Epstein Secrets

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

CM/ECF on thislZ day of April, 2010. Respectfully submitted, By I.Jlf,tE ROBERT '.cR.rfTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/84

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

ied by CM/ECF on this 141 day of April, 2010. Respectfully submitted, Br ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, a 33401 561/842

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

Isidro Manuel Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] Richard Horace Willits [email protected] Robert C. Josefsberg rjosefs

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

Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell cassell