Case 9:08-cv-80811-KAM
Summary
Case 9:08-cv-80811-KAM Document 121 Entered on FLSD Docket 06/17/2009 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN and Defendants. PLAINTIFF, MOTION FOR PROTECTIVE ORDER REGARDING RECORDS OF DOMINIQUE HYPPOLITEISCHOOL DISTRICT OF PALM BEACH COUNTY, GOOD SAMARITAN HOSPITAL, ST. MARY'S HOSPITAL, FLORIDA ATLANTIC UNIVERSITY AND GLORIA C. HAKKARAINEN, M.D. Plaintiff , by and through her undersigned attorneys, hereby files her Motion For Protective Order Regarding Records of Dominique Hyppolite/School District of Palm Beach County, Good Samaritan Hospital, St. Mary's Hospital, Florida Atlantic University and Gloria C. Hakkarainen, M.D., and in support there of states as follows: 1. This is an action to recover money damages against Defendant, JEFFREY EPSTEIN, for acts of sexual abuse and prostitution committed upon the then- minor, 2. On June 1, 2009, Defendant, Jeffrey
Persons Referenced (6)
“... filing to all counsel of record on the attached service list. is/Jack P Hill Jack Scarola Florida Bar No.: Jack P. Hill Florida Bar No.: CM= Searcy Denney Scarola Barnhart & Shipley, P.A. 2139...”
The Defendant“...LOCAL RULE 7.1 Counsel for the movant conferred via telephone with counsel for the Defendant and counsel for the Defendant is not in agreement with Plaintiffs Motion For P...”
Jack A. Goldberger“...r & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33414 Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South Wes...”
United StatesJack P. HillJeffrey Epstein“...as follows: 1. This is an action to recover money damages against Defendant, JEFFREY EPSTEIN, for acts of sexual abuse and prostitution committed upon the then- minor, 2. On June 1, 2009, Defenda...”
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Case 9:08-cv-80119-KAM
Case 9:08-cv-80119-KAM Document 181 Entered on FLSD Docket 06/26/2009 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO.2, Plaintiff, CASE NO.; 08-CV-80119-MARRA/JOHNSON vs. JEYPREY EPSTEIN, Defendant. JANE DOE NO.3, CASE NO.; 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO.4, CASE NO.; 08-CV-80380-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 5, CASE NO.; 08-CV-8038I-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. EFTA00222299 Case 9:08-cv-80119-KAM Document 181 Entered on FLSD Docket 06/26/2009 Page 2 of 12 Page 2 JANE DOE NO. 6, Plaintiff, CASE NO.; 08-CV-80994-MARRA/JOHNSON vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 7, CASE NO.; 08-CV-80993-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. C.M.A., CASE NO.; 08-CV-80811-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE, CASE NO.; 08-CV-80893-MARRA/JOHNSON
Case 9:08-cv-80119-KAM
Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009 Page 1 of 20 #281849/clw UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV- MARRA/JOHNSON C.M.A., Plaintiff(s), vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendant(s). NOTICE OF SERVING ANSWERS TO INTERROGATORIES COMES NOW the Plaintiff, C.M.A., by and through undersigned counsel, and hereby files this Notice with the Court that Answers to Interrogatories propounded by the Defendant, JEFFREY EPSTEIN, on January 16, 2009, have been furnished to the attorney for the Defendant. I HEREBY CERTIFY that a true copy of the foregoing has been furnished by mail this IT .74%. day of February, 2009, to: See attacked list of counsel. CL JACK SCAC.OLA Florida Bar No.: 169440 JACK P. HILL Florida Bar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9410 Attorn
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0338E903Etek.888893941AAAA ODCIKNOM03712 En 1'€10 ikaPRPFAftikW54/4/(1809 Pander)! !24 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRA/JOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, Defendant. Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedinas 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, dated December 16, 2008, (Document 28), in which this
Case 9:08-cv-80811-KAM
Case 9:08-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRA/JOHNSON C.M. A., Plaintiff, v. EPSTEIN and Defendants, DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS FIRST AMENDED COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION, AND MOTION FOR MORE DEFINITE STATEMENT; MOTION TO STRIKE, AND SUPPORTING MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, moves to dismiss Count I through XXXI of Plaintiffs First Amended Complaint for failure to state a cause of action, and for more definite statement, or to strike, as specified herein. Rule 12(b)(6), (e) and (f), Fed.R.Civ.P. (2008); Local Gen. Rule 7.1 (S.D. Fla. 2008). In support of dismissal, Defendant states: The First Amended Complaint attempts to allege 32 counts. Counts I through XXX are purportedly brought pursuant to 18 U.S.C. §2255 - Civil Remedies for Person
Case 9:08-cv-80811-KAM
Case 9:08-cv-80811-KAM Document 58 Entered on FLSD Docket 04/13/2009 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON C.M.A., Plaintiff, vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS FIRST AMENDED COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION, AND MOTION FOR MORE DEFINITE STATEMENT; MOTION TO STRIKE, AND SUPPORTING MEMORANDUM OF LAW The Plaintiff, C.M.A., by and through undersigned counsel, files this Response to Defendant, Jeffrey Epstein's, Motion to Dismiss First Amended Complaint for Failure to State a Cause of Action, and Motion for More Definite Statement; and Motion to Strike (D.E. 47). As a preliminary matter, the Plaintiff submits that she has pled sufficient factual bases to support the 31 claims set forth against the Defendant in this case. In this Court's Opinion and Order on Motion to Dismiss and Mot
Case 9:08-cv-80811-KAM
Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON C.M.A., Plaintiff, VS. PSTEIN and Defendants. PLAINTIFF C.M.A.'S MOTION FOR PROTECTIVE ORDER REGARDING TREATMENT RECORDS FROM AND INCOR AND Plaintiff, C.M.A., by and through her undersigned attorneys, hereby files her Motion For Protective Order Regarding Treatment Records FroH a n d and Incorporated Memorandum of Law, and in support there of states as follows: 1. This is an action to recover money damages against Defendant, JEFFREY EPSTEIN, for acts of sexual abuse and prostitution committed upon the then- minor, C.M.A. 2. Plaintiff has plead thirty separate counts against EPSTEIN for separate incidences of abuse committed by EPSTEIN against Plaintiff pursuant to 18 U.S.C. §2255. 18 U.S.C. §2255, entitled "Civil remedy for personal injuries", creates a private right of action fo
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