Epstein Secrets

Entered on FLSD Docket 08/11/2009 Page 5 of 15 discussed Jeffrey Epstein with her in a public forum, l.e., Jane Doe 7 discussed her lawsuit with Haley Robson in public, with others. See Exhibit "A". Even so, an elementary review of the alleged questioning by the investigators as set forth in Jane Doe 7'

t. (Declaration, DE 251-2, 15). Moreover, Haley Robson's affidavit tells a different story; that is, Ja

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 3160 305-931-2200 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulev

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

Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: (305) 931-2200 Fax: (305) 931-0877 5

, 48, 52, 56, 61, 65, and 69, Comp., DE I. Jane Doe 101 and 102 came to Defendant's home on a number of occasions. Jane Doe 101 brought her friend, Haley Robson (referenced by name in a number of actions) to experience this same "trauma" - it does not make sense. Jane Doe 101 had issues associated with law e

ccasions. Jane Doe 101 brought her friend, Haley Robson (referenced by name in a number of actions) to ex

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 33160 305-931-2200 Fax: 305-931-0877 [email protected] [email protected]

limited without violating Epstein's constitutional due process rights to defend himself. 15. Next, Jane Doe #7 claims that investigators mentioned Haley Robson, but fails to state what references were made relative to Haley Robson. Is it Jane Doe #7's contention that investigators cannot ask others whether

ussed Jeffrey Epstein with her in a public forum, i.e., Jane Doe #7 discussed her lawsuit with Haley Robson in public, with others. See Exhibit "I", Robson Affidavit. Even so, an elementary review of the alleged questioning by the investigators as set forth in Jane Doe #7' s declaration shows that same

4 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 33160 305-931-2200 Fax: 305-931-0877 [email protected] [email protected]

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

art S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miam

on as part of any claim or defense. § 90.503(4); Roberson, 884 So.2d at 980; State v. Famiglietti, 817 So.

art S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miam

diction. (b) There is no ossibili that the plaintiff can establish a cause of action against under Florida law. (i) The conspiracy claim against Robson must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 44

HEARING BEFORE THE HONORABLE KENNETH A. MARRA, 12 UNITED STATES DISTRICT JUDGE APPEARANCES: 13 14 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 18205 Biscayne Boulevard Miami, FL 33160 16 For Jane Doe 17 BRADLEY J. EDWARDS, ESQ. Rothstein Rosenfeldt Adler 18 401 East Las Olas Bou