Epstein Secrets

HAEL). PIKE HEATHER MCNAMARA RUDA DAVID YAREMA 1FLORIDA BOARD CERTIFIED CIVIL TRIAL LAWYER. 2ADMITTED TO

IED CIVIL TRIAL LAWYER. 2ADMITTED TO PRACTICE IN FLOR.I DA AND COLORADO Sent by E.Mail and U.S. Mail Stuar

DATE &TIME Jane Doe #4 September 16, 2009 c/o Mermelstein & Horowitz PA at 1:00 PM 18205 Biscayne Bouleva

ne Doe's Mother brings this action individually and as parent and natural guardian of Jane Doe No. 1. Jane Doe's Mother is a citizen and resident of the State of Georgia. EFTA00313582 Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 3 of 7 3. This Complaint is brought under fictitious nam

th , 2008 with the Clerk of the Court through ECF, and that ECF will send an e-notice of the electronic filing to the following: Jeffrey M. Herman, Mermelstein, Stuart S. Adam D. Horowitz, /s/Theodore J. Leopold, Esq. THEODORE J. LEOPOLD, ESQ. Florida Bar No. 705608 RICO-LEOPOLD, P.A. 2925 PGA Boule

he pertinent federal statutes, and respectfully request that the Office of the Deputy Attorney General end federal involvement in this matter so that the State of Florida may resolve this case appropriately. Summary of the Facts Mr. Epstein has maintained a home in Palm Beach, Florida for the past 20 years. While the

creates a substantive right which prevents prosecution and conviction of an individual after the statute has run.” See State v. King, 282 So. 2d 162 (Fla. 1973); Tucker v. State, 417 So. 2d 1006 (Fla. 3d D.C.A. 1982) (citing cases). Given the one-year statute of limitations, any conduct that might amou

med partner in Mr. Herman’s firm. See Tab 31, Florida Bar Website page. Mr. Herman, who is the named pariner in the former firm of Herman, Sloman, & Mermelstein, filed five lawsuits, each asking for $50 million, against Mr. Epstein. Each lawsuit is entitled “Jane Doe # vs. Jeffrey Epstein,” despite the fact t