Epstein Secrets

1308065 COUNT II Intentional Infliction of Emotional Distress 21. Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother, individually, repeat and rcallege paragraphs 1 through 16 above. 22. Epstein's conduct was intentional or reckle

ww.hermanlaw.com SDNY_GM_00328643 EFTA_00201395 EFTA01308071 24. As a direct and proximate result of Epstein's intentional or reckless conduct. Jane Doc, has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE. Plaintiff Jane Doe No. 2 demands judgment against Defendant Jef

would cause emotional trauma and damage to Jane Doe's parents. 25. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiffs Jane D

island, known as Little St. James, in St. Thomas. 12. An integral player in Epstein's Florida scheme was IMM, a Palm Beach HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com SDNY_GM_00328635 EFTA_00201387 EFTA01308063 She recruited girls ostensibly to give a wealthy man a massage for monetary compen

2728833 COUNT II Intentional Infliction of Emotional Distress 21. Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother, individually, repeat and reallege paragraphs 1 through 16 above. 22. Epstein's conduct was intentional or reckle

would cause emotional trauma and damage to Jane Doe's parents. 25. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiffs Jane D

of Florida. She is a minor under the age of 18 years. 2. Jane Doe's Father brings this action individually and as parent and natural guardian of Jane Doc. Jane Doe's Father is a citizen and resident of the State of Florida. 3. Jane Doe's Stepmother brings this action individually. Jane Doe's Stepmoth

known as Little St. James, in St. Thomas. 12. An integral player in Epstein's Florida scheme was Haley Robson, a Palm Beach HERMAN & MERMELSTEIN, P. A. 09/12/2019 - 2 - 71 1ge 1 CONFIDENTIAL vAwthermanlaw.com Agency to Agency Requet: 19-411 SDNY_GM_00330201 EFTA_00202927 EFTA02728831 Comm

tted willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 26. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had

act, and Jane Doe was thereby put in such imminent apprehension. 17. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane Poe, creating a reasonable fear of imminent peril. 18. Epstein intentionally inflicted harmful or offensive contact on the person &Jane Doe, with the

e experienced confusion, shame, humiliation and embarrassment, and has suffered severe psychological and emotional injuries. HERMAN E. MERMELSTEIN, P. A. COUNT I Sexual Assault and Battery - 3 - EFTA00175886 Case 9:08-cu _J381-KAM Docurneri. , Enters. on FLSD Docket 09/22. Page 4 of 8 15. Plai

FREY M. HERMAN STATE OF FLORIDA ) SS: COUNTY OF MIAMI-DADE Jeffrey M. Herman, deposes and states as follows: 1. I am the attorney of record for Jane Doe No. 2, and have knowledge of the status and history of this case. 2. The Complaint filed in this action alleges that Defendant Epstein is a financ

The filing of Jane Doe No. 2's case received extensive press coverage, as did a prior related case filed on January EXHIBIT HERMAN S. MERMELSTEIN, P. A. A www.hermanlaw.com EFTA00222595 Case 9:08-cv-80119-KAM Document 9-2 Entered on FLSD Docket 06/11/2008 Page 2 of 5 24, 2008 making similar all

TO ENTER DEFAULT AGAINST DEFENDANT, OR ALTERNATIVELY, FOR AN ENLARGEMENT OF TIME TO SERVE PROCESS, AND INCORPORATED MEMORANDUM OF LAW Plaintiff, Jane Doe No. 2, by and through her undersigned counsel, and pursuant to Federal Rules of Civil Procedure 55(a) and 4(m), and S.D. Fla. L.R. 7.1, hereby files

erve the Defendant with process ran on June 5, 2008, one day before the Clerk denied Plaintiff's Motion for Entry of Default. HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com -4- EFTA00222612 Case 9:08-cv-80119-KAM Document 9 Entered on FLSD Docket 06/11/2008 Page 5 of 7 Order compelling the Clerk t

012635 TAB 32 HOUSE_OVERSIGHT_012636 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 20069 " JANE DOE NO. 1, by and through JANE DOE’s FATHER as parent and natural guardian, and JANE DOR’s FATHER, and . . JANE DOE’s STEPMOTHER, individually, ciV-MA RRA Plaintiffs, MAGISTRATE JUDGH

to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this District. ] HERMAN & MERMELSTEIN, P. A. www.hermaniaw.com | 10f6 HOUSE_OVERSIGHT_012644 ; Case 9:08-cv-80232-KAM Document1 Entered on FLSD Docket 03/05/2008 Page 2of6 i Factual Allegat