Epstein Secrets

. 947245 Adam D. Horowitz Florida Bar No. 376980 [email protected] r to Case No. 08-80736-CV-MAFtRA P-008991 EFTA00190925 305-931/200 Herman inerrnsIsteln. P 01:1S:05 p.m. 02-04-2008 3/3 1) 0 • CERTIFICATE OF SERVIC& I hereby certify that a true and correct copy of the foregoing w

de certified copies of same to the officer for use in compliance with the requirements of law. DONE AND ORDERED, on ?-r) NUNC PRO TUNC 96.30-2008 Sandra K. McSorley, Circuit dge I acknowledge receipt of a copy of this order and that the conditions have b planted to me and I agree to abide by them. Date: Inst

orth Dixie Highway Courtroom 11F West Palm Beach, Florida 33401 Re: State of Florida" Jeffrey Epstein Case No.: 502006CF009454AXXXMB Dear Judge McSorley: We represent a witness in the above-referenced matter. It is kindly requested that a fifteen (15) minute or less special set hearing be scheduled

) exceeds $75,000, delusive of interest and costs; MERMELSTEIN & HOROWITZ, P. A. I of T - I - vAmsexabuseattomey.com EFTA00194741 305-9312200 Herman ttholermoisteln, P 02:33:35 p.m. 01-06-2009 5/8 and (ii) is between citizens of different states. 6. Additionally, this Court has jurisdiction

ppropriate. Eighth, it is both unreasonable and unjustifiable to hold Mr. Epstein responsible—never mind declare him in breach—with regard to Judge McSorley's nunc pro tune order. Exhibit 1, June 15, 2009 Letter at 3. Neither Mr. Epstein nor defense counsel had anything to do with and certainly no prior

o other "Jane Does" who filed similar lawsuits in the past six weeks. All three suits were filed by Miami lawyer Jeffrey Herman. More crime coverage Herman subsequently withdrew the first Jane Doe's lawsuit because of squabbling by her parents over the litigation. The girl may refile the suit after she t

stein has agreed to plead guilty to state charges. Mr. Epstein’s change of plea and sentencing will occur on December 14, 2007, at a.m., before Judge Sandra K. McSorley, in Courtroom 11F at the Palm Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida. Pursuant t i Sections 960.001 (1)(k) and 9

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 end Privileged —Attorney Work Product -12- Case No. 08-80736-CV-MARRA P-01

e failure to set a timely plea and sentencing date. At that time, you assured me that the scheduling delay was caused by the unavailability of Judge McSorley. You promised that a date would be set promptly. On November 15th, Rolando Garcia met with Barry Krisher on another matter, and was told by Mr. Kri

ayne Boulevard Suite 2218 Miami, Florida 33160 Re: Jeffrey Epstein/Angelique Garcia (née Cavatiara): NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Herman: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to y

ctim notifications (and, later, a Declaration in the Jane Doe litigation) based upon this understanding. When Epstein entered his guilty plea, Judge McSorley required him to file his federal Non-Prosecution Agreement with the Court since that formed part of the consideration for the state plea. I wanted

ty Courthouse 205 North Dixie Highway West Palm Beach, Florida 33401 RE: State of Florida v. Jeffrey Epstein Case No. 2006CF009454A Dear Judge McSorley: Enclosed please find a courtesy copy of the Defendant's Response to the Motion for Protective Order filed by Theodore Leopold. ).1 V ours, Jac

r your consid ration espectfully OLD TJL:amd Enclosure RICCI-LEOPOLD CONSUMER JUSTICE ATTORNEYS February 5, 2008 VIA HAND DELIVERY Honorable Sandra K. McSorley Circuit Criminal, Division W Palm Beach County Courthouse 205 N Dixie Highway West Palm Beach, FL 33401 Re: State of Florida v. Jeffrey Epstei

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