Epstein Secrets

s violation of 18 U.S.C. §2422, Plaintiff has suffered personal injury, including mental, psychological and emotional damages. 33. Plaintiff hired Mermelstein & Horowitz, P.A. (filda Herman & Mermelstein, P.A.), in this matter and agreed to pay them a reasonable attorneys' fee. WHEREFORE, Plaintiff Jane Doe No. 6 demands

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

f 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 Jane Doe No. 3 wherein she was sexually assaulted by Defendant Epst

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

Foundation is not listed on the building's directory, neither is Jessica Arbour, counsel who attended the subject IME, listed as an attorney on the Mermelstein & Horowitz, P.A. (M&H) website. Attached as Exhibit A is the "Attorneys" section of the M&H website, which noticeably fails to list Ms. Arbour. In addition, Ms. Ar

because the company was administratively dissolved in September 2009 should fall on deaf ears. It is clear that Mr. Horowitz knew, two weeks before Jane Doe #3's !ME, that Epstein's office was located at 250 Australian A venue. 1 7. Just as the Florida Science Foundation is not listed on the building's d

STATE OF FLORIDA ) SS: COUNTY OF MIAMI-DADE ) Jessica Arbour deposes and states as follows: 1. My name is Jessica Arbour. I am an attorney at Mermelstein & Horowitz, P.A., the law firm representing Jane Doe Nos. 2-7. 2. On or about March 12, 2010, I spoke with FBI Paralegal Specialist Deborah Moore at the FBI's Nor

rd Epstein between approximately 2006 and 2007. The statements we seek are those given to the FBI by our clients, each of whom has brought suit as a Jane Doe in the Southern District of Florida. The statements given to the FBI investigators are directly relevant because the FBI investigation concerned the

stein's violation of 18 §2422, Plaintiff has suffered personal injury, including mental, psychological and emotional damages. 33. Plaintiff hired Mermelstein & Horowitz, P.A. (ffIda Herman & Mermelstein, P.A.), in this matter and agreed to pay them a reasonable attorneys' fee. • WHEREFORE, Plaintiff.. Doe No. 6 demands j

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