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

691 [email protected] Co-Counsel for Defendant Jeffrey Epstein Respectfully submitted, By: Isl Michael J. Pike ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Driv

states that she attended De Paul law school and was admitted to practice in 2009. 8. Although it is uncertain exactly when Ms. Arbour joined M&H, the Florida Bar News announced that she joined the firm in its October 15, 2009 edition of "On the Move" (attached as Exhibit C), which was just over one month bef

would know when. he was in town. They concluded that Epstein paid girls $:200 to $300 each atter the massage sessicm·s. 'Tm like a, Heidi fl~iss," Haley Robson., now 22, told police abou.ther efforts in recruiting girl's Jor Epstein. There was p·roba:ble cause to charge Epstein with unlawfoi sex acts with

r-old girl to Epstein’s house was Haley Robson, a Palm Beach Community College student from Loxahatchee. In a sworn statement at police headquarters, Robson, then 18, admitted she had taken at least six girls to visit Epstein, all between the ages of 14 and 16. Epstein paid her for each visit, she said. D

le, Suite 400 Boca Raton, Florida 33486 Telephone: (561) 955-7629 Facsimile: (561) 338-7099 By: Isl Stephen A. Mendelsohn STEPHEN A. MENDELSOHN Florida Bar No. 849324 [email protected] [email protected] [email protected] By: Isl Michael J G,ygiel MICHAEL J GRYGIEL (Admitted Pro Hae Vice) 54 S

erything: Jeffrey Epstein Craved Big Homes, Elite Friends and, Investigators Say, Underage Girls.,” published on August 14, 2006, reporting that: Haley Robson, a local community college student, admitted in a sworn statement to police that “she had taken at least six girls to visit Epstein, all between the

or and to charge his personal assistanti Sarah Kellen, now 27i for her alleged role in arranging the visits. Police officials also wanted to charge Robsoni the self-described Heidi Pleiss, with lewd and lascivious acts. By theni the department was frustrated with the way the state attorney's office had

le, Suite 400 Boca Raton, Florida 33486 Telephone: (561) 955-7629 Facsimile: (561) 338-7099 By: /s/ Stephen A. Mendelsohn STEPHEN A. MENDELSOHN Florida Bar No. 849324 [email protected] [email protected] [email protected] By: /s/ Michael J Grygiel MICHAEL J GRYGIEL (Pro Hac Vice applicat

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, a/k/a JANE DOE #1, Plaintiff, vs. JEFFREY EPSTEIN, HALEY ROBSON, and SARAH KELLEN, Defendants. NOTICE OF REMOVAL July 18, 2008 STEVEN M. LARIMORF CLERK D.S. DIST. CT. S.O. OF FLA. • MIAMI In accordance wit

lez, Case No. 50 2008 DR 001141 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there is complete diversity, regardless of Robson's citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circu

25 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 nsor & Associates Reportiny and lranscrirrix, inc Page 48 1 Florida Bar? 2 A. I did not select him. 3 Q. Who did? 4 A. My father. 5 Q. Did you ever meet Mr. Herman? 6 A. Once. 7 Q. Don't don't tell me w

ed one. Epstein's attorneys actually made these baseless allegations in depositions and other court filings. (See, e.g., Jane Doei Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- Marra/Johnson, DEl at 44-52.) 42 08-80736-CV-MARRA 000861 EFTA00230685 fmney,'" Case 9:08-cv-8

gs. (See, e.g., Jane Doei Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- M

aintiffs. Without attempting to make any connection to the asserted violation of the CVRA, Paragraphs 52 and 53 falsely allege that Movant violated Florida Bar rules and Department of Justice regulations by representing Epstein's employees in civil litigation after Movant retired from the United States Att

telephone. computer or any other facility of interstate commerce, hut rather in a nate-to-face discussion with a third party who was her friend (Ms. Robson) and who told her to lie to Mr. Epstein about her age. As such, it is simply impassible to shoehorn this conduct into any of the above-discussed fe

y extended period, and there is no basis for your assertion that the judge is the cause of any past or future delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is rat an adequate basis for delay. Three weeks ago I also asked you to provide our Office with

subject case now under consideration by the SDFL. Recently, I learned that there is a reference to the law firm of "Herman Sluman & Mermelstein" on the Florida Bar website, under a section called "Find A Lawyer." This reference appears when Stuart Mennelstein's name and information is accessed. To reiterate, s

3031340, 600:00.rt 64064, 10:0100 33133 301316 EFTA00180409 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 4 of 100 Robson, besides having nothing to do with the substantive allegations of the plaintiff's $50,000,000 case, is a community-college student with no assets w

e 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 nsor & Associates ReparlillS and 1.71111Gliptill11. Inc. Page 48 1 Florida Bar? 2 A. I did not select him. 3 Q. Who did? 4 A. My father. 5 6 7 8 with him. Where did you meet him? 9 10 friend's house. 11 12 13

telephone, computer or any other facility of interstate commerce, but rather in a face-to-face discussion with a third party who was her friend (Ms. Robson) and who told her to lie to Mr. Epstein about her age. As such, it is simply impossible to shoehorn this conduct into any of the above-discussed fe

3 FAX 305 630 8440 EXECUTIVE OFFICE JAY P. LEEKOWITZ, ESQ. DECEMBER 6, 2007 PACE 2 OF 4 any past or figure delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay. Three weeks ago I also asked you to provide our Office with

d 1 protection team; the Peace at Home award, presented by Gover- _ i for his work with victims of family violence: a life- : q chievement award from the Florida Bar. He was a board oo of the National District Attorneys Association. And he 4 Sos necessarily ais to going after the rich and powerful. ; 3, he launche

ne Highway West Palm Beach, FL 33401 Oear Mr. Krischer, Please find enclosed the probable c; resulting from the Patm Beach Police Depa Kellen and Haley Rooson The submissio Assistant State Atloney Lanna @gioniaved Beach Police Department's presentation fc know that you agree that it is our public interest