Epstein Secrets

lclaw.com Paul G. Cassell [email protected] Richard Horace Willits [email protected] Robert C. Josefsberg rjosefsbe rg@pod h u rst.com Adam D. Horowitz [email protected] Stuart S. Mermelstein [email protected] William J. Berger [email protected] 21 Case 9:08-cv-80119-KA

ut Jeffrey Epstein, he is a billionaire and owner of a private island in the Virgin Island (Little St. James Island), and was a financial trader at Bear Steams. He then founded his own financial management firm, J. ..-- EXHIB\1 ~ Case 9:08-cv-80119-KAM Document 165 Entered on FLSD Docket 06/19/2009

s and Emery Air Freight. 6. According to the Vanity Fair article, before working with Wexner and Hoffenberg, defendant Jeffrey Epstein worked with Beam Stearns. He left the firm very suddenly in 1981 after being questioned by S.E.C. investigators in an insider trading scandal involving several Italian and

of24 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. 401 East Las Olas Boulevard 18205 Biscayne Boulevard Suite 1650 Suite 2218 Fort

to Jane Doe's Injunction Motion Page 7 of24 Italian and Swiss investors. Id. '1[6. This statement is obviously intended to associate Epstein with Bear Sterns, a tarnished financial institution apparently involved in questionable international transactions in the 1980's, to somehow suggest Epstein is frau

wenty-eight years ago, in 1981, and that Epstein was merely questioned because the SEC believed "Epstein had information on insider trading at Bear Sterns." The foregoing assertions in Mr. Cassell's affidavit have absolutely no bearing on Jane Doe's Injunction Motion. Then, Mr. Cassell goes beyond the

2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami, F

AM Document 81 Entered on FLSD Docket 04/20/2009 Page 4 of 11 potential sources of information and to produce those sources.” Id. at 41. In Bear Sterns, the Court explained that the facts of Hubbell were unique and do not support a blanket, all-encompassing assertion by a witness or party that the

declares that in so doing he would incriminate himself; his assertion does not of itself establish the hazard of incrimination. Id. at 684. In Bear Sterns, the Court found that the defendant failed to meet his burden in asserting the privilege against self-incrimination in response to a request for pro

f 24 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. Counsel for Plaintiff in Related Case No. 08-80893 ounse or amttj s In related Ca

his untenable connection. Similarly, Mr. Cassell states that Epstein was questioned by the SEC in 1981 regarding an insider trading investigation at Bear Steams involving EFTA00221934 Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07/13/2009 Page 7 of 24 Jane Doe v. EDSICia Case No. 08-CV-

tely twenty-eight years ago, in 1981, and that Epstein was merely questioned because the SEC believed "Epstein had information on insider trading at Bear Sterns." The foregoing assertions in Mr. Cassell's affidavit have absolutely no bearing on Jane Doe's Injunction Motion. Then, Mr. Cassell goes beyond the

Dated: April 20, 2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami,

ertain records sought in the government's subpoena would be directly incriminating. Hubbell, 167 F.3d at 582. Id. at 683. As noted by the Court in Bear Sterns, a determination that the production of documents would be testimonial cannot be premised on the witness's say so: A witness is not exonerated from