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

te 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isidrogarcia©bellsouth.net Counsel .for:Plaintiff in Related Case No. 08- 80469 ' Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 riosefsb

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

st.com Michael James Pike [email protected] Paul G. Cassell [email protected] Richard Horace Willits [email protected] Robert C. Josefsberg [email protected] Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010 Page 10 of 10

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

e 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Counselfor·Plaintiff in Related Case No. 08- , 80469 • Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 riosefab

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

chard Horace Willits [email protected] Robert C. Josefsberg [email protected] Case 9:08-

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

the 12th claim by a young woman who also says she was lured to his Palm Beach mansion as a teen and sexually abused. Prominent Miami at- torney Robert Josefsberg filed the most recent federal lawsuit last week, on behalf of the Jane Doe 101 who allegedly visited Epstein a few times while 17 years old and