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efta-efta00212861DOJ Data Set 9Other

Case 9:09-cv-80591-KAM

Case 9:09-cv-80591-KAM Document 53 Entered on FLSD Docket 06/12/2009 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CI V- 80591 - KAM JANE DOE NO. 101, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S NOTICE OF WITHDRAWL OF ARGUMENTS THROUGH VII OF THE DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT (DE29) Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, hereby withdraws arguments I through VII as set forth in the Defendant's Motion to Dismiss the Plaintiff's First Amended Complaint (FAC) [DE 29], dated May 26, 2009. Defendant withdraws his arguments contained subparagraphs A, B, C and Sections I (The Complaint Must Be Dismissed Because Plaintiff Is Not A Minor), II (The FAC Must Be Dismissed Because The Defendant Has Not Been Convicted Of A Predicate Offense), III (Count One Of The FAC Must Be Dismissed Because It Does Not Please A Violation Of 18 U.S.C. § 2422(b)), IV (C

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00212861
Pages
2
Persons
1
Integrity

Summary

Case 9:09-cv-80591-KAM Document 53 Entered on FLSD Docket 06/12/2009 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CI V- 80591 - KAM JANE DOE NO. 101, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S NOTICE OF WITHDRAWL OF ARGUMENTS THROUGH VII OF THE DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT (DE29) Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, hereby withdraws arguments I through VII as set forth in the Defendant's Motion to Dismiss the Plaintiff's First Amended Complaint (FAC) [DE 29], dated May 26, 2009. Defendant withdraws his arguments contained subparagraphs A, B, C and Sections I (The Complaint Must Be Dismissed Because Plaintiff Is Not A Minor), II (The FAC Must Be Dismissed Because The Defendant Has Not Been Convicted Of A Predicate Offense), III (Count One Of The FAC Must Be Dismissed Because It Does Not Please A Violation Of 18 U.S.C. § 2422(b)), IV (C

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Case 9:09-cv-80591-KAM Document 53 Entered on FLSD Docket 06/12/2009 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CI V- 80591 - KAM JANE DOE NO. 101, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S NOTICE OF WITHDRAWL OF ARGUMENTS THROUGH VII OF THE DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT (DE29) Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, hereby withdraws arguments I through VII as set forth in the Defendant's Motion to Dismiss the Plaintiff's First Amended Complaint (FAC) [DE 29], dated May 26, 2009. Defendant withdraws his arguments contained subparagraphs A, B, C and Sections I (The Complaint Must Be Dismissed Because Plaintiff Is Not A Minor), II (The FAC Must Be Dismissed Because The Defendant Has Not Been Convicted Of A Predicate Offense), III (Count One Of The FAC Must Be Dismissed Because It Does Not Please A Violation Of 18 U.S.C. § 2422(b)), IV (Count Two Must Be Dismissed Because It Does Not Plead A Violation Of 18 U.S.C. §2423(b)), V (Count Three Must Be Dismissed Because It Does Not Plead A Violation Of 18 U.S.C. § 2251, VI (Counts Four and Five Must Be Dismissed Because They Do Not Plead Violation of 18 U.S.C. §§ 2252(a)(1) Or 2252(a)(1), and VII (Count Six Must Be Dismissed Because 18 U.S.C. § 2252A(g) Was Not Enacted Until 2006). Defendant will rely only on those arguments set forth in subparagraph D, on page 3, and Paragraph VIII (Any Surviving Count Should Be Merged Into A Single Count) of the EFTA00212861 Case 9:09-cv-80591-KAM Document 53 Entered on FLSD Docket 06/12/2009 Page 2 of 2 Defendant's Motion to Dismiss the First Amended Complaint Or, In The Alternative, For A More Definite Statement [DE 29) dated May 26, 2009. Counsel for De dant EPSTEIN 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 record ' ntified on the following Service List in the manner specified by CM/ECF on thiV ay of 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. Counsel for Defendant Jeffrey Epstein Respectfully submitted By: ROBERT D. ITTON, JR., ESQ. Florida B MICHAEL J. PIKE, ESQ. Florid a BURMAN, CRITTON, arrrmR & COLEMAN (Counsel for Defendant Jeffrey Epstein) EFTA00212862

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Case #9:09-CV-80591-KAM

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Case 9:08-cv-80232-KAM Document 16 Entered on FLSD Docket 07'16'2008 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80232-CIV-MARRA/JOHNSON JANE DOE NO. 3, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO SEAL THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to File Ex Parte and Under Seal, filed July 10, 2008. Defendant seeks to file a Notice of Continued Pendency of Federal Criminal Action under seal.' The Court has carefully considered the motion and the record and is otherwise fully advised in the premises. As stated in the Local Rules for the Southern District of Florida, "proceedings in the United States District Court are public and Court filings are matters of public record." S.D. Fla. L.R. 5.4(A). It is well settled that the media and the public in general possess a common-law right to inspect and copy judicial records. See Nixon I Warner Communications, Inc., 435 U.S. 589, 597 (1978).

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EXHIBIT A (FILED UNDER SEAL) Confidential SETTLEMENT AGREEMENT AND GENERAL RELEASE [REDACTED - Survivor], f/k/a [REDACTED - Survivor] (“[REDACTED - Survivor]”), individually, and Jeffrey Epstein, individually (jointly referred to as “Parties”), enter into this Setttement Agreement and General Release (“Settlement Agreement”) in order to resolve the pending litigation between them as follows: 1. Dismissal. The Parties agree to immediately dismiss the pending lawsuit presently styled Jane Doe No. 102 vs. Jef

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CM/ECF - Live Database - flsd Page 1 of 17 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80380-KAM Doe No. 4'. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson Lead case: 9:08-ev-80111-.KAM Member case• (View Member Case) Case: 9:09-0-80802-KAM Cause: 28:1332 Diversity Plaintiff Jane Doe No. 4 Date Filed: 04/14/2008 Jury Demand: Plaintiff Nature of Suit: 360 P.I.: Other Jurisdiction: Diversity represented by Adam D. Horowitz Mermelstein & Horowitz PA 18205 Biscayne Boulevard Suite 2218 Miami FL 33160 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Jeffrey Marc Herman Herman & Mermelstein 18205 Biscayne Boulevard Suite 2218 Miami FL 33160 Fax: 931-0877 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Stuart S. Mermelstein Mermelstein & Horowitz PA 18205 Biscayne Boulevard Suite 2218 Miami FL 33160 MOM Fax: 931-0877 Email: LRJ https://ecIfIsd.uscourts.g

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