Epstein Secrets

inary purposes does not in itself constitute abuse when it does not result in harm to the child as defined in s. 39.01. EFTA00194740 305-9312200 Herman &Mermelsteln, P 02:33:18 p.m. 01-06-2009 4/8 1,1; tali m UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CV-80802-Marra-Johnson JAN

im for damages. whether pursuant to state. federal or common law". Exhibit 2, NPA 1 8. More is required of a plaintiff than to simply allege, as did Jane Doc 101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended Complaint 1 24. Such an averment satisfies only the e

Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 25. Epstein's conduct caused severe emotional distress to Janc Doe. Epstein knew or had

were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 25. Epstein's conduct caused severe emotional distress to Janc Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional distress and damage to Jane Doe, or Epstein a

Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLI

305-9312200 Herman &Mermelsteln, P 03:04:45p.m. 02-04-2010 7/15 Doe No. 3 v. Epstein Page 6 11. Please identify your five closest friends for the years 2006 — 2010, including

Page 7 Plaintiff has not yet identified all of the witnesses she intends to call at trial. The witnesses who went to Epstein's residence include: Jane Doe No. 2 Address previously provided by Mermelstein & Horowitz, P.A., While still a minor, Jane Doe No. 2 was brought to Defendant Epstein's home by

ndant Epstein's home by his agent/employee to give him a massage wherein he sexually assaulted Jane Doe on at least one occasion. See transcript of Jane Doe's deposition. Ho ess unknown do Esq. Upon Information and belief, was brought or invited to Defendant Epstein's home by his employee and/66Nant

) exceeds $75,000, delusive of interest and costs; MERMEL.STEIN & HOROWITZ. P. A. loll - I - www.sexabuseattomey.com EFTA00183787 305-9312200 Herman &Mermelsteln, P 02:33:35 p.m. 01-06-2009 5/8 and (ii) is between citizens of different states. 6. Additionally, this Court has jurisdiction pursuant to 28

7th Floor Ft. Lauderdale, FL 33394 Re: B.B. I. JEFFREY EPSTEIN OUR FILE NO.: 080303 Dear Ms. As you are aware, this firm represents Plaintiff, Jane Doe, a/k/a/ B.B. in the civil litigation against Jeffrey Epstein styled Jeffiey Epstein. case no.: 502008CA037319 MB AB. We are hereby requesting that