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(bX6). 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- EFTA02743341