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Case 9:09-cv-80802-KAM Document 15 Entered on FLSD Docket 08/20/2009 Page 1 of 10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-CV-80802-MARRA-JOHNSON
JANE DOE NO. 8
Plaintiff,
V.
JEFFREY EPSTEIN,
Defendant.
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DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM OF LAW IN
OPPOSITION TO MOTION TO DISMISS PLAINTIFF'S COMPLAINT. dated 08/12/09
Defendant EPSTEIN, by and through his attorneys, replies to Plaintiff JANE DOE
No. 8's Memorandum of Law in Opposition to Motion to Dismiss Plaintiff's Complaint,
("memorandum"), dated August 12, 2009. In support of dismissal of Count I - "Sexual
Assault and Battery" and Count Ill - "Coercion and Enticement to Sexual Activity in
Violation of 18 U.S.C. §2422," based on the statute of limitations, Defendant replies:
Introduction
Defendant's position is that Counts I and Ill are each barred by the applicable
statute of limitations. Since the issues in parts I and II of Plaintiff's memorandum
overlap, Defendant will address those parts together in I and II herein. Part Ill
addresses the statute of limitations for Count Ill, as set forth in 18 U.S.C. §2255{b).
I. Plaintiff's Complaint on its face does show the date that her claims accrued.
II. Based on the Complaint allegations. §95.11 (7). Fla. Stat .• does not apply to
Count I - Assault and Battery; thus, such claim is time barred.
Pursuant to the allegations on the face of Plaintiff's complaint, Count I, based on
Florida's common law of assault and battery, and Count Ill, brought pursuant to 18
Case 9:09-cv-80802-KAM Document 15 Entered on FLSD Docket 08/20/2009 Page 2 of 10
Jane Doe No. 8 v. Epst
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