The plaintiff responds to Jeffrey Epstein's motion for partial summary judgment on Count I of the plaintiff's second amended complaint. Epstein argues there is no private right of action under various criminal statutes, but the plaintiff contends that these statutes are used to demonstrate Epstein's negligence and violation of standard care. The response argues that the statutes cited are designed to protect minors from sexual abuse, constituting negligence per se, and that the motion for summary judgment should be denied.
documents/EFTA00725918.pdf
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