📧 Communication

This document is a legal response filed on June 26, 2009, by the attorneys for Plaintiff Jane Doe No. 101 in the case against Jeffrey Epstein. The Plaintiff argues against Epstein's motion to dismiss, specifically contesting his claim that multiple violations of sexual exploitation statutes should be merged into a single count with a single penalty. The response asserts that 18 U.S.C. § 2255 allows for separate civil remedies and damages (minimum $150,000) for each distinct violation of a predicate offense.