Epstein Secrets

atement 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

erson ..."). § 2423(b) is not such a statute. Federal court decisions watering down the "for the purpose of " requi ment fly in the face of the two Suprems Court decisions addressing that element. See Hansen'. Huff, 291 U.S. 559 (1934); Mortensen. United States, 322 U.S. 369 (1944). Santos and Cuellar speak l

"victims" until after Epstein was sentenced and incarcerated. 38. We have reason to believe that, around this same time, Mr. former law partner, Jeffrey Herman, had met with the father of one of the prospective plaintiffs, Saige Gonzalez.5 At the same time (and until as recent] as March of 2008), the Offici

st look like. Indeed, the Court made clear that it was not imposing a heightened pleading standard. As a general matter, I am loath to assume that the Supreme Court circumvented the normal channels for amending the Federal Rules. The Court’s “new standard” was merely a specific way to articulate a solution to

quest that Defendant’s Motion to Dismiss be denied in their entirety. Dated: October 31, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowit

is claim that would entitle him to relief" Id, (abrogating and quoting Conley v. 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

sel of record identified on the following Service List in the manner specified by CM/ECF on this 14th day of October, 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 Counsel for Plaintiff Jane Doe #2 Respectfully submitt B

S.Ct. 1955 (2007). In discussing Twomblv, the Eleventh Circuit in Watts v. Fla. International Univ., 495 F.3d 1289, 1295 (11th 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

l counsel of reco&identified on the f (lowing Service List in the manner specified by CM/ECF on this Nrday of T11O 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein Es counser or Kaustilt—Jane Doe #7 Respectfully submitted, By: ROBE JR., ESQ. BURMAN, CRITTON, LUTTIER & COLEMAN

s claim that would entitle him to relief." Id, (abrogating and quoting Conley v. 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

nsel of record identified on the following Service List in the manner specified by CM/ECF on this 6th day of October, 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger A

. 1955 (2007). In discussing Twombly, the Eleventh Circuit in Watts v. Fla. International Univ., 495 F.3d 1289, 1295 (11th 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

unsel of record entified on the following manner specified by CM/ECF on this/0 day of November 2008: Adam D. Horowitz, Esq. Jack Alan Goldberger Jeffrey Marc Herman, Esq. Atterbury Goldberger & Weiss, P.A. Stuart S. Mermelstein, Es Service List in the Counsel for Defendant Jeffrey Epstein Michael R. Tein, Es

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

nsel of record identified on the following Service List in the manner specified by CM/ECF on this sth day of October 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami. L 60 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A

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

sel of record identified on the following Service List in the manner specified by CM/ECF on this 6'" day of October, 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 60 Fax: Counsel for Plaintiff Jane Doe #3 Jack Alan Goldberger Atterbur

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

sel of record identified on the following Service List in the manner specified by CM/ECF on this 61h day of October, 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermeistein, Esq. 18205 Biscayne Boulevard Suite 2218 60 Fax: ahorowitzehermanlaw.com jhermanehermanlaw.com Iriveraehermanlaw

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

ff Jane Doe LEAD ATTORNEY ATTORNEY TO BE NOTICED represented by Adam D. Horowitz (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Jeffrey Marc Herman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Stuart S. Mermelstein (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICE