Epstein Secrets

intained an office at 250 Australian Avenue. 6. On November 10, 2009, two weeks before Jane Doe #3's IME, Adam Horowitz attended the deposition of Haley Robson at 250 Australian Avenue in which Epstein viewed the deposition from his office on the 14th floor. Thus, any argument that counsel did not know Eps

, Adam Horowitz attended the deposition of Haley Robson at 250 Australian Avenue in which Epstein viewed

Page 6 of 6 Jane Doe #2 v. Epstein Case No.08-CIV-80119 Epstein's Reply to Jane Doe #3 's Response to Epstein's Motion for Sanctions Page 6 of6 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

the Plaintiffs/victims were threatened and harassed. 3. As with other Plaintiffs, Jane Does 4 and 7 were first introduced to Defendant Epstein by Hayley Robson, who was a high school friend.1 4. Robson had had contact with these Plaintiffs on several occasions in which she represented to Plaintiffs Jane D

d. 3. As with other Plaintiffs, Jane Does 4 and 7 were first introduced to Defendant Epstein by Hayley Robson, who was a high school friend.1 4. Robson had had contact with these Plaintiffs on several occasions in which she represented to Plaintiffs Jane Doe 4 and 7 that she is cooperating with Defe

Plaintiffs’ attorneys of record for the duration of the Order. Dated: June 8, 2009 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ,

ing frames or wall frames. Request No. 14. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Haley Robson, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 15. Any and all docume

, or (3) when the patient raises and relies on the issue of his or her mental condition in litigation as part of any claim or defense. § 90.503(4); Roberson, 884 So.2d at 980; State v. Famiglietti, 817 So.2d 901, 903 (Fla. 3d DCA 2002). The privilege does not allow the invasion of a patient's privileged

e copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March, 2009. Adam D. Horowitz, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected] [email protected] Counse

ith inaccuracies and misstatements. For example, Haley Robson has not been asked to gather any information rela

case styled, Jane Doe v. Jeffrey Epstein, Haley Robson and Sarah Kellen, Case No. 502008CA006596XXXXMB A

frey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horo

ing frames or wall frames. Request No. 14. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Haley Robson, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 15. Any and all docume

, or (3) when the patient raises and relies on the issue of his or her mental condition in litigation as part of any claim or defense. § 90.503(4); Roberson, 884 So.2d at 980; State v. Famiglietti, 817 So.2d 901, 903 (Fla. 3d DCA 2002). The privilege does not allow the invasion of a patient's privileged

ue copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March 2009. Adam D. Horowitz, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ahorowitz(hermanlaw.com Irivera hermanlaw.com Counse

No. 2 v. Epstein Page 14 Request No. 14. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Haley Robson, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting

communications between Jeffrey Epstein and Haley Robson, including, but not limited to, letters, notes,

e copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 25th day of March, 2009. Adam D. Horowitz, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ahorowitzehermanlaw.com Iriveraahermanlaw.com Counse

rls in Florida, New York and on his private island, known as Little St. James, in St. Thomas. 9. An integral player in Epstein's Florida scheme was Haley Robson, a Palm Beach Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a wealthy man a massage for monetary comp

rida. She recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's plan, Ms. Robson would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf

Jeffrey M. Page 5 of 6 EFTA00313586 Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 7 of 7 Herman Adam D. Horowitz, Stuart S. Mermelstein, RICCI- 2925 P Palm B By: 33410 POLD, Esq. lorida Bar No 5608 Page 6 of 6 EFTA00313587

nd on his private island, known as Little St. James, in St. Thomas. 11. Epstein's scheme involved the use of young girls to recruit underage girls. Haley Robson, a Palm Beach Community College student from Loxahatchee, Florida recruited girls ostensibly to give a wealthy man a massage for monetary compensati

udent from Loxahatchee, Florida recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Ms. Robson, upon information and belief, generally sought out economically disadvantaged HERMAN 54 MERMELSTEIN, P. A. - 2 - wvm.hermanlaw.com 2 of EFTA0017

is action on all claims so triable. Dated: September i V , 2008 Respectfully su By: Jeffrey M. Herman (FL Bar No. 521647) ihermanftermanlaw.com Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) ahorowitzahermanlaw.com HERMAN & MERMELSTEIN, P.A. Attorneys for Plai

tate of Florida, the Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to wit: JENNIFER SICILIANO, HALEY ROBSON COURTNEY WILDE & DANIEL GONZALEZ Such oral examination will continue from day to day until completed. You are hereby notified to phone in and take

ia telephone, to wit: JENNIFER SICILIANO, HALEY ROBSON COURTNEY WILDE & DANIEL GONZALEZ Such oral exam

f the record in my office.0 THS—JM2422008 SHARON R. BOCK 2 C ER COMPTROLLER .I.ER EFTA00178247 ci HERMAN St MERMELSTEIN PA ATTORNEYS AT LAW Stuart S. Mermelstein Tel 305-931-2200 Fax 305-931-0877 [email protected] 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 www.hermanlaw.com March 31, 2008