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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
Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isidrogarcia©bellsouth.net Coun
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
Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Bradley James Edwards [email protected] Isidro Manuel Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike MPike
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
ice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F [email protected] Coun
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
Bradley James Edwards [email protected] Isidro Manuel Garcia [email protected] Jack Patrick Hil
Entities connected to both Myers and Isidro Manuel Garcia

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Adam D. Horowitz
PERSONJack Patrick Hill
PERSONRichard Horace Willits
PERSONMichael J. Pike
PERSONKatherine W. Ezell
PERSONRobert D. Critton
PERSONRobert C. Josefsberg
PERSONMermelstein & Horowitz
ORGANIZATION
Alan Dershowitz
PERSON
Salt Lake City
LOCATIONJack Scarola
PERSON
Lake Worth
LOCATIONSouthern District
LOCATION
George W. Bush
PERSONScott Rothstein
PERSON