Case 9:08-cv-80994-KAM Document 10 Entered on FLSD Docket 11/10/2008 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80994-MARRa JANE DOE NO. 6, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION TO DISMISS & FOR MORE DEFINITE STATEMENT Defendant, JEFFERY EPSTEIN, (EPSTEIN), by and through his undersigned attorneys, files his reply to Plaintiffs' Memorandum Of Law In Opposition To Motions To Dismiss, dated October 31, 2008, and states: Although Plaintiffs, Jane Doe Nos. 2 through 7, are separate and distinct persons, in separate and distinct actions, with separate and distinct facts and circumstances pertaining to the claims each is attempting to allege, Plaintiffs' counsel has filed a broad brush, identical response to Defendant's motions to dismiss and for more definite statement which were filed in each of the actions. As pointed out in Defendant's previously filed motions, there are factual distinctions in the actions and the allegations in Plaintiffs' attempts to assert the claims labeled as Count I — "Sexual Assault and Battery," and Count III - "Coercion and Enticement to Sexual Activity In Violation of 18 U.S.C. §2422." It is essential that each of the actions and the respective complaints filed therein are examined and treated as separate and distinct actions in deciding the respective legal issues and positions asserted. EFTA02742627