Plaintiff L.M. responds to Jeffrey Epstein's motion for partial summary judgment on Count I of her complaint, arguing that Epstein's motion should be denied. L.M. clarifies that she is not seeking a private right of action under criminal statutes but is using them to demonstrate Epstein's negligence and violation of standard care. The response outlines the legal basis for using criminal statutes as evidence of negligence per se and distinguishes the case from others cited by Epstein.
documents/EFTA01109699.pdf
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