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14681-XXXX-MB Div.: AG Plaintiff, v. DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida, Defendants. FIRST AMENDED COMPLAINT CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its First Amended Complaint against Dav
attorneyJeffrey Herman represents six young women who’ve sued Epstein, claiming he sexually abused them at his Palm Beach home when they were minors. Herman said he received a letter about the work-release program from the U.S. Attorney’s Office within the past few days. But Herman says Epstein had,been,
th offices located at 2751 S. Dixie Highway, West Palm Beach, Florida. 3. Defendant Joseph Abruzzo is the duly elected Clerk and Comptroller of Palm Beach County, Florida. He is sued herein in his official capacity as his office is in possession and/or control of documents that are the subject of this action
rney Jeffrey Herman represents six young women who've sued Epstein, claiming he sexually abused them at his Palm Beach home when they were minors. Herman said he received a letter about the work-release program from the U.S. Attorney's Office within the past few days. But Herman says Epstein had been
h fully set forth herein. 32. On or about the dates enumerated as to each count listed below, the exact dates A being unknown to the Grand Jury, Beach County, in the Southern District of Florida, and elsewhere, the Defendants listed below did knowingly, in and affecting interstate and foreign commerce, r
gs with the Florida Division of Corporations and/or the Florida Bar. On 08, at approximately 1:15 pm, I received a call from Jeffrey Herman of . Herman said that he was planning to file a civil lawsuit the next Confidential and Privileged— Attorney Work Product -12- EFTA00224647 week against Jeff
be sealed, according to a transcript of the hearing. And so it was. But Florida rules of judicial admin- istration, as well as rules of the Palm : Beach County court’ system, require | \ public notification that a court document | ' thas been or will be sealed, meaning kept | from public view. The rules also
torney Jeffrey Herman represents six young women who've sued Epstein, claiming he sexually abused them at his Palm Beach home when they were minors. Herman said he received a letter about the work-re- lease program from the US. Attorney's Office within the past few days. But Herman nder leaves . plea a
ger to stop Epstein and his attor- that Epstein and/or his coun- who was indicted by a Palm neys from 'continuous and' set arepurposefully attempt- Beach County grand jury in systematic harassment. ing to Jane Doe and July 2006 on a single count of The girl, identified in her mother," Leopold said in felo
court papers only as Jane Doe "It's like a sideshow" The girl turns 18 in May and can sue • again at that time without her parents' involvement, Herman said. Herman sued Epstein last month on • behalf of the girl, her father and her stepmother. Her birth mother, who lives near Atlanta, then asked
. S 34 EFTA00225249 (208) On or about January 1, 2005, Defendants JEFFREY EPSTEIN, a, and traveled from Anguilla, British West Indies tt item Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (209) On or about January 6, 2005, Defendant JEFFREY EPSTEIN traveled from Tet
ions and/or the Florida Bar. On Friday, January 18, 2008, at approximately 1:15 pm, I received a call from Jeffrey Herman of Herman & Mermelstein. Herman said that he was planning to file a civil lawsuit the next Confidential and Privileged — Attorney Work Product -12- EFTA00225189 r • week agains
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.:50 2009 CA 040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually,
Page: HOUSE_OVERSIGHT_010566 →lstein, filed the first civil action against Epstein on behalf of one of its seven clients who were molested by Epstein. The complaints that attorney Herman filed on behalf of his seven clients were similar in tenor and tone to the complaint that Edwards filed on behalf of his three clients. See id. 49.
Page: HOUSE_OVERSIGHT_010584 →IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, Vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M
Page: HOUSE_OVERSIGHT_013304 →wsuits against Epstein, other civil attorneys were filing similar lawsuits against Epstein. For example, on or about April 14, 2008 another law firm, Herman and Mermelstein, filed the first civil action against Epstein on behalf of one of its seven clients who were molested by Epstein. The complaints that
Page: HOUSE_OVERSIGHT_013337 →95 • 305-9312200 Herman &Mermelstein, P 04:23: • m. 31-03-2008 2 /5 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.: 502006CF009454AXXXMB STATE OF FLORIDA v. JEFFREY EPSTEIN, Defendant MOTION FOR PROTECTIVE ORDER COMES NOW, Witness Y. Doe,1
Page: Epstein_Part_12_Redacted_p42 →EIN, P.A. Attorneys for Witness Y. Doe 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 By: Jeffrey . Herman jherman@,hermanlaw.com Florida Bar No. 521647 Stuart S. Mermelstein ssm@,hermanlaw.com Florida Bar No. 947245 Adam D. Horowitz Florida Bar N
Page: Epstein_Part_12_Redacted_p44 →Entities connected to both Beach County and Herman

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSONJane Doe
PERSON
Alexander Acosta
PERSON
United States
LOCATION
Bradley Edwards
PERSONLeon Black
PERSON
Jeffrey Marc Herman
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSONFBI
ORGANIZATION
Palm Beach County
LOCATION
Scarlett Johansson
PERSONRoy Black
PERSON
Bill Clinton
PERSON