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Case 9:09-cv-80802-KAM Document 13 Entered on FLSD Docket 08/12/2009 Page 1 of 10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-CV-80802-MARRA/JOHNSON
JANE DOE NO. 8,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
____________________________________/
PLAINTIFF JANE DOE NO. 8’s MEMORANDUM OF LAW IN
OPPOSITION TO MOTION TO DISMISS PLAINTIFF’S COMPLAINT
Plaintiff, Jane Doe No. 8, submits this Memorandum of Law in Opposition to Motion to
Dismiss Plaintiff’s Complaint, pursuant to S.D.Fla.L.R. 7.1(C), as follows:
INTRODUCTION
As with the related cases in this Court against Defendant Jeffrey Epstein, Plaintiff Jane Doe
No. 8 alleges that she was the victim of a plan and scheme by Defendant Epstein to lure her to his
Palm Beach mansion, where he sexually molested her. The Complaint in this case sets forth state
law claims and a federal law claim under 18 U.S.C. §§2422 and 2255. Defendant relies exclusively
on the statute of limitations as grounds for dismissal pursuant to Fed.R.Civ.P. 12(b)(6).
With respect to Plaintiff’s state law causes of action for assault and battery, Defendant
incorrectly applies a four-year statute of limitations. Florida Statute §95.11 is clear that a seven-year
statute of limitations applies to the state law claims alleged by Plaintiff. As a result, the state law
cause of action for assault and battery is timely.
In contending that Plaintiff’s federal claim should be dismissed based on the statute of
-1-
Case 9:09-cv-80802-KAM Document 13 Entered on FLSD Docket 08/12/2009 Page 2 of 10
limitations, Defendant wrongly assumes that this claim accrued on the date when Defendant’s
wro
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