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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
ads). Finally, at the deposition of Detective Recarey of the Palm Beach Police Department, on March 19, 2010, the following exchange occurred: Mr. Kuvin: Okay. And what were the dates of the surveillance? Witness: [Referencing his Report] It appears she met with members of the B.S.F. unit, Burglary
st which delineates alleged victims. Once the NPA was made public, Judge Colbath, with the agreement of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private. As such, Request for Production Numbers 7, 9 and 10 seeks information that may violate others thi
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
ads). Finally, at the deposition of Detective Recarey of the Palm Beach Police Department, on March 19, 2010, the following exchange occurred: Mr. Kuvin: Okay. And what were the dates of the surveillance? Witness: [Referencing his Report] It appears she met with members of the B.S.F. unit, Burglary
t of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private
ar-old Jason Roden of Loxahatchee. "He was a wonderful boy, and he did a lot for 111 ;29.9.3 • Absolut Vodka I Three Olives • -- '24.99 Myers Platinum Rum $1659 $ Chivas — Regal '49.99 The I $ , Macallan J‘. • 39.99 g Early lime • Canadian Mist .. 46.99 Wild Turkey '29
o federal grand jury proceedings, which are secret and protected by federal rules. A federal judge should decide the issue, he said. Attorneys Spencer Kuvin and Brad Edwards, who represent some of the women now suing Epstein, both said they were not surprised by Epstein's at- torney moving to appeal.
decide the issue, he said. Attorneys Spencer Kuvin and Brad Edwards, who represent some of the wom
ALM BEACH COUNTRY CLUB SMITH,PAGE W MYERS,RICHARD ROONEY,TIMOTHY J ROGER DEAN
MCDONALD,JOHN R BREKUS,GORDON L KUVIN,SANFORD F HARRINGTON,RICHARD L VILL
Entities connected to both Myers and Spencer Kuvin

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSON
George W. Bush
PERSON
Palm Beach Gardens
LOCATIONJack Scarola
PERSONScott Rothstein
PERSONRobert D. Critton
PERSONRobert C. Josefsberg
PERSONMichael J. Pike
PERSON
Ghislaine Maxwell
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSONKatherine W. Ezell
PERSON
Alan Dershowitz
PERSONRichard Horace Willits
PERSON
Sarah Kellen
PERSONIsidro Manuel Garcia
PERSON
United States
LOCATION