Epstein Secrets

nd, in any event, not well founded, and therefore should be denied. Dated: September 22, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman ______ . Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected]

www.hermanlaw.com - 4 - SERVICE LIST DOE vs. JEFFREY EPSTEIN CASE NO.: 08-CV-80119-MARRA/JOHNSON United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Michael R. Tein, Esq. [email protected] Robert D. Critton, Esq. [email protected]

Rule 7.1.A.3, and all other relief this Court deems just and appropriate. Dated: July 18, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman ______ . Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected]

Palm Beach Circuit Court, State of Florida v. Jeffrey Epstein, Case No. 2006 CF 09454 AXXMB (Fifteenth Judicial Circuit, Palm Beach County), and in the Southern District of Florida, In re Grand Jury, No. FGJ 07-103 (WPB) (S.D. Fla.). The Motion to Stay as to the state court criminal action was rendered moot on June 30, 2008 wh

chael R. Tein Michael R. Tein Service List Jeffrey M. Herman, Esq. Stuart S. Mermelstein, Esq. Adam D. Horow

al Rules of the United States District Court for the Southern District of Florida, defendant Jeffrey Epstein respectfully requests

in New York, where he owns a 51,000-square-foot Manhattan mansion. "It's validation of what we're saying in the civil cases," said Miami attorney Jeffrey Herman, who represents the alleged victims in the federal lawsuits. West Palm Beach attorney Ted Leopold represents one alleged victim in a civil suit in

07. However, at the request of Epstein’s lawyers, the indictment was never presented to a federal grand jury. 22. Instead, then U.S. Attorney for the Southern District of Florida, Alexander Acosta, negotiated a plea deal with Epstein’s team of lawyers to grant immunity to Epstein (along with four named co-conspirators and an

us that you already have our May 19 and May 27 communications to the Deputy Attorney General, as well as our prior written submissions to CEOS and to the Southern District of Florida. In light of the significant volume of our prior submissions and to facilitate your review, we have drafted four supplemental submissions that will

victims” until after Epstein was sentenced and incarcerated. We have reason to believe that, around this same time, Mr. Sloman’s former law partner, Jeffrey Herman, had met with the father of one of the prospective plaintiffs, Saige Gonzalez.> At the same time (and until as recently as March of 2008), the Offici

a thorough investigation." (DE 407 at ¶ 93.) The January 10, 2008 notification letters did not disclose that the Jane Doe 1 and Jane Doe 2 case in the Southern District of Florida was the subject of the NPA entered into by Epstein and the Office, or that there had been any potentially binding resolution. (DE 407 at ¶ 94.) Othe

federal prosecution in favor of this state plea and sentence." (Sept. 3, 2008 letter, DE 363-66; (DE 407 at ¶ 148.) On September 16, 2008, attorney Jeffrey Herman, who represented several Epstein victims, wrote to the line prosecutor to object to the restitution procedures established in the NPA after learnin

a thorough investigation." (DE 407 at ¶ 93.) The January 10, 2008 notification letters did not disclose that the Jane Doe 1 and Jane Doe 2 case in the Southern District of Florida was the subject of the NPA entered into by Epstein and the Office, or that there had been any potentially binding resolution. (DE 407 at ¶ 94.) Othe

federal prosecution in favor of this state plea and sentence." (Sept. 3, 2008 letter, DE 363-66; (DE 407 at ¶ 148.) On September 16, 2008, attorney Jeffrey Herman, who represented several Epstein victims, wrote to the line prosecutor to object to the restitution procedures established in the NPA after learnin

the conduct escalated to full sexual intercourse. As part of the resolution of the case, Epstein has agreed that he would not contest jurisdiction in the Southern District of Florida for any victim who chose to sue him for damages pursuant to 18 USC 2255. Mr. Epstein agreed to provide an attorney for victims who elected to proceed

y Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights against self--excuse me, against--under the Constitution. And though your partner, Jeffrey Herman, was disbarred after filing this lawsuit [a statement that was untrue], Mr. Edwards! partner sits in jail for 21 HOUSE_OVERSIGHT_010586 --- PAGE B

e 12 HOUSE_OVERSIGHT_013330 --- PAGE BREAK --- discussions, on September 24, 2007, Epstein signed an agreement with the U.S. Attomney’s Office for the Southern District of Florida. Under the agreement, Epstein agreed to plead guilty to an indictment pending against him in the 15" Judicial Circuit in and for Palm Beach County ch

y Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights against self--excuse me, against--under the Constitution. And though your partner, Jeffrey Herman, was disbarred after filing this lawsuit [a statement that was untrue], Mr. Edwards' partner sits in jail for 21 HOUSE_OVERSIGHT_013339 --- PAGE B