Epstein Secrets

of $506,847.78 for 5 years of sexual harassment and sexual touching was reasonable). Unfortunately, the parties were unable to reach a agreement. Myers clearly demonstrates that Epstein's offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe

offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe as compared to the allegations in Myers. Moreover, allowing such discovery at this juncture goes against the grain and the law in that Plaintiff has not made a reasonable showing establish

9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 37 of 37 Doe v. Epstein 08-CV80119 Page No. 37 Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ssm@,sexabuseauornev.com

kes it clear that there is a compelling need for any net worth discovery not protected by the Fifth Amendment privilege. 5 Defendant relies upon Myers v. Central Florida Investment, Inc., 592 F.3d 1201 (11th Cir. 2010) for its “stipulation” argument. In Myers, however, the district court heard tes

Myers, however, the district court heard testimony regarding each of the defendant’s net worth. There was no unilateral statement of net worth in Myers as Defendant wishes to create in the instant case. To the extent that Defendant relies upon the Court’s holding in Myers regarding the reasonablen

: May 28, 2010. Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218 Miami,

ures. Such a stipulation more than satisfies any necessity for the disclosure of the tax returns or any additional net worth information. See e.g., Myers v. Central Florida Investments, Inc., 592 F.3d 1201 (I Ith Cir. 2010)(reasoning that a compensatory award of $103,622.09 and a punitive damage award

of $506,847.78 for 5 years of sexual harassment and sexual touching was reasonable). Unfortunately, the parties were unable to reach a agreement. Myers clearly demonstrates that Epstein's offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe

-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 37 of 37 Doe v. Epstein 08-CV80119 Page No. 37 Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected]

Amendment privilege. 5 Defendant relies upon Myers v. Central Florida Investment, Inc., 592 F.3d 120

here was no unilateral statement of net worth in Myers as Defendant wishes to create in the instant case

(FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected]