Plaintiff L.M. responds to Jeffrey Epstein's motion for partial summary judgment on Count I, arguing that Epstein misinterprets the use of criminal statutes in her tort action. L.M. is not seeking a private right of action under these statutes but is using them to demonstrate Epstein's negligence and violation of standard care. The response argues that the statutes cited are designed to protect minors from harm and that their violation constitutes negligence per se. The response distinguishes this case from others cited by Epstein, emphasizing that a cause of action for sexual assault exists at common law and does not need to be judicially implied from statutes.
documents/EFTA00727755.pdf
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