Epstein Secrets

iv.P. 55(a); and such other and further relief as this Court deems proper. Dated: June 24, 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] A

P. A. www.hermanlaw.com - 2 - response as Exhibit “A” the Affidavit of Richard Barnett, who claims to have received the copies of the Summons and Complaint on May 7, 2008 at Defendant Epstein’s residence. In this Affidavit, Mr. Barne

rnett, who claims to have received the copies of the Summons and Complaint on May 7, 2008 at Defendant Epstein’s residence. In this Affidavit, Mr. Barnett states very little. He asserts that he does not now, nor has he ever, resided at 9 E. 71st Street, New York, New York (Mr. Epstein’s residence). H

ng CM/ECF. I also certify that the foregoing document is being served this day on counsel of record identified below by facsimile and U.S. Mail. Jeffrey M. Herman, Esq. Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Herman & Mermelstein, P.A. 18205 Biscayne Blvd, Suite 2218 Miami, Florida 33160 Fax:

and Procedural History 1. On May 7, 2008, service was delivered at defendant Epstein’s house located at 9 East 71st Street, New York, New York, to Richard Barnett, an employee. 2. Mr. Barnett does not reside at that address. See Affidavit of Richard Barnett (attached as Ex. A). 3. Upon the plaintiff

, service was delivered at defendant Epstein’s house located at 9 East 71st Street, New York, New York, to Richard Barnett, an employee. 2. Mr. Barnett does not reside at that address. See Affidavit of Richard Barnett (attached as Ex. A). 3. Upon the plaintiff’s motion,2 the Clerk of Court den

Jane Doe No. 3. Replies due by 7/28/2008. (Attachments: # 1 Exhibit A)(Herman. Jeffrey) (Entered: 07/18/2008) 07/21/2008 21 AFFIDAVIT signed by : Jeffrey M. Herman. re 17 Order to Show Cause and Service of Process by Jane Doe No. 3. (Herman, Jeffrey) (Entered: 07/21/2008) 07/25/2008 22 MOTION for Hearing Def

ON for Entry of Default by Clerk Against Defendant Jane Doe No. 3 filed by Jeffrey Epstein. Replies due by 6/23/2008. (Attachments: # 1 Affidavit of Richard Barnett) (Goldberger, Jack) (Entered: 06/13/2008) Defendant's MOTION to Stay by Jeffrey Epstein. Responses due by 7/10/2008 (Goldberger, Jack) (Entered: 0

sing CM/ECF. I also certify that the foregoing document is being served this day on counsel of record identified below by facsimile and U.S. Mail. Jeffrey M. Herman, Esq. Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Herman & Mermelstein, P.A. 18205 Biscayne Blvd, Suite 2218 Miami, Florida 33160 Fax: 3

08, service was delivered at defendant Epstein's house located at 9 East 71st Street, New York, New York, to Richard Barnett, an employee. 2. Mr. Barnett does not reside at that address. See Affidavit of Richard Barnett (attached as Ex. A). 3. Upon the plaintiff's motion,2 the Clerk of Court denied

Jane Doe No. 4. Replies due by 7/28/2008. (Attachments: # 1 Exhibit A)(Herman. Jeffrey) (Entered: 07/18/2008) 07/21/2008 32 AFFIDAVIT signed by : Jeffrey M. Herman. Regarding Service of Process and This Court's Order to Show Cause by Jane Doe No. 4. (Herman, Jeffrey) (Entered: 07/21/2008) 07/25/2008 33 MOTIO

of Jeffrey Epstein (Goldberger, Jack) (Entered: 06/13/2008) MOTION to Set Aside Clerk's Default by Jeffrey Epstein. (Attachments: # 1 Affidavit of Richard Barnett) (Goldberger, Jack) (Entered: 06/13/2008) RESPONSE in Opposition re 7 Plaintiff's MOTION for Judgment Upon Default and Order Setting Hearing on Da