Epstein Secrets

for this deposition. 18 BY MR. TEIN: 19 Q. Go ahead. Please answer yes or no. 20 A. Yes. 21 Q. Thank you. 22 In fact, you know that Mr. Herman held a 23 press conference after he filed the fifty-million-dollar 24 lawsuit on your behalf, don't you? 25 A. After it happened. Ph. 561.682

hasis added). In this case, the plaintiffs have tried to whip Jane Doe's original, one- defendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F. Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended 12 Levyk:Ctin M. 3059 GweAvanur,SUOTE 340, Coormul Glo

At the same time (and until as recently as March of 2008), the Official Florida Bar website continued to identify Mr. SIM as a named partner in Mr. Herman's firm. See Tab 31, Florida Bar Website page. 39. Mr. Herman, who is the named partner in the formcr firm of Herman, Sloman, & Mermelstein, filed

ernment had to show that Sims benefited financially from Owen's sexual activity and that Sims knew that (a) force or cocrcion would be used to cause Owens to engage in a criminal sex act or (b) that Owens was under the age of 18.) (emphasis added). Again, none of these factors is present in this case.

e 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 75 of 100 nsor & Associates \ Reporting and Transcriponn, Inc. Page 49 1 Mr. Herman in the presence of IMO" 2 A. None. 3 Q. What discussions did you have in the 4 presence of her aunt? 5 A. Of my aunt? 6 MR. GOLDBERGER:

hasis added). In this case, the plaintiffs have tried to whip Jane Doe's original, one- defendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F. Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended 12 Lewis.Teinii. 3039Gamy Avinim, Sun 340, COCOMUIGNOW,

1 Entered on FLSD Docket 07/21/2008 Page 40 of 100 nsor & Associates Roportenp and Tanscriptinn, 2 4 5 6 7 8 9 10 11 stepmother and Mr. Herman at the press conference 12 regarding your lawsuit? 13 A. Yes. 14 Q. Now you know that this is a very serious 15 matter, don't you? 16 MR.

hasis added). In this case, the plaintiffs have tried to whip Jane Doe's original, one- defendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F. Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended 12 1...evfitACCFin N. 3059 Gumo Ave nue n 340, Cocewi

for this deposition. 18 BY MR. TEIN: 19 Q. Go ahead. Please answer yes or no. 20 A. Yes. 21 Q. Thank you. 22 In fact, you know that Mr. Herman held a 23 press conference after he filed the fifty-million-dollar 24 lawsuit on your behalf, don't you? 25 After it happened. Ph. - Fax. 16

hasis added). In this case, the plaintiffs have tried to whip Jane Doe's original, one- defendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F. Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended 12 n 3059 MIAS° Amkut.$44ti 340. CoccoanGtovi,40444343

t the same time (and until as recently as March of 2008), the Official Florida Bar website continued to identify Mr. Sloman as a named 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 l

vernment had to show that Sims benefited financially from Owen’s sexual activity and that Sims knew that (a) force or coercion would be used to cause Owens to engage in a criminal sex act or (b) that Owens was under the age of 18.) (emphasis added). Again, none of these factors is present in this case. T