UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80993-MARRA-JOHNSON JANE DOE NO. 7, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION FOR SUMMARY JUDGMENT, INCLUDING SUPPORTING MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, seeks summary judgment determining that under the undisputed material facts, (1) the version of 18 U.S.C. §2255, effective 1999 to Jul. 26, 2006, the period of time during which EPSTEIN's alleged conduct occurred, applies to Plaintiff JANE DOE NO. 7's claim brought pursuant to §2255 in Count III of the Amended Complaint [D.E. 19]; (2) Plaintiff has failed to and cannot establish a predicate act — under 18 U.S.C. §2422 as plead in her complaint, in order to state a cause of action pursuant to 18 U.S.C. §2255 (2004); (3) 18 U.S.C. §2255 allows for a single recovery of the presumptive minimum damages amount against a single Defendant, and not a multiplication thereof based on the number of statutory predicate act violations; and (4) the version of 18 U.S.C. § 2255 in effect when the predicate acts allegedly were committed allow only "minors" to file suit. Rule 56, Fed.R.Civ.P. (2010); Local Gem Rules 7.1, and 7.5 (S.D. Fla. 2010). In support of his motion, Defendant states: Introduction EFTA01100005