defendant with sufficient notice to frame a responsive pleading.
+
+# Conclusion
+
+For the reasons stated herein, Defendant's Motion to Dismiss and Motion for More Definite Statement, Directed to Plaintiff's Jane Doe No. 6's Complaint (DE 8) is GRANTED IN PART AND DENIED IN PART as follows:
+
+- I. Defendant's motion to dismiss or for a more definite statement as to Count I is DENIED.
+- 2. Defendant's motion to dismiss or for a more definite statement as to Count III is GRANTED IN PART AND DENIED IN PART. Defendant's motion to dismiss is denied; however, Plaintiff must file another complaint, which includes a more definite statement as to Count III - Coercion and Enticement to Sexual Activity in Violation of 18
+
+<sup>2</sup> In its opposition, Plaintiff improperly seeks to rely upon a July 10, 2008 letter from A. Villafana, Assistant U.S. Attorney to Plaintiff's counsel. This letter was not referenced in nor attached to the Complaint. It is axiomatic that, at the motion to dismiss stage, the Court must consider well-pled allegations of the complaint as true and must limit its examination to the four corners of the complaint. Grossman v. Nationsbank, N.A., 225 F.3d 1228, 1231 (11th Cir. 2000). Thus, the Court will not consider the letter in ruling on the instant motion.
+
+U.S.C. § 2422, as explained in this Order.
+
+DONE AND ORDERED in at West Palm Beach, Palm Beach County,
+
+Florida, this 12ih day of February, 2009.
+
+KENNETH A. MARRA United States District Judge
+
+copies to: All counsel of record

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARRA,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+# NOTICE OF CHANGE OF NAME OF PLAINTIFF'S COUNSEL
+
+YOU ARE HEREBY NOTIFIED that counsel of record for Plaintiff has changed its name from Herman & Mennelstein, P.A., to:
+
+# MERMELSTEIN & HOROWITZ, P.A.
+
+18205 Biscayne Boulevard
+
+Suite 2218
+
+Miami, Florida 33160
+
+Telephone: (305) 931-2200
+
+Facsimile: (305) 931-0877
+
+Please direct all future pleadings and correspondence to the above-named counsel.
+
+Dated: February 23, 2009 Respectfully submitted,
+
+By: s/ Adam D. Horowitz
+
+Stuart S. Mermelstein (FL Bar No. 947245)
+
+ssm@sexabuseattorney.com
+
+Adam D. Horowitz (FL Bar No. 376980)
+
+ahorowitz@sexabuseattomey.com
+
+MERMELSTEIN & HOROWITZ, P.A.
+
+Attorneys for Plaintiffs Jane Doe
+
+18205 Biscayne Blvd., Suite 2218
+
+Miami, Florida 33160
+
+Tel: 305-931-2200
+
+Fax: 305-931-0877
+
+#### CERTIFICATE OF SERVICE
+
+I hereby certify that on February 23, 2009, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing.
+
+s/ Adam D. Horowitz
+
+## SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida
+
+Jack Alan Goldberger, Esq. jgoldberger@agwpa.com
+
+Robert D. Critton, Esq. rcritton@bciclaw.com
+
+s/ Adam D. Horowitz

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marker2/court-doe-6-v-epstein/EFTA02742657/EFTA02742657.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-80381-CIV-MARRA,
+
+JANE DOE NO. 5,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+#### SECOND AMENDED COMPLAINT
+
+Plaintiff, Jane Doe No. 5 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey Epstein, as follows:
+
+#### Parties, Jurisdiction and Venue
+
+- 1. Jane Doe No. 5 is a citizen and resident of the Commonwealth of Virginia, and is sui juris.
+- 2. This Complaint is brought under a fictitious name to protect the identity of the Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a minor.
+  - 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+  - 4. This is an action for damages in excess of \$50 million.
+- 5. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. §1332(a), as the matter in controversy (i) exceeds \$75,000, exclusive of interest and costs; and (ii) is between citizens of different states.
+  - 6. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial
+
+part of the events or omissions giving rise to the claim occurred in this District.
+
+# Factual Allegations
+
+7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, St. and Palm Beach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
+
+8. Upon information and belief, Epstein has a sexual preference and obsession for underage girls. He engaged in a plan and scheme in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave them money. In or about 2002-2003, Jane Doe, then approximately 15-16 years old, fell into Epstein's trap and became one of his victims.
+
+9. Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St.
+
+10. Epstein's scheme involved the use of young girls to recruit underage girls. These underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. The girls would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Upon information and belief, Epstein generally sought out economically disadvantaged underage girls from western Palm Beach County who would be enticed by the money being offered - generally \$200 to \$300 per "massage" session - and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made. This was an important element of Epstein's plan.
+
+I I. Epstein's plan and scheme reflected a particular pattern and method. The underage
+
+victim would be brought to the kitchen entrance of Epstein's mansion, where she would be introduced to , Epstein's assistant. would then bring the girl up a flight of stairs to a room that contained a massage table in addition to other furnishings, and a bathroom. The girl would then find herself alone in the room with Epstein, who would be wearing only a towel. He would then remove his towel and lie naked on the massage table, and direct the girl to remove her clothes. Epstein would then perform one or more lewd, lascivious and sexual acts, including masturbation and touching the girl's vagina.
+
+12. Consistent with the foregoing plan and scheme, when Jane Doe was approximately 15-16 years old, she was recruited to give Epstein a massage for monetary compensation. Jane and another girl were brought to Epstein's mansion in Palm Beach, to the kitchen entrance. Once there, they were introduced to who led them up the flight of stairs to the room with the massage table. Jane and the other girl were directed by Epstein to remove their clothes and give him a massage. Jane and the other girl removed their clothes except for their panties and bras, and complied with Epstein's instructions. While on the massage table, Epstein masturbated himself and touched both girls on their vaginas with his hand and with a vibrator.
+
+13. After Epstein had completed the sexual assault, both girls were then able to get dressed, leave the room and go back down the stairs. Epstein gave both girls money for this "massage."
+
+14. As a result of this encounter with Epstein, Jane experienced confusion, shame, humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+
+### COUNT I Sexual Assault and Batton
+
+15. Plaintiff Jane Doe repeats and realleges paragraphs I through 14 above.
+
+16. Epstein acted with intent to cause an offensive contact with Jane Doe, or an imminent apprehension of such a contact, and Jane Doe was thereby put in such imminent apprehension.
+
+17. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane Doe, creating a reasonable fear of imminent peril.
+
+18. Epstein intentionally inflicted harmful or offensive contact on the person of lane Doe, with the intent to cause such contact or the apprehension that such contact is imminent.
+
+19. Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts were intentional, unlawful, offensive and harmful.
+
+20. Epstein's plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously.
+
+21. As a direct and proximate result of Epstein's assault on Jane, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages.
+
+WHEREFORE, Plaintiff Jane Doe No. 4 demands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this Court deems just and proper.
+
+### COUNT II Intentional Infliction of Emotional Distress
+
+22. Plaintiff Jane Doe repeats and realleges paragraphs I through 14 above.
+
+23. Epstein's conduct was intentional or reckless.
+
+24. Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds of decency.
+
+25. Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired.
+
+26. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional distress and damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing severe emotional distress to Jane Doe.
+
+27. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, has suffered and will continue to suffer severe mental anguish and pain.
+
+WHEREFORE, Plaintiff Jane Doe No. 5 demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper.
+
+## COUNT III Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
+
+28. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+
+29. Epstein used a facility or means of interstate commerce to knowingly persuade, induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or sexual activity for which any person can be charged with a criminal offense.
+
+30. On June 30, 2008, Epstein entered a plea of guilty to violations of Florida if 796.07 and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-00938 1 AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and scheme as alleged herein.
+
+31. As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of
+
+Florida Statute §796.07(2) (including subsections (c), (d), (e), (f), (g), and (h) thereof), and other criminal offenses including violations of Florida Statutes §§ 798.02 and 800.04 (including subsections (5), (6) and (7) thereof).
+
+- 32. Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
+- 33. As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal injury, including mental, psychological and emotional damages.
+- 34. Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a reasonable attorneys' fee.
+
+WHEREFORE, Plaintiff Jane Doe No. 5 demands judgment against Defendant Jeffrey Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual and compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as this Court deems just and proper.
+
+## JURY TRIAL DEMAND
+
+Plaintiff demands a jury trial in this action on all claims so triable.
+
+Dated: February 27, 2009
+
+Respectfully submitted,
+
+By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) ssm@sexabuseattornev.com Adam D. Horowitz (FL Bar No. 376980) ahorowitz@sexabuseattomev.com MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877
+
+# CERTIFICATE OF SERVICE
+
+I hereby certify that on February 27, 2009, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing.
+
+/s/ Adam D. Horowitz
+
+### SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida
+
+Jack Alan Goldberger, Esq. igoldberger@agwpa.com
+
+Robert D. Critton, Esq. rcritton@belclaw.com
+
+Is/ Adam D. Horowitz

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marker2/court-doe-6-v-epstein/EFTA02742665/EFTA02742665.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CV-80994-MARRA
+
+JANE DOE NO. 6,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+#### AMENDED COMPLAINT
+
+Plaintiff, Jane Doe No. 6 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey Epstein, as follows:
+
+#### Parties, Jurisdiction and Venue
+
+- 1. Jane Doe No. 6 is a citizen and resident of the State of Florida, and is sui juris.
+- 2. This Complaint is brought under a fictitious name to protect the identity of the Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a minor.
+  - 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+  - 4. This is an action for damages in excess of \$50 million.
+- 5. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. §1332(a), as the matter in controversy (i) exceeds \$75,000, exclusive of interest and costs; and (ii) is between citizens of different states.
+- 6. Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
+
+jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein which form part of the same case or controversy.
+
+7. This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as a substantial part of the events or omissions giving rise to the claim occurred in this District.
+
+# Factual Allegations
+
+8. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, approximately 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, St. and Palm Beach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
+
+9. Upon information and belief, Epstein has a sexual preference and obsession for underage minor girls. He engaged in a plan and scheme in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave them money. In or about 2004, Jane Doe, then approximately 13 years old, fell into Epstein's trap and became one of his victims.
+
+10. Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St.
+
+II. Epstein's scheme involved the use of young girls to recruit underage girls. These underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically disadvantaged underage girls from western Palm Beach County who would be enticed by the money being offered - generally \$200 to \$300 per "massage" session - and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made. This was an important element of Epstein's plan.
+
+12. Epstein's plan and scheme reflected a particular pattern and method. The underage victim would be brought or directed to Epstein's mansion, where she would be led up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. The girl would then find herself alone in the room with Epstein, who would be wearing only a towel. He would then remove his towel and lie naked on the massage table, and direct the girl to remove her clothes. Epstein would then perform one or more lewd, lascivious and sexual acts, including masturbation.
+
+13. Consistent with the foregoing plan and scheme, when Jane Doe was only 13 years old, she was recruited by another girl to give Epstein a massage for monetary compensation. Jane was brought to Epstein's mansion in Palm Beach. Once there, she was led up the flight of stairs to the room with the massage table. Epstein came into the room and directed Jane to remove her clothes and give him a massage. As directed by Epstein, Jane stripped to her underwear. Epstein then sexually assaulted Jane during the massage. In addition, Epstein masturbated during the massage. Epstein then paid Jane money.
+
+14. As a result of this encounter with Epstein, Jane experienced confusion, shame, humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+
+# COUNT I Sexual Assault and Batten?
+
+15. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+
+16. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane Doe, creating a reasonable fear of imminent peril and sexual assault.
+
+17. Epstein intentionally inflicted harmful or offensive sexual contact on the person of
+
+Jane Doe.
+
+18. Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts were intentional, unlawful, offensive and harmful.
+
+19. Epstein's plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously.
+
+20. As a direct and proximate result of Epstein's assault on Jane, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages.
+
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this Court deems just and proper.
+
+#### COUNT II Intentional Infliction of Emotional Distress
+
+21. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+
+22. Epstein's conduct was intentional or reckless.
+
+23. Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds of decency.
+
+24. Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired.
+
+25. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional distress and damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing severe emotional distress to Jane Doe.
+
+26. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, has suffered and will continue to suffer severe mental anguish and pain.
+
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper.
+
+## COUNT III Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
+
+27. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+
+28. Epstein used a facility or means of interstate commerce to knowingly persuade, induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or sexual activity for which any person can be charged with a criminal offense.
+
+29. On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §§ 796.07 and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and scheme as alleged herein.
+
+30. As to PlaintiffJane Doe, Epstein could have been charged with criminal violations of Florida Statute §796.07(2) (including subsections (c), (d), (e), (f), (g), and (h) thereof), and other criminal offenses including violations of Florida Statutes §§ 798.02 and 800.04 (including subsections (5), (6) and (7) thereof).
+
+31. Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
+
+32. As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal injury, including mental, psychological and emotional damages.
+
+33. Plaintiff hired Herman & Mermelstein. P.A.. in this matter and agreed to pay them a reasonable attorneys' fee.
+
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual and compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as this Court deems just and proper.
+
+# JURY TRIAL DEMAND
+
+Plaintiff demands a jury trial in this action on all claims so triable.
+
+Dated: February 27, 2009
+
+Respectfully submitted,
+
+By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) ssm@sexabuseattorney.com Adam D. Horowitz (FL Bar No. 376980) ahorowitz@sexabuseattomey.com MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877
+
+# CERTIFICATE OF SERVICE
+
+I hereby certify that on February 27, 2009, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing.
+
+/s/ Adam D. Horowitz
+
+# SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida
+
+Jack Alan Goldberger, Esq. igoldberger@agwpa.com
+
+Robert D. Critton, Esq. reritton@bc1claw.com
+
+/s/ Adam D. Horowitz

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marker2/court-doe-6-v-epstein/EFTA02742673/EFTA02742673.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CV-80994-MARRA
+
+JANE DOE NO. 6,
+
+Plaintiff, vs.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## NOTICE OF STRIKING DOCKET ENTRY NO. 17
+
+Plaintiff, Jane Doe No. 6, by and through undersigned counsel files this Notice of Striking Docket Entry No. 17, and states as follows:
+
+- 1. On February 27, 2009, Plaintiff filed an Amended Complaint in this matter and inadvertently selected the wrong document to be filed.
+- 2. Plaintiff respectfully requests that Docket Entry No. 17 be stricken from the Court's docket in this matter.
+
+Dated: March 3, 2009.
+
+Respectfully submitted,
+
+By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) ssm@sexabuseattorney.com Adam D. Horowitz (FL Bar No. 376980) ahorowitz@sexabuseattorney.com MERMELSTEIN & HOROWITZ. P.A. Attorneys for Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877
+
+## CERTIFICATE OF SERVICE
+
+I hereby certify that on March 3, 2009, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing.
+
+/s/ Adam D. Horowitz
+
+## SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida
+
+Jack Alan Goldberger, Esq. igoldberger@agwpa.com
+
+Robert D. Critton, Esq. reritton@bc1claw.com
+
+/s/ Adam D. Horowitz

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marker2/court-doe-6-v-epstein/EFTA02742676/EFTA02742676.md

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CV-80994-MARRS
+
+JANE DOE NO. 6,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+### DEFENDANT's MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO PLAINTIFF'S AMENDED COMPLAINT
+
+Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his undersigned attorneys, respectfully moves this Court for an extension of time in which to respond to Plaintiffs Amended Complaint dated February 27, 2009. Local General Rule 7.1 A.1 and Rule 6, Fed. R. Civ. P. (2009). Defendant seeks an extension until April 3, 2009, to file his response. As good cause in support of granting the motion, Defendant states:
+
+- 1. Defendant's response to the Amended Complaint would be due on March 11, 2009 (10 days to respond, not including weekend).
+- 2. Plaintiffs counsel also represents five (5) other Plaintiffs pursuing claims against Defendant, EPSTEIN. All Plaintiffs have also filed amended complaints bearing the same dates. In order to fully and adequately respond to this and the other complaints, Defendant is in need of an extension until April 3, 2009.
+- 3. In addition to the multiple amended complaints, good cause for the extension also includes that counsel has been attempting to resolve discovery issues in this and
+
+Jane Doe No. 6 v. Epstein Page 2
+
+other cases against Defendant, EPSTEIN; an associate of Defendant's undersigned counsel who works extensively on this case was out of the office for two weeks during the month February caring for two of her children who had the flu, and the associate herself also caught the flu; Defendant's counsel is also in the midst of preparing for two state court trials — one on a March trial docket and the other specially set in mid-May, (OLD MARSH GOLF CLUB, INC. v. OLD MARSH PARTNERS, et al, Case No. 50 2006CA001667>0MMBAD — set on trial docket beginning March 16, 2009; CARDIOPULMONARY & PRIMARY CARE ASSOC. OF TREASURE COAST, P.A v. M.D., Case No. 562008CA001726, specially set for trial beginning May 13 through 15, 2009). Discovery in both of these cases is ongoing with several depositions set to prepare for trial.
+
+4. The requested extension is fair in reasonable under the circumstances as it will provide time to allow the Defendant, EPSTEIN, to fully and adequately respond to this and the other amended complaints. In addition, this action is still at its early stages.
+
+5. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiffs counsel is in agreement with the requested extension.
+
+WHEREFORE, Defendant requests that this Court enter an order granting an Defendant an extension until April 3, 2009, in which to respond to the Amended Complaint.
+
+# Local Rule 7.1 Statement
+
+Counsel for the movant conferred by telephone with counsel for the Plaintiff and Counsel for Plaintiff is in agreement with the requested extension until April 3, 2009 for
+
+Jane Doe No. 6 v. Epstein  
+Page 3
+
+Defendant to respond to the Second Amended Complaint.
+
+![]()**Certificate of Service**
+
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this D day of March, 2009:
+
+Stuart S. Mermelstein, Esq.  
+Adam D. Horowitz, Esq.  
+Mermelstein & Horowitz, P.A.  
+18205 Biscayne Boulevard  
+Suite 2218  
+Miami, FL 33160  
+305-931-2200  
+Fax: 305-931-0877  
+[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com)  
+[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com)  
+Counsel for Plaintiff Jane Doe #6
+
+Respectfully submitted,
+
+![]()
+
+# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CV-80994-MARRa
+
+JANE DOE NO. 6,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+### ORDER ON DEFENDANT'S MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO AMENDED COMPLAINT
+
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion For Extension of Time In Which to Respond to Amended Complaint. Having considered Defendant's motion and Plaintiffs counsel being in agreement with the requested extension, it is HEREBY ORDERED and ADJUDGED that:
+
+Defendants motion is GRANTED. Defendant shall respond to the Amended Complaint on or before April 3, 2009.
+
+DONE and ORDERED this day of , 2009.
+
+Kenneth A. Marra United States District Judge
+
+Courtesy Copies: Counsel of Record

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marker2/court-doe-6-v-epstein/EFTA02742680/EFTA02742680.md

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+<sup>A</sup>TRUE BILL 616" .-1y1,14er
+
+IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA <sup>S</sup>
+
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA
+
+For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two Thousand and Six, to-wit:
+
+The Grand Jurors of the Slate of Florida, inquiring in and for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in the Circuit and State aforesaid,
+
+## COUNT ONE FELONY SOLICITATION OF PROSTITUTION
+
+on or about or between the 1st day of August in the year of our Lord Two Thousand and Four and October 31, 2005, did solicit, induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to Florida Statute 796.07(1) on three or more occasions between August 01, 2004 and October 31, 2005, contrary to Florida Statute 796.07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1)
+
+against the form of the statute, to the evil example of all others, and against the peace and dignity of the State of Florida.
+
+<sup>I</sup>hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law.
+
+Assistant State At( may of tfie— Fifteenth Judicial Circuit of the State of Florida, prosecuting for the said State
+
+GRAND JURY FOREPERSON
+
+DATE
+
+Jeffrey E. Epstein, Race: , Sex: Male, DOB: January 20, 1953, SS#: 090-44.3348; Issue Warrant
+
+I A 4 EXHIBITA

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marker2/court-doe-6-v-epstein/EFTA02742681/EFTA02742681.md

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+## AFFIDAVIT OF JACK A. GOLDBERGER, ESQUIRE
+
+STATE OF FLORIDA ) SS COUNTY OF PALM BEACH )
+
+BEFORE ME, the undersigned authority, personally appeared having personal knowledge and being duly sworn, deposes and says:
+
+1. I, Jack A. Goldberger, have personal knowledge of the matters set forth herein. I am an attorney licensed to practice in the State of Florida since 1978. I am a partner with the law firm of Atterbury Goldberger & Weiss, P.A., located at One Clearlake Centre, Suite 1400, 250 Australian Avenue South, West Palm Beach, FL 33401.
+
+2. My practice includes and specializes in the defense of criminal matters. I am board certified in criminal law. I have been and currently am the criminal defense attorney for JEFFREY EPSTEIN.
+
+3. I represented Mr. EPSTEIN in the negotiation of and entering into a Non-Prosecution Agreement with the United States Attorney's Office (USAO) for the Federal Southern District of Florida. The terms and conditions of the Non-Prosecution Agreement also entailed the entering of a Plea Agreement with the State Attorney's Office, Palm Beach County, State of Florida. (The Non-Prosecution Agreement shall hereinafter be referred to as the "NPA").
+
+4. By its terms, the NPA took effect on June 30, 2008. Also, pursuant to the terms of the NPA, any criminal prosecution against EPSTEIN is deferred as long as the terms and conditions of the NPA are fulfilled by EPSTEIN.
+
+EXHIBITIE
+
+5. The criminal matters against EPSTEIN remain ongoing until the NPA expires by its terms in late 2010 and as long as the USAO determines EPSTEIN has complied with those terms and conditions. The threat of criminal prosecution against EPSTEIN by USAO in the Southern District of Florida continues presently and through late 2010.
+
+6. Pursuant to the terms of the NPA, the USAO possesses the right to declare that the agreement has been breached, give EPSTEIN's counsel notice, and attempt to move forward with a prosecution. As of the date of this Affidavit, the USAO has taken the position on a number of occasions that it might consider the following actions by EPSTEIN to be a breach of the NPA.
+
+- Investigation by EPSTEIN (by and through his attorneys) of this Plaintiff and the other Plaintiffs in other pending civil cases for purposes of defending the civil actions;
+- EPSTEIN's contesting damages in this action and other civil actions.
+- EPSTEIN or his legal representatives making statements to the press about this Plaintiff or the other Plaintiffs.
+- Using the word "jail" instead of "imprisonment" in the plea agreement with the Palm Beach County State Attorney's Office.
+
+7. EPSTEIN, through counsel, submitted a Freedom of Information Act request to the Federal Bureau of Investigation (FBI) for documents relating to this and the other cases; the FBI denied the request stating the materials are at this time exempt from disclosure because they are in an investigative file, i.e. the matter is still an ongoing criminal investigation.
+
+8. The NPA expires in late 2010.
+
+FURTHER THE AFFIANT SAYETH NAUGHT
+
+![]()STATE OF FLORIDA  
+COUNTY OF PALM BEACH
+
+I hereby Certify that on this day, before me, an officer duly authorized to administer oaths and take acknowledgments, personally appeared Jack A. Goldberger, Esquire, known to me to be the person described in and who executed the foregoing Affidavit, who acknowledged before me that he/she executed the same, that I relied upon the following form of identification of the above named person: Known Personally, and that an oath was/was not taken.
+
+WITNESS my hand and official seal in the County and State last aforesaid this 19<sup>th</sup> day of February, 2009.
+
+(SEARCHED INDEXED SERIALIZED FILED)
+
+![](_page_2_Picture_100.jpeg)
+
+![]()PRINT NAME: KLUE ROSIN  
+NOTARY PUBLIC/STATE OF FLORIDA  
+COMMISSION NO.: DD 489790  
+MY COMMISSION EXPIRES: 11/13/2009

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marker2/court-doe-6-v-epstein/EFTA02742684/EFTA02742684.md

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+
+CASE NO.: 08-CV-80994-MARRA/Mill
+
+JANE DOE NO. 6,
+
+Plaintiff,
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+#### Defendant, Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum Of Law
+
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing this action for a time certain (i.e., until late 2010 when the NPA expires), pursuant to the application of the Fifth Amendment of the U.S. Constitution and the fact that a parallel proceeding is ongoing and being investigated. In support of his motion, EPSTEIN states:
+
+### I. Introduction
+
+At the outset, EPSTEIN notes this Court's prior Order in a companion case, dated December 16, 2008, (Document 28 in CMA — Case No. 08-CV-80811-MARRAMM), in which this Court denied a motion for stay brought by Defendant's prior counsel. In that instance, Defendant's counsel requested a mandatory stay under 18 U.S.C.A. §3509(k) which the court denied. In denying the request for the stay, this Court stated that a discretionary stay was not appropriate at the time the order was entered but also stated, in part, that "Any such issues shall be resolved as they arise in the course of litigation." As discussed herein, "special circumstances" now exist which, in the "interests of justice," merit the entry of a stay of this civil
+
+action until the criminal matter in the 15th Judicial Circuit is "closed" in accordance with the United States Attorney's Office ("USAO") Non-Prosecution Agreement ("NPA") and until the NPA expires.
+
+Moreover, EPSTEIN was indicted by a grand jury in or around July 2006. See Exhibit "A". The Non-Prosecution Agreement is part of the record in connection with that indictment, which is signed by the State Attorney of the 15'h Judicial Circuit in and for Palm Beach County, Florida ("SAO"). In fact, the NPA acknowledges the investigation performed by the SAO. Further, the USAO was present at the Plea hearing whereby the NPA was made part of the record. Thus, there is no question that a parallel criminal matter exists in that the SAO's case remains open and the NPA lives along side it, which places EPSTEIN under great scrutiny by the USAO. The NPA actually places an affirmative duty upon EPSTEIN to undertake discussions with the SAO to ensure compliance with the NPA. That check and balance, therefore, remains in the hands of the SAO, which has a parallel criminal proceeding. Here, the threat of prosecution is real, substantial, and present should the USAO determine that EPSTEIN somehow violated the NPA. As discussed below, because the NPA fails to define what constitutes a breach, the USAO has apparently taken it upon itself to determine whether a breach has occurred and whether to seek criminal prosecution. In fact, the USAO has already attempted to claim violations of the NPA due to, among other things, EPSTEIN defending the civil actions against him. Clearly, it is NOT simply EPSTEIN's choice as to whether he violates the NPA — that discretion apparently lies with the USAO. For this reason alone, a stay is required until the NPA expires.
+
+The difference between this Motion and the prior motion to stay in the companion case is solely due to the ripeness of the issues discussed herein.
+
+### 11. THE NPA
+
+By its terms, the NPA took effect on June 30, 2008 and expires by those same terms in late 2010 so long as EPSTEIN complies with the terms and conditions — violations of which remain undefined. The NPA, which remains under seal, outlines various obligations on the part of EPSTEIN including, but not limited to, pleading guilty to the Indictment and Information before the 15th Judicial Circuit, recommendations for his sentencing before the I5" Judicial Circuit, waiver of challenges to the Information filed by the SAO, waiver of right to appeal his conviction, agreement not be afforded benefits for gain time, and the agreement to not prosecute others listed thereon so long as EPSTEIN does not breach and fulfills the requirements of the NPA.
+
+What the NPA does not outline or define is what constitutes a breach or what act or omission constitutes a breach thereof. Therefore, the USAO apparently believes it has the discretion to make that unwritten and undefined determination, which places an unreasonable burden upon EPSTEIN in defending the civil claims in that he has no idea what the USAO will define as a breach in the event he does not assert his 5th Amendment Rights. As an example, the USAO has already claimed that EPSTEIN violated the NPA by:
+
+- 1. investigating the Plaintiffs (by and though his attorneys) whom brought civil suits against him for purposes of defending those civil actions;
+  - 2. contesting damages in this action and in the other civil actions;
+- 3. making statements to the press about this Plaintiff or other Plaintiffs by and though his attorneys; and
+
+office. 4. using the word "jail" instead of "imprisonment" in the plea agreement with SA's
+
+See Exhibit "B" Goldberger Affidavit - EPSTEIN's criminal counsel.
+
+These allegations are silly, unfounded and alleged violations which are not defined as violations under the NPA but arrived at by the USAO. Thus, EPSTEIN is left with "Morton's Fork" in his side - the undesirable choice of taking the 5th Amendment and having a judgment (summary or otherwise) entered against him in the civil action or the undesirable choice of subjecting himself to discovery in the civil action before the NPA expires and, thus, face the possibility of criminal prosecution by the USAO based upon some illusory breach deemed by the USAO by way of information obtained through civil discovery proceedings. This is inherently unfair, the danger is clear, and the playing field is not level in light of the NPA language or lack thereof.
+
+As a result, the threat of criminal prosecution against EPSTEIN by the USAO continues presently and through late 2010.
+
+### III. Justice Requires The Entry of A Stay Because Defendant Is Being Forced To Choose Between Waiving His Sth Amendment Privilege Or Risk Losing This Civil Case And Forfeiting Other Constitutional Guarantees Of Due Process And Effective Assistance Of Counsel
+
+Once the NPA expires, EPSTEIN fully intends to testify to all relevant and nonobjectionable inquiries made to him in discovery be it a deposition, in interrogatories or in production requests. (Emphasis Added) However, the current circumstances are such that by testifying or responding to discovery, EPSTEIN will be required to waive his constitutional privileges, thereby subjecting himself to criminal prosecution and scrutiny by the USAO as a
+
+result of matters alleged in this civil action (and others before this Court and in the State of Florida 15° Judicial Circuit Court, Palm Beach County).
+
+The special circumstances of this action are such that a stay or continuance for a time certain is NOT prejudicial and is required to be entered so that:
+
+(1) EPSTEIN is not required to waive his Fifth Amendment right against selfincrimination under the United States Constitution resulting in severe prejudice to EPSTEIN in pending criminal matters; and
+
+(2) EPSTEIN is not forced to choose between waiving his Fifth Amendment right against self-incrimination or losing the civil case.
+
+Here, in asserting his Fifth Amendment Privilege, the Plaintiff is afforded an opportunity rarely given - that is, to put on only her evidence without any counterevidence from Defendant resulting in a judgment of liability against EPSTEIN. This is inherently unfair and precisely the special circumstances where "in the interests of justice" a stay is required. Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006), citing. United States v. Lot 5, Fox Grove 23 F.3d 359 (11th Cir. 1994). In Ventura, a stay was entered where a Defendant was confronted with issue of waiving his 5th Amendment Privilege or to loose a civil case by way of motion for summary judgment. Id. Here, EPSTEIN is not requesting a mandatory stay. EPSTEIN only asks that this court recognize that "special circumstances" exists in this matter and enter a stay in the "interests of justice" and only for a specified period of time (i.e., after the NPA expires). See also Securities and Exchange Commission, 755 F.Supp. 1018, 1019 (S.D. Fla. 1990)(Defendant was in precarious position while being subject to criminal investigation and reasoning that compelling Defendant to speak by ordering an accounting of alleged illicit funds would directly
+
+impinge his right against self-incrimination). The court found it appropriate to grant the request for stay. (Emphasis Added).
+
+Citing to U.S. v. Lot 5. Fox Grove supra, the Southern District Court, Florida, in Ventura v. Broskv 2006 WL 3392207 (S.D. Fla. 2006), stated —
+
+The Eleventh Circuit has also created a test for these circumstances, stating that where there exists a concurrent civil and criminal proceeding, a court must stay a civil proceeding pending resolution of a related criminal prosecution when "special circumstances" so require in the "interests of justice."
+
+(Bold emphasis added). See also United States v. Kordel, 397 U.S. 1, 12 & n. 27, 90 S.Ct. 763, 769-70 & n.27 (1970). The Ventura Court went on to state that "situations where a defendant in both criminal and civil proceedings must choose whether to waive his privilege against selfincrimination or to lose the civil case in summary or default judgment proceedings have met this test's burden and warrant a stay." Id. The Ventura court granted the stay. Here, the 15th Judicial Circuit action lives along with the NPA.
+
+In making a decision to enter such a stay, the court may consider the following factors:
+
+- (1) the interests of the Plaintiffs in proceeding expeditiously with litigation, or any aspect of it, and the potential prejudice of Plaintiff to the delay;
+- (2) the burden which any particular aspect of the proceedings may impose on the defendant;
+- (3) the convenience of the court in the management of its cases, and the efficient use of judicial resources;
+  - (4) the interests of persons not parties to the civil litigation; and
+  - (5) the interest of the public in the pending civil and criminal litigation.
+
+See U.S. v. Pinnacle Quest International, 2008 WL 4274498 (N.D. Fla. 2008).
+
+First, in applying the above factors, the Plaintiff in the instant matter will not be prejudiced simply by claiming a delay in time. Second, the burden is far greater on EPSTEIN if he is forced to waive his 5th Amendment Privilege or remain silent and have a judgment entered against him or choose to testify and face criminal prosecution. Third, efficient use of judicial resources would be rendered upon a stay by way of preventing an appeal if such a stay is not entered. The Court has broad discretion to enter such a stay. Fourth, the interests of the individuals outlined in the NPA will be served because EPSTEIN's fulfillment of NPA alleged obligations is determinative upon whether the USAO prosecutes those individuals or whether the claims will be dropped upon the expiration of the NPA. Finally, the interest of the public in the pending civil and criminal cases will not be prejudiced as EPSTEIN is already serving his term whereby a plea was entered in the 15 Judicial Circuit action.
+
+# a. Application of the 5m Amendment
+
+Next, the Fifth Amendment privilege against self-incrimination "permits a person not to answer official questions put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985), clikgz Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is also available to those who claim innocence. One of the Fifth Amendment's "basic functions ... is to protect innocent men ... `who otherwise might be ensnared by ambiguous circumstances."). Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth Amendment - "[i]t would be incongruous to have different standards
+
+determine the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court"); Kastigar v. U.S. 406 U.S. 441, 44445, 92 S.Ct. 1653 (1972)(The Fifth Amendment privilege "can be asserted in any proceeding, civil or criminal, administrative or judicial, investigatory or adjudicatory; and it protects against any disclosures which the witness reasonably believes could be used in a criminal prosecution or could lead to other evidence that might be so used. This Court has been zealous to safeguard the values which underlie the privilege." (Emphasis added)).
+
+The United States Supreme Court made it clear that the scope of the Fifth Amendment Privilege includes the circumstances as here "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); Fisher v. United States 425 U.S. 391 (1976); McCormick on Evidence Title 6, Chap. 13. The Privilege Against Self-Incrimination, §138 (6th Ed.). The privilege against self-incrimination may be asserted during discovery when a litigant has "reasonable grounds to believe that the response would furnish a link in the chain of evidence needed to prove a crime against a litigant." A witness, including a civil defendant, is entitled to invoke the Fifth Amendment privilege whenever there is a realistic possibility that the answer to a question could be used in anyway to convict the witness of a crime or could aid in the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company v. Conbov, 495 U.S. 248, 103 S.Ct. 608 (1983).
+
+Certainly, if the USAO decides to prosecute EPSTEIN for an alleged violation of the NPA, it would undoubtedly be able to use information obtained during discovery against him or use that information to aid in the development of other evidence against him at a criminal trial.
+
+The USAO is already claiming violations of the NPA based upon EPSTEIN defending the civil actions and, at the same time, while EPSTEIN asserts the 5th Amendment. Imagine, because that is all we can do based on the lack of wording in the NPA, what violations the USAO will assert if EPSTEIN is forced to waive his 5ih Amendment privilege to defend himself in this and the other civil actions.
+
+The Fifth Amendment provides, in relevant part, that "No person ... shall be compelled in any Criminal Case to be a witness against himself." Hoffman v. United States 341 U.S. 479, 486, 71 S.Ct. 814 (1951), citing v. United States, 1944, 322 U.S. 487, 489, 64 S.Ct. 1082, 1083, 88 L.Ed. 1408." The Fifth Amendment's privilege against self-incrimination is "accorded liberal construction in favor of the right it was intended to secure." "The immediate and potential evils of compulsory self-disclosure transcend any difficulties that the exercise of the privilege may impose on society in the detection and prosecution of a crime." Id., at 490; and In relM Financial Svcs. of Fla., Inc., 259 B.R. 391, 399 (M.D. Fla. 2000). The privilege not only extends to answers that would in themselves support a conviction under a criminal statute but likewise embraces those which would furnish a link in the chain of evidence needed to prosecute the claimant for a crime. Id, citing Blau v. United States, 1950, 340 U.S. 159, 71 S.Ct. 223. The Fifth Amendment privilege against self-incrimination "permits a person not to answer official questions put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d at 669, citing Leflcowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). As EPSTEIN is here, "the claimant must be `confronted by substantial and `real,' and not merely trifling or imaginary, hazards of incrimination."' See generally, United States v. Apfelbaum. 445
+
+U.S. 115, 128, 100 S.Ct. 948, 956, 63 L.Ed.2d 250 (1980)). See also, United States v. Neff, 615 F.2d 1235, 1239 (9th Cir.), cert. denied, 447 U.S. 925, 100 S.Ct. 3018, 65 L.Ed.2d 1117 (1980)(Information is protected by the privilege not only if it would support a criminal conviction, but even if “the responses would merely ‘provide a lead or clue’ to evidence having a tendency to incriminate.’”). EPSTEIN falls under each of the above category of cases.
+
+The United States Supreme Court has made clear that the scope of the Fifth Amendment Privilege also encompasses the circumstance where “the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect.” United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976). In explaining the application of the privilege, the Supreme Court stated:
+
+We have held that “the act of production” itself may implicitly communicate “statements of fact.” By “producing documents in compliance with a subpoena, the witness would admit that the papers existed, were in his possession or control, and were authentic.” Moreover, as was true in this case, when the custodian of documents responds to a subpoena, he may be compelled to take the witness stand and answer questions designed to determine whether he has produced everything demanded by the subpoena. The answers to those questions, as well as the act of production itself, may certainly communicate information about the existence, custody, and authenticity of the documents. Whether the constitutional privilege protects the answers to such questions, or protects the act of production itself, is a question that is distinct from the question whether the unprotected contents of the documents themselves are incriminating.
+
+“The issue presented in those cases was whether the act of producing subpoenaed documents, not itself the making of a statement, might nonetheless have some protected testimonial aspects. The Court concluded that the act of production could constitute protected testimonial communication because it might entail implicit statements of fact: by producing documents in compliance with a subpoena, the witness would admit that the papers existed, were in his possession or control, and were authentic. United States v. Doe, 465 U.S., at 613, and n. 11, 104 S.Ct. 1237; Fisher, 425 U.S., at 409-410, 96 S.Ct. 1569; *id.*, at 428, 432, 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States, [487 U.S.] at 104, 108 S.Ct. 2284; [*id.*] at 122, 108 S.Ct. 2284 (dissenting opinion). Thus, the Court made clear that the Fifth Amendment privilege against self-incrimination applies to acts
+
+that imply assertions of fact."... An examination of the Court's application of these principles in other cases indicates the Court's recognition that, in order to be testimonial, an accused's communication must itself, explicitly or implicitly, relate a factual assertion or disclose information. Only then is a person compelled to be a `witness' against himself." Doe v. United States. 487 U.S., at 209-210. 108 S.Ct. 2341 (footnote omitted).
+
+Finally, the phrase "in any criminal case" in the text of the Fifth Amendment might have been read to limit its coverage to compelled testimony that is used against the defendant in the trial itself. It has, however, long been settled that its protection encompasses compelled statements that lead to the discovery of incriminating evidence even though the statements themselves are not incriminating and are not introduced into evidence. Thus, a half century ago we held that a trial judge had erroneously rejected a defendant's claim of privilege on the ground that his answer to the pending question would not itself constitute evidence of the charged offense. As we explained:
+
+"The privilege afforded not only extends to answers that would in themselves support a conviction under a federal criminal statute but likewise embraces those which would furnish a link in the chain of evidence needed to prosecute the claimant for a federal crime." Hoffman v. United States, 341 U.S. 479. 486. 71 S.Ct. 814. 95 L.Ed. 1118 (1951).
+
+Compelled testimony that communicates information that may "lead to incriminating evidence" is privileged even if the information itself is not inculpatory. Doe v. United Stales. 487 U.S. 201. 208. n. 6. 108 S.Ct. 2341. 101 L.Ed.2d 184 (1988). It's the Fifth Amendment's protection against the prosecutor's use of incriminating information derived directly or indirectly from the compelled testimony of the respondent that is of primary relevance in this case.
+
+The privilege against self-incrimination may be asserted during discovery when a litigant has "reasonable grounds to believe that the response would furnish a link in the chain of evidence needed to prove a crime against a litigant." A witness, including a civil defendant, is entitled to invoke the Fifth Amendment privilege whenever there is a realistic possibility that the answer to a question could be used in anyway to convict the witness of a crime or could aid in the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company
+
+v. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983). See also Hubbell, supra, as to what is encompassed by the phrase "in any criminal case" contained in the Fifth Amendment.
+
+As noted, the Fifth Amendment privilege against self-incrimination is broad. Hoffman; In re= Financial Svcs.,supra. To deny a witness the right to invoke the privilege, the judge must be perfectly clear, from a careful consideration of all the circumstances in the case, that the witness is mistaken, and that the answers cannot possibly have such tendency to incriminate. LI at 488, 399. Recognizing the breadth and magnitude of this constitutional privilege, the United States Supreme Court in discussing how a court is to analyze the application of the privilege stated —
+
+... It is for the court to say whether his silence is justified, Rogers v. United States, 1951, 340 U.S. 367, 71 S.Ct. 438, and to require him to answer if 'it clearly appears to the court that he is mistaken.' Temple v. Commonwealth 1880, 75 Va. 892, 899. However, if the witness, upon interposing his claim, were required to prove the hazard in the sense in which a claim is usually required to be established in court, he would be compelled to surrender the very protection which the privilege is designed to guarantee. To sustain the privilege, it need only be evident from the implications of the question, in the setting in which it is asked, that a responsive answer to the question or an explanation of why it cannot be answered might be dangerous because injurious disclosure could result. The trial judge in appraising the claim `must be governed as much by his personal perception of the peculiarities of the case as by the facts actually in evidence.'
+
+Hoffman,supra at 486-487.
+
+Hoffman and its progeny establish that "in view of the liberal construction of the provision [protecting against self-incrimination], after a witness has asserted the privilege, he should be compelled to provide the requested information only if it "clearly atmears" to the court that the witness was mistaken in his invocation of the privilege." (Emphasis added). In re Financial Svcs.,supra at 399, citing Hoffman at 486.
+
+In the instant case, the privilege applies as Defendant EPSTEIN "has reasonable cause to apprehend danger from a direct answer." The risk of incrimination resulting from being subject to discovery or to testify in his own defense while the NPA exists is "substantial and real" and "not trifling or imaginary haphazards of communication." See generally, In re= Financial Svcs., supra at 400. Based on the nature of Plaintiff's claims, along with the ongoing scrutiny of the USAO in the criminal matters, EPSTEIN has "reasonable grounds to believe that his responses to the discovery would furnish a link in the chain of evidence needed to prove a crime against him. Finally, in order to preserve the privilege, the privilege must be asserted or one risks the loss or waiver of this liberty ensuring protection. generally, U.S. v. .a , 846 F.2d 678, 690 (11th Cir. 1988X"First, it ignores the settled principle which requires a witness to assert his Fifth Amendment rights. A witness who testifies at any proceeding, instead of asserting his Fifth Amendment rights, loses the privilege. ... A civil deponent cannot choose to answer questions with the expectation of later asserting the Fifth Amendment.").
+
+Also applicable in upholding the assertion of the Fifth Amendment privilege is the guarantee of effective assistance of counsel by the Sixth Amendment of the U.S. Constitution. See Yarborough v. Gentry, 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d 1 (2003XSixth Amendment guarantees criminal defendants effective assistance of counsel.), on remand 381 F.3d 1219. The United States Constitutional guarantees are applicable to the states through the Fourteenth Amendment. Obviously, EPSTEIN's assertion of his constitutional privileges and protections is on the advice of counsel. Again, EPSTEIN continues to face criminal prosecution by the USAO until the expiration of the NPA; under the constitutional guarantee of effective assistance of
+
+counsel, he is entitled to follow the recommended advice of his criminal defense attorney. See Goldberger Affidavit attached hereto.
+
+EPSTEIN's invocation of his constitutional protections of the Fifth, Sixth and Fourteenth Amendments must be upheld for the reasons set forth herein; otherwise such constitutional protections would be rendered meaningless. Thus, EPSTEIN's entitlement to a stay is ripe for determination.
+
+Based upon the foregoing, a stay is warranted in this action as the Defendant is being forced to choose between the assertion of his Fifth Amendment right or losing this case by judgment (summary or otherwise) or waiver of his 5al, Amendment right and face potential criminal prosecution.
+
+> By: ROB RT D. CRITTO JR., ESQ.
+
+## Certificate of Service
+
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify 3at the foregoing document is being served this day on all counsel of record identifi the (lowing Service List in the manner specified by CM/ECF on this day of 2009:
+
+Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ssmesexabuseattornev.com ahorowitzCsexabuseattornev.com Counsel for Plaintiff Jane Doe #6
+
+Respectfully submitted,
+
+![]()ROBERT D. CRITTON, JR., ESQ.
+
+Florida Bar No. 224162
+
+rcrit@bclclaw.com
+
+MICHAEL J. PIKE, ESQ.
+
+Florida Bar #617296
+
+mpike@bclclaw.com
+
+BURMAN, CRITTON, LUTTIER & COLEMAN
+
+515 N. Flagler Drive, Suite 400
+
+West Palm Beach, FL 33401
+
+561/842-2820 Phone
+
+561/515-3148 Fax
+
+*(Counsel for Defendant Jeffrey Epstein)*

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marker2/court-doe-6-v-epstein/EFTA02742699/EFTA02742699.md

@@ -0,0 +1,312 @@
+Westlaw.
+
+703 So.2d 1076  
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169  
+(Cite as: 703 So.2d 1076)
+
+Page 1
+
+District Court of Appeal of Florida,  
+Fifth District.  
+Kimberly BALAS and Teresa Shumate, Petitioners,  
+v.  
+Marjorie A. RUZZO, and Exec., Inc., etc., Re-  
+spondents.  
+No. 97-82.
+
+307Ak31 k. Relevancy and Materiality.  
+Most Cited Cases  
+Party may be permitted to discover evidence that  
+would be inadmissible at trial, if it would lead to  
+discovery of relevant evidence. West's F.S.A. RCP  
+Rule 1.280(b)(1).
+
+**[3] Pretrial Procedure 307A ✉36.1**
+
+As Modified on Grant of Clarification Jan. 2, 1998.  
+rev. denied, 719 So.2d 286 (Fla.  
+Plaintiffs brought action against alleged house of 1998).  
+prostitution for, inter alia, coercion of prostitution.  
+The Circuit Court, Brevard County, █ Pound,  
+J., granted in part defendants' motion to compel dis-  
+covery. Plaintiffs filed petition for writ of certior-  
+ari. The District Court of Appeal, W. Sharp, J., held  
+that evidence of plaintiffs' past prostitution and  
+their revenues relating to such activities was dis-  
+coverable.
+
+307A Pretrial Procedure  
+307AII Depositions and Discovery  
+307AII(A) Discovery in General  
+307Ak36 Particular Subjects of Disclos- ure  
+307Ak36.1 k. In General. Most Cited
+
+Petition denied.  
+Harris, J., concurred specially and filed opinion.
+
+West Headnotes
+
+**[1] Pretrial Procedure 307A ✉31**  
+307A Pretrial Procedure  
+307AII Depositions and Discovery  
+307AII(A) Discovery in General  
+307Ak31 k. Relevancy and Materiality.
+
+Cases  
+Evidence of plaintiffs' past prostitution and their  
+revenues relating to such activities, including activ-  
+ities with alleged house of prostitution against  
+which they had filed suit, was discoverable, where  
+plaintiffs brought action not only for coercion of  
+prostitution, but also for battery, false imprison-  
+ment, invasion of privacy, intentional infliction of  
+emotional distress, violation of their civil rights,  
+and racketeering. Violent Crime Control and Law  
+Enforcement Act of 1994, § 40302, 42 U.S.C.A. §  
+13981; West's F.S.A. §§ 772.014, 796.09; West's  
+F.S.A. RCP Rule 1.280(b)(1).  
+\*1076 Richard E. █ and Heather Fisher Lind-  
+say, of Spriggs & █ Tallahassee, for Peti-  
+tioners.
+
+Most Cited Cases  
+Discovery in civil cases must be relevant to subject  
+matter of case and must be admissible or reason-  
+ably calculated to lead to admissible evidence.  
+West's F.S.A. RCP Rule 1.280(b)(1).
+
+Mark S. Peters of Amari, Theriac & Eisenmenger,  
+P.A., Cocoa, for Respondents.  
+W. SHARP, Judge.
+
+**[2] Pretrial Procedure 307A ✉31**  
+307A Pretrial Procedure  
+307AII Depositions and Discovery  
+307AII(A) Discovery in General
+
+Balas and Shumate petition this court for a writ of  
+certiorari to review certain portions of the lower  
+court's order which granted, in part, a motion to  
+compel discovery filed by respondents Ruzzo and  
+Exec., Inc. Petitioners argue that those portions de-  
+part from the essential requirements of law and will  
+cause them irreparable harm because they will be
+
+EXHIBIT "A"
+
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169(Cite as: 703 So.2d 1076)compelled to disclose intimate details of their sexual history. We decline to issue the writ of certiorari.
+
+Balas and Shumate filed suit against Ruzzo and Exec, Inc., doing business as "The Boardroom." According to Balas and Shumate, The Boardroom operates ostensibly as **\*1077** a leisure spa but actually is a house of prostitution. Balas worked at The Boardroom from December 1993 until February 1996; Shumate worked there from October 1992 until March 1996. Ruzzo, the sole officer and shareholder of Exec, Inc., collected about fifty to sixty percent of each employees' earnings from performing sexual acts.
+
+According to Balas and Shumate, Ruzzo exerted mental and emotional control over her employees and thus she was able to exploit them as prostitutes. Ruzzo required her employees to pay her substantial sums of money to attend "metaphysical workshops" conducted by Ruzzo or persons associated with her. At the work place, the employees were required to participate in religious and quasi-religious "circles," rituals and incantations. These practices were allegedly designed to break down the personalities of the women who worked for Ruzzo and to ██████████ dependency and loyalty to herself. At one time when the earnings of a new employee were missing and believed to be stolen, Ruzzo required that the petitioners be strip searched and body cavity searched. Ruzzo caused the petitioners to believe their continued employment was dependent on their submission to these searches and that they might be arrested on felony charges if they refused to submit to the searches.
+
+Balas and Shumate's second amended complaint against Ruzzo contains seven counts. Count I is an action for coercion of prostitution pursuant to section 796.09, Florida Statutes. Petitioners allege the requirement that they perform sexual acts to retain their employment constitutes inducement and coercion to engage in prostitution. Count II is a claim for battery for the unwanted and offensive touching of the petitioners' bodies. Count III is a claim for false imprisonment for physically confining the pe-
+
+titioners against their will. Count IV alleges that respondents' actions constituted an invasion of petitioners' privacy. Count V is a claim for the intentional infliction of emotional distress. Count VI alleges a civil rights action-that respondents have violated petitioners' right to be free from crimes of violence motivated by gender within the meaning of 42 U.S.C. section 13981. Finally, count VII seeks civil remedies for criminal practices or racketeering pursuant to section 772.104, Florida Statutes. The petitioners claim that they suffered emotional pain, anguish, humiliation, insult, indignity, loss of self-esteem, inconvenience, hurt and emotional distress. They seek an award of general and punitive damages, among other relief.
+
+The discovery to which the petitioners are being required to respond is as follows:
+
+#### I.
+
+**Interrogatory 8:** Please advise how long have you been engaged in prostitution....
+
+#### II.
+
+**Interrogatory 22:** State with specificity the manner in which the acts as described in your Complaint have materially affected how you interact with your husband, boyfriend, fiancée' [sic] or any other individual of the opposite sex.
+
+#### III.
+
+**Request for Production 30:** A copy of any photographs, movies or videotapes in which you performed sexual acts and/or simulated sexual acts in exchange for money or other consideration.
+
+#### IV.
+
+**Interrogatory 16:** Please list the names, addresses, telephone numbers and rates of pay for all employers for which you worked, including the
+
+703 So.2d 1076  
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169  
+(Cite as: 703 So.2d 1076)
+
+Page 3
+
+nature of the work, during the five years immediately preceding the date of employment with the Boardroom and from the date of your termination with the Boardroom to the present, providing the names of your immediate supervisors at each place of employment and the reason for your leaving each place of employment.
+
+V.
+
+**Interrogatory 26:** Please state your total income while employed at the Boardroom, and state the source of that income including any income from other employment or \*1078 income earned from prostitution other than at the Boardroom.
+
+VI.
+
+**Request for Production 34:** Business records from any selfemployment or owned business ventures in the last 5 years, including any records or list of customers, "special customer lists" or "sugar daddy's list."
+
+[1][2] Discovery in civil cases must be relevant to the subject matter of the case and must be admissible or reasonably calculated to lead to admissible evidence. *See Allstate Insurance Co. v. Langston*, 655 So.2d 91 (Fla.1995); *Amente v. [REDACTED]*, 653 So.2d 1030 (Fla.1995); [REDACTED] v. *Stardust Cruisers, Inc.*, 690 So.2d 743 (Fla. 5th DCA 1997). The concept of relevancy is broader in the discovery context than in the trial context and a party may be permitted to discover evidence that would be inadmissible at trial, if it would lead to the discovery of relevant evidence. *Allstate; Amente*. Florida Rule of Civil Procedure 1.280(b)(1) delineates the proper scope of discovery:
+
+*In General.* Parties may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter of the pending action, whether it relates to the claim or defense of the party seeking discovery or the claim or defense of any other party, including the existence, description,
+
+nature, custody, condition, and location of any books, documents, or other tangible things and the identity and location of persons having knowledge of any discoverable matter. It is not ground for objection that the information sought will be inadmissible at the trial if the information sought appears reasonably calculated to lead to the discovery of admissible evidence.
+
+Nonetheless, the discovery of certain kinds of information may cause material injury of an irreparable nature. This includes the "cat-out-of-the-bag" material that could be used to injure another person or party outside the context of the litigation, material protected by privilege, trade secrets or work product. Discovery was never intended to be used as a tactical tool to harass, embarrass or annoy one's adversary. Rather, pretrial discovery was implemented to simplify the issues in a case, to eliminate the elements of surprise, to encourage the settlement of cases, to avoid the cost of litigation, and to achieve a balanced search for the truth to ensure a fair trial. *Elkins v. Syken*, 672 So.2d 517 (Fla.1996).
+
+Here the petitioners argue that the information sought to be discovered regarding prostitution and their sexual activities was propounded solely to embarrass them and to invade their right to privacy. The petitioners also claim that this information is privileged under section 796.09 and is not calculated to lead to evidence which would be admissible at trial.
+
+Section 796.09 provides a person with a civil cause of action for compensatory and punitive damages against anyone who coerces that person into prostitution, who coerces that person to remain in prostitution, or who uses coercion to collect or receive any part of that person's earnings derived from prostitution. In the course of litigation under this section, any transaction about which a plaintiff testifies or produces evidence does *not* subject the plaintiff to criminal prosecution or to any penalty or forfeiture. In addition, any testimony or evidence or any information produced by the plaintiff or wit-
+
+703 So.2d 1076  
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169  
+(Cite as: 703 So.2d 1076)
+
+Page 4
+
+ness for the plaintiffs cannot be used against the plaintiffs or witness in any other investigation or proceeding, except one for perjury.
+
+Section 796.09(5) specifically provides that it is *not* a defense that the plaintiff was paid or otherwise compensated for prostitution, that the plaintiff had engaged in prostitution prior to any involvement with the defendant or that the plaintiff made no attempt to escape from the defendant. Section 796.09(6) provides that convictions for prostitution or prostitution-related offenses are *inadmissible* for the purpose of attacking the plaintiffs' credibility.
+
+This legislation was the result of the Florida Supreme Court Gender Bias Study Commission, which conducted an extensive investigation of prostitution in this state. The Commission's activities included interviews with law enforcement and corrections personnel, \*1079 judges, public defenders, prosecutors, drug rehabilitation counselors, social workers, medical personnel, prostitutes, clients and pimps. The Commission found prostitution to be prevalent and uniform throughout the state and law enforcement largely unable to deter it under prevailing social attitudes and judicial practices. The Commission further found that prostitutes are often victims of economic, physical, and psychological coercion, that most persons do not chose to become prostitutes, but do so to survive, and that ninety percent of street prostitutes, both adult and children, are controlled by pimps who use a variety of coercive methods to maintain this control. The Commission determined that clients and pimps are rarely prosecuted and, when prosecuted, receive light sentences; whereas prostitutes, who are mainly females, are frequently prosecuted and receive harsher treatment in the courts. The Commission recommended changes in the methods of intervention in prostitution from punitive to therapeutic, changes in the law to require more equal treatment by the courts of the prostitute in relation to the client and the pimp and to lessen the incentive to traffic in human flesh by giving the prostitute access to the judicial system without first having to be
+
+arrested.
+
+Under section 796.09, the petitioners' prior involvement in prostitution and their earnings from prostitution would be irrelevant. Hence discovery should not be permitted because such information would not be admissible at trial nor would it be reasonably calculated to lead to evidence ultimately admissible at trial. Even though the scope of discovery is generally quite broad, section 796.09 is designed to encourage prostitutes to sue their pimps. Thus the usually broad scope of discovery may be constricted so that prostitutes will not be embarrassed, harassed or hindered in their actions.
+
+[3] Had the petitioners brought their lawsuit against Ruzzo and The Boardroom *only* under section 796.09, evidence of petitioners' past prostitution, including with the Boardroom, and their earnings relating to such activities, may not have been discoverable. However, the petitioners filed a multi-count complaint for compensatory and punitive damages, alleging numerous causes of action against the respondents. These other causes carry no such protection from discovery. Since the information sought by discovery may be relevant or may lead to the discovery of admissible evidence in one or more of these *other* causes of action or to determination of damages, we cannot conclude that the trial court departed from the essential requirements of law in granting this discovery. *See* [REDACTED] v. *TIB Bank of the Keys*, 687 So.2d 895 (Fla. 3d DCA 1997) (by alleging fraud as well as breach of contract, purchaser placed at issue her reliance on venders' assertions, the veracity of financial documents she submitted to the vender, and the state of her mental health, including memory problems she was experiencing at the time of the alleged tortious conduct, thus deposition questions concerning her state of mind were relevant).
+
+Petition for Writ of Certiorari DENIED.
+
+THOMPSON, J., concurs.  
+HARRIS, J., concurs specially with opinion.HARRIS, Judge, concurring specially:
+
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169(Cite as: 703 So.2d 1076)There is a temptation in cases such as this to inquire which, the pot or the kettle, is imbued with the darker hue. Indeed that may ultimately be the question uppermost in the jurors' minds. But the issue presently before us is simply whether the pot, in order to establish the parties' comparative complexion, may discover the historical condition and the inherent characteristics of the kettle.
+
+We are here involved with parties that the limited record before us indicates were co-conspirators in a joint effort to violate Florida's laws against prostitution. The defendants are the owner/operators of a "social club" whose primary service is prostitution; the plaintiffs are employees of the club who provide such services. The employees are suing the owner/operators for, among other counts, taking advantage of their vulnerabilities ("coercing" them to be prostitutes) through manipulation and exploitation. In order to prepare a defense to the action, defendants have filed certain interrogatories for the employees to answer. These interrogatories\*1080 request such information as how long the employees have been engaged in prostitution; how the employees have been affected by the defendants' conduct; copies of photographs, movies, and videotapes in which the employees have performed sexual acts or simulated sexual acts; the names of previous employers and previous rates of pay; and a statement of income received from defendants. These interrogatories survived the employees' objections. I agree certiorari should be denied.
+
+The employees' primary cause of action is based on section 796.09(1), Florida Statutes, which provides:
+
+(1) A person has a cause of action for compensatory and punitive damages against:
+
+(a) A person who coerces that person into prostitution;
+
+(b) A person who coerces that person to remain in prostitution, or
+
+(c) A person who uses coercion to collect or receive
+
+any part of that person's earnings derived from prostitution.
+
+The employees resist discovery of their past prostitution or their past or present earning experience on the basis of subparagraph 5 of section 796.09:
+
+(5) It does not constitute a defense to a complaint under this section that:
+
+a) The plaintiff was paid or otherwise compensated for acts of prostitution;
+
+b) The plaintiff engaged in acts of prostitution prior to any involvement with the defendant ...
+
+But the question before us is not whether prior acts of prostitution (or the receipts of earnings therefrom) which might be revealed by answering the interrogatories could be used as a defense to the complaint, but rather whether evidence of such conduct or such earnings would be relevant in determining whether the employees were, in fact, "coerced" into prostitution, into remaining prostitutes, or into sharing the proceeds of their services with defendants. The relevancy of this information depends, of course, on what constitutes coercion.
+
+If we apply the definition of "coercion" which is commonly accepted, then the relevancy of the requested information is apparent and this appeal has no merit at all. Webster defines "coercion" as: (1) to restrain or dominate by force, (2) to compel an act or choice, or (3) to enforce or bring about by force or threat. In sexual battery cases, the legislature has adopted the common meaning of the word "coercion" and has even placed limits on it. It has provided that consent will not be recognized if submission is *coerced* by threats of force or violence *if* the victim reasonably believes the perpetrator has the present ability to execute the threat.<sup>FN1</sup> Consent also will not be recognized if submission is *coerced* by a threat of retaliation against the victim or another *if* the victim reasonably believes that the perpetrator has the ability to execute the threat in the future.<sup>FN2</sup> And in sexual battery cases, the legislature has vitiated what might otherwise be con-
+
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+
+703 So.2d 1076, 22 Fla. L. Weekly D2375.23 Fla. L. Weekly D169
+
+(Cite as: 703 Sold 1076)
+
+sidered as consensual if one exploits a known physical or mental weakness of the victim to achieve his or her goal or takes advantage of one who is physically helpless or involuntarily intoxicated." Therefore, even in sexual battery cases, before coercion or exploitation will vitiate consent, the free will of the victim must be overcome by force or threat or some unfortunate circumstance suffered by the victim.
+
+> FNI. Section 794.011(4)(b), Florida Statutes.
+
+> FN2. Section 794.01I(4)(c), Florida Statutes.
+
+FN3. Section 794.011(4)(a),(d),(e). and (0, Florida Statutes.
+
+But then we get to the definition of "coercion" contained in section 796.09(3):
+
+:3) As used in this section, the term "coercion" means any practice of dominion, restraint, or inducement for the purpose of or with the reasonably foreseeable effect of causing another person to engage in or remain in prostitution or to relinquish earnings derived from prostitution, and includes, but is not limited to:
+
+:a) Physical force or threats of physical force
+
+:b) Physical or mental torture.
+
+:c) Kidnapping.
+
+'1081 (d) Blackmail.
+
+,'e) Extortion or claims of indebtedness.
+
+',f) Threats of legal complaint or report of delinquency.
+
+,'g) Threat to interfere with parental rights or responsibilities, whether by judicial or administrative action or otherwise.
+
+:h) Promise of legal benefit.
+
+',I) Promise of greater financial rewards.
+
+'j) Promise of marriage.
+
+:k) Restraint of Speech or communications with others.
+
+',/ ) Exploitation of a condition of developmental disability, cognitive limitation, affective disorder, or substance dependency.
+
+:m) Exploitation of victimization by sexual abuse.
+
+;n) Exploitation of pornographic performance.
+
+:0) Exploitation of human needs for food, shelter, safety, or affection.
+
+The definition urged by the employees herein is the "promise of a greater financial reward." Whether the requested information is relevant to the issue of coercion in this case will depend on what the legislature intended by subsection (I) in the meaning of "coercion."
+
+I agree with Judge Altenbemd's thoughtful analysis in State v. Brigham, 694 So.2d 793 (1997):
+
+There can be no dispute that the legislature's unusual definition of "percent" is not a common dictionary definition. This is perhaps an appropriate case in which to remind ourselves of Learned Hand's famous observation that a "mature and developed jurisprudence" does not "make a fortress out of the dictionary."
+
+But even so. one would expect some nexus between the commonly accepted meaning of a word and the definition of that word ascribed by the legislature. If, for example, the legislature defined "canine" as including cats, although one might, jurisprudentially speaking, expect to hear a meow emanate from a Great Dane, the courts should nevertheless closely examine the legislative history to see if that is really what the legislature intended. The court in Young v. O'Keefe, 246 Iowa 1182, 69 N.W.2d 534, 537 (1955), stated this principle as follows: "But
+
+703 So.2d 1076  
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169  
+(Cite as: 703 So.2d 1076)
+
+Page 7
+
+before a definition is construed so as to expand the meaning of a well-known word to include its antonym ..., the intention of the legislature to that effect must be clear." As Judge [REDACTED] observed in *Catron v. Roger Bohn, D.C., P.A.*, 580 So.2d 814, 818 (Fla. 2d DCA 1991):
+
+It is our primary duty to give effect to legislative intent and, if a literal interpretation of a statute leads to unreasonable results, then we should exercise our power to interpret reason and logic to it.
+
+\* \* \* \* \*
+
+Unfortunately, it is apparent that in enacting this legislation, the legislature has, without redefining the terms for the purposes of this legislation, often used terms with commonly accepted meanings for purposes at great variance from those commonly accepted meanings.
+
+In our case, the legislature did define the term for the purpose of the act. But because the term (coercion) as so defined can be interpreted two ways-one consistent with the commonly accepted meaning and one at variance-we should not accept the "antonym" unless such legislative intent is clear. A free will decision, even if based on a hope of financial gain, is the opposite of a coerced decision.
+
+The employees urge that the mere promise of a greater reward brings them within the act. But if the mere promise of a greater reward is sufficient to establish coercion, then anyone who makes a voluntary and reasoned exercise of free will motivated by the hope of economic gain has been coerced. This definition removes the element of compulsion implicit in the commonly accepted meaning of coercion and substitutes therefor the mere desire for financial gain. The employees herein assert that since they were offered "a greater financial reward" for providing the services performed by them through defendants' establishment, they were coerced into their prostitution activities. This equates the giving
+
+of an opportunity to make a decision with the coercion of that decision. But subsection (I) can also mean \*1082 that the promise of a greater reward is coercion *only if* such promised reward is sufficient to overcome one's natural revulsion to selling one's body for money. If there is no such revulsion, there can be no coercion. Becoming a prostitute only because one likes the hours and wages or "because it beats the heck out of working for a living" simply should not meet the test of section 796.09(1).
+
+At oral argument herein, it was suggested without contradiction, that at least one of the employees has a college degree and gave up a well-paying, legitimate job in order to engage in this profession for the greater reward. Section 796.09 does not appear to be a general prostitute's relief act. It is based on a report by the Gender Bias Study Commission which recommended the equalization of treatment in relation to the prostitute, the client and the "pimp." It is based on the premise that prostitutes are generally victims of economic, physical, and psychological coercion and choose prostitution in order to survive. Further, the Commission was concerned that 90 percent of the street prostitutes are controlled by "pimps" who use a variety of coercive methods to maintain control. It seems clear that the legislature was not intending to depart from the precepts of the commonly understood meaning of "coercion" and to redefine it to include both free will decisions and compelled decisions.. The interpretation urged by the employees seems at variance with the stated goal of the legislature and the Gender Bias Commission.
+
+Since there is no cause of action provided for one who makes a reasoned and voluntary exercise of their free will to enter or continue in the profession solely for financial rewards (assuming "coercion" is given the definition more consistent with its commonly accepted meaning and assuming that my interpretation of legislative intent is correct), coercion becomes the critical issue in the trial of such action. The interrogatories propounded by defendants appear relevant to the issue of coercion.
+
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169(Cite as: 703 So.2d 1076)This is a case of first impression based on a relatively new statute. As indicated, the legislative history of the new law suggests that the statute is designed to assist those who were forced to enter prostitution in order to keep a roof over their heads or food on their table. It does not appear to be intended to aid those who voluntarily enter the profession in order to drive a Mercedes instead of a █████. The limited record before us indicates that even beginning employees of the defendants (those who do not have an established clientele) bring in \$700 a day and can keep 50% of their earnings. Based on a five-day work week, this would reflect an income of \$87,500 a year even with a two week vacation. And the employees herein are not beginners.
+
+There is no indication that the legislature intended to legalize prostitution or to make it a respectable profession. It merely intended to place the prostitute on the same footing with the client and the "pimp." If a prostitute voluntarily makes the decision to participate, free from force, intimidation, or disadvantageous circumstance, then he or she is on the same footing as the other participants and should be treated the same.
+
+Although it might well serve a legitimate public purpose to permit the cannibalistic demise of such enterprises (and I am not unsympathetic with this view), that does not appear to be the policy behind the current statute. Therefore, in cases where coercion is not present (and this may or may not be one), the court should continue its tradition of not interceding in civil conflicts involving transactions that are either illegal or are against public policy. *See Wechsler v. Novak*, 157 Fla. 703, 26 So.2d 884 (1946); █████ v. *Ratiner*, 462 So.2d 1157, 1160 (Fla. 3d DCA 1984), *rev. denied*, 472 So.2d 1182 (Fla.1985) ("An action may lie for interference with an unenforceable contract and even perhaps a voidable contract. No such cause of action lies for interference with a contract *void* as against public policy [another's representation of a client obtained by a doctor/lawyer's illegal personal injury solicitation
+
+in the hospital] and which makes one who is a party thereto, as the appellant in the instant case, guilty of a criminal act for entering into such an agreement.")
+
+We are not asked in this proceeding to rule on the admissibility of the discovered information as evidence at the trial of this cause. We are to determine only if the information might lead to admissible evidence. Even \*1083 though we deny the Writ I suggest we certify the following question:
+
+DOES ONE, FREE FROM FORCE, INTIMIDATION, OR DISADVANTAGEOUS CIRCUMSTANCE, WHO MAKES A REASONED DECISION TO BECOME OR REMAIN A PROSTITUTE OR TO SHARE THE PROCEEDS THEREOF BECAUSE OF A PROMISE OF A GREATER FINANCIAL REWARD HAVE A CAUSE OF ACTION UNDER SECTION 796.09(1), FLORIDA STATUTES?
+
+*ON MOTIONS FOR REHEARING, FOR CLARIFICATION, FOR CERTIFICATION, AND FOR REHEARING EN BANC*
+
+W. SHARP, Judge.
+
+Petitioners Balas and Shumate have filed motions for rehearing, clarification and certification. We deny the motions in full except for one regard. We delete the sentence in the last full paragraph of the opinion which reads: "These other causes of action carry no such protection from discovery."
+
+Motion for Clarification GRANTED as stated above; Motion for Rehearing and Certification DENIED.
+
+HARRIS and THOMPSON, JJ., concur.
+
+Fla.App. 5 Dist., 1997.
+
+Balas v. Ruzzo
+
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+
+END OF DOCUMENT

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