Epstein Secrets

ir article (the "2005 Vanity Fair Article"). See Vicky Ward, "The Talented Mr. Epstein," Vanity F

knowledge. The majority of Mr. Cassell's assertions in his affidavit are based on a 2005 Vanity Fair article (the "2005 Vanity Fair Article"). See Vicky Ward, "The Talented Mr. Epstein," Vanity Fair chttp://vickyward.com/wordpress/archives/30> (January 24, 2005; accessed June 24, 2009). Mr. Cassell

cle (the "2005 Vanity Fair Article"). See Vicky Ward, "The Talented Mr. Epstein," Vanity Fair c

sition to Jane Doe's Injunction Motion Page 23 of 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

published source of information about defendant Jeffrey Epstein that I have been able to locate is an article that was published in Vanity Fair by Vicky Ward. Vicky Ward is a contributing editor to Vanity Fair, a contributor to CNBC, and a weekly columnist for the London Evening Standard. The article can

pstein was moving all of his considerable assets to Israel. The note also indicated that, having written the earlier detailed article about Epstein, Ward was now frequently viewed as an "expert" on Epstein. 9. According to reputable press reports, Jeffrey Epstein has travelled internationally with D

an article that was published in Vanity Fair by Vicky Ward. Vicky Ward is a contributing editor to Vani

com Richard Horace Willits [email protected] Robert C. Josefsberg [email protected] Adam D. Horowitz ahorowitz sexabuseattomev.com Stuart S. Mermelstein ssmsexabuseattornev.com William J. Berger [email protected] 21 EFTA00234891 Case 9:08-cv-80119-KAM Document 165 Entered on FLSD Docket 06/

published source of information about defendant Jeffrey Epstein that I have been able to locate is an article that was published in Vanity Fair by Vicky Ward. Vicky Ward is a contributing editor to Vanity Fair, a contributor to CNBC, and a weekly columnist for the London Evening Standard. The article can

an article that was published in Vanity Fair by Vicky Ward. Vicky Ward is a contributing editor to Vani

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-KAM Document 165 Entered on FLSD Docket 06/19/2009

claims or that if she did such a compensatory damage recovery could possible implicate punitive damages in excess of Epstein's offer to stipulate.. Ward v. Estalciro Itajai S/A. 541 F.Supp.2d 1344. 1357 (S.D. Fla. 2008)(The court cannot apply Rule 26 and allow Plaintiff to obtain discovery she seeks

/JOHNSON EFTA00317246 Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 37 of 37 Doe v. Epstein 08-CV80119 Page No. 37 Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877

MIOIAEL PIKE HEATHER McNAMARA RUDA I R.ORIDA WARD anima CIVIL TRIAL LAWYER BURMAN, CRITTON, LUTTI

being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this day of , 2009: Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected] Irive

acted in bad faith in refusing to move for down- ward departure, the Government may then rebut the all

t 06/10/2009 Page 7 of 8 Doe 101 v. Epstein Page 7 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami FL 3 160 Fax: ssmasexabuseattomev.com Coun