Epstein Secrets

iscovery of documents falling within the scope of these two rules. Rule 410 was created to promote active plea negotiations and plea bargains, which our Supreme Court has acknowledged are "important components of this country's criminal justice system." ... Our Court of Appeals has held that "in order for plea bar

heir civil case, but to gain information to aid in the future prosecution of Epstein in direct violation of his Fifth Amendment rights. In fact, the Mermelstein and Horowitz firm was quoted in the Palm Beach Post stating, among other things, that the book sold to undercover agents could open the door to fut

his claim that would entitle him to relief." Id, (abrogating and quoting Conley Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme Court rejected the notion that "a wholly conclusory statement of claim [can] survive a motion to dismiss whenever the pleadings le[ave] open the possibili

Response to Motion, to Compel Answers to Interrogatories and Production of Documents by Jane Doe No. 4. (Attachments: # 1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/03/2009) 04/06/2009 71 Defendant's MOTION for Extension of Time to File Response as to 21 MOTION for Protective Order Agains

is claim that would entitle him to relief." Id, (abrogating and quoting Conley I. Gibson 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme Court rejected the notion that "a wholly conclusory statement of claim [can] survive a motion to dismiss whenever the pleadings le[ave] open the possibili

Response to Motion, to Compel Answers to Interrogatories and Production of Documents by Jane Doe No. 3. (Attachments: # 1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/03/2009) 04/06/2009 61 Defendant's MOTION for Extension of Time to File Response as to $1 MOTION for Protective Order Agains

s claim that would entitle him to relief." Id, (abrogating and quoting Conley I. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme Court rejected the notion that "a wholly conclusory statement of claim [can] survive a motion to dismiss whenever the pleadings le[ave] open the possibili

Response to Motion, to Compel Answers to Interrogatories and Production of Documents by Jane Doe No. 5. (Attachments: # 1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/03/2009) 04/13/2009 73 Unopposed MOTION for Extension of Time to File Response /Memorandum in Opposition to Motion to Stay a

re, .'s treatment records from the Parent-Child Center, Inc. and Dr. Serge Thys are protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee'. Redmond, 518 U.S. 1, 116 S.Ct. 1923 3 EFTA00182846 Case 9:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009

arcia Innle ' Katherine Warthen ell Michael James Pike Paul G Cassell Richard Horace Willits Robert C. Josefsberg Adam D. Horowitz Stuart S Mermelstein William J. Realer 11 EFTA00182843 Case 5:08-cv-80811-KAM Document 114 Entered on FLSD Docket 06/05/2009 Page 1 of 8 UNITED STATES DISTRICT CO

56 (11th Cir.2006). In discussing Twombly the Eleventh Circuit in Watts v. Fla. International Univ., 495 F.3d 1289, 1295 (111h Cir. 2007), noted - "The Supreme Court's most recent formulation of the pleading specificity standard is that 'stating such a claim requires a complaint with enough factual matter (taken a

to File Response /Memorandum in Opposition to Motion to Stay and/or Continue Action by Jane Doe No. 7. (Attachments: # 1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/13/2009) 04/14/2009 34 ENDORSED ORDER granting (75) Motion for Extension of Time to Respond re (65 in 9:08-cv-80119-KAM) De

s claim that would entitle him to relief." Id, (abrogating and quoting Conley I. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme Court rejected the notion that "a wholly conclusory statement of claim [can] survive a motion to dismiss whenever the pleadings le[ave] open the possibili

to 62 Response to Motion, to Compel Answers to Interrogatories and Production of Documents by Jane Doe. (Attachments: # 1 Text of Proposed Order) (Mermelstein, Stuart) (Entered: 04/03/2009) 04/06/2009 71 Defendant's MOTION for Extension of Time to File Response as to 66 MOTION for Protective Order and t

tatement reveals how inapposite a federal prosecution is to the facts in this case. Importantly, we note that the CEOS review was conducted prior to the Supreme Court’s very recent decisions in Santos and Cuellar, which we believe—illuminating as they do the Court’s interpretive methodology when it comes to federal c

med partner in Mr. Herman’s firm. See Tab 31, Florida Bar Website page. Mr. Herman, who is the named pariner in the former firm of Herman, Sloman, & Mermelstein, filed five lawsuits, each asking for $50 million, against Mr. Epstein. Each lawsuit is entitled “Jane Doe # vs. Jeffrey Epstein,” despite the fact t