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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
led the "Declaration of /Mt' attaching the state detective's affidavit in support of a search warrant for Epstein's house. See : hay Subpoenas Awes Tatum OLY-63 and OLY.64, No. Fat 07.103(WPB) (S.D. Fla. July 31, 2007). At the time she filed affidavit, she knew it contained numerous material misrepr
rmer law partner, has filed several civil lawsuits against Mr. Epstein on behalf of the alleged "victims." It is our understanding that each of Mr. Herman's clients are on the EFTA00192764 &bell 08/02/08 05. 10.11$ MON 15: 02 MON 13:25 FAX FAX 305 I 530 213 6440 080 8500 EXECUTIVE OFFICE Al RK
prosecutors during the negotiations of a deterred prosecution a reement. The consistent a re . resentations of ke Government witnesses (such as Tatum. Brittany Beak, Saige . and in) confirm the following critical points: First, there was no communication, totelephonic or otherwise, that meets t
or his counsel [would] pursue [plea negotiations] if the remarks uttered during the course of it are to be admitted in evidence as proof of guilt." Herman, 544 F.2d at 797. Plea negotiations are "rooted in the imperative need 22 EFTA00177961 Case 9:08-cv-80736-KAM Document 94 Entered on FLSD Docket
in's residence prior to Rivera's first contact with him. During one of their conversations, Epstein asked Rivera, "Do you know that girl Jenny that Tatum brought?" At the conclusion of the interview, Rivera directed the interviewing agents to Virginia LNU's residence, 2319 Avenue Barcelona Este, loca
Entities connected to both Herman and Tatum

Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
United States
LOCATIONJack Goldberger
PERSON
Alexander Acosta
PERSON
George W. Bush
PERSONJane Doe
PERSONLeon Black
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Jay Lefkowitz
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Scarlett Johansson
PERSONRoy Black
PERSON
Virginia Giuffre
PERSON
Ken Starr
PERSON
Joe Biden
PERSON