Epstein Secrets

z.5 At the same time (and until as recent] as March of 2008), the Official Florida Bar websitc continued to identify Mr. 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 former firm of Herman, , & Mermelstein, filed five

it has identified. Because the information provided by these women goes directly to the question of Mr. Epstein's guilt or innocence, it is classic Brady information. We understand that the U.S. Attorney might not want to disclose impeachment information about their witnesses prior to a charge or dur

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

it has identified. Because the information provided by these women goes directly to the question of Mr. Epstein's guilt or innocence, it is classic Brady information. We understand that the U.S. Attorney might not want to disclose impeachment information about their witnesses prior to a charge or dur

oman's former law partner, Jeffrey Herman) to bring civil lawsuits against Mr. Epstein. Around this same time, Mr. Sloman's former law artner effre Herman, had met with the father of one of the prospective plaintiffs, who was one of the women on Ms. Villafana's "secret" list. At the same time (and fo

each was astonished that any evidence Ms. Villafana purported to have was not shared with the State or made available to Mr Epstein's attorneys as Brady evidence. Ms. Villafana launched a totally unsupportable and vastly overreaching sex trafficking investigation without providing notification to th

work effectively and fairly, a defendant must be free to negotiate without fear that his statements will later be used against him." United States' Herman, 544 F.2d 791, 796 (5th Cir. 1977). The candor and meaningful dialogue that bring about settlements would be impossible if either party risked havi

e attorneys representing criminals, the Office would promptly turn over all information in its possession that was helpful to these criminals under Brady' Maryland, 373 U.S. 83 (1963), and related decisions. Victims' counsel asked the Office to extend to the victims the same assistance that it would p

r § 2255. Moreover, these women stated that they did not, now or in the past. consider themselves to be victims. • During the last few months, Mr. Herman, First Assistant Sloman's thriller law partner, has tiled several civil lawsuits against Mr. Epstein on behalf of the alleged "victims." It is our

statements. their, credibility and the foundations. if any. fir claiming personal injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in tlx: form of prior inconsistent statements made by these women before they learned of any financial benefit that may be avai

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

ir statements, their credibility and the foundations, if any, for claiming person! injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the tbnn of prior inconsistent statements made by these women before they learned of any financial benefit that may be avail

ntativeJosefsberes fees B-89 9/2/2008 Mailed Amended Victim Notification letters to #1 )12, #3 (via Richard H. Willits), #4, #13, #8 friaJeffrey Herman), #9, #10, #11, #14, #16, #I7 (via Theodore Leopold), #20, #21, #23, #24, #25 (viaJelfrey Herman), #26 biaJellity Herman), #30, #31, #32, #33, #37

npersuaded by the letter and the presentation, but I agreed that I should carefully review transcripts of the recorded statements given to PBPD for Brady issues." Since witness credibility was clearly at the fore, I undertook efforts " The requested documents and items were never provided. 15 As the

New York, where he owns a 51,000-square-foot Manhattan mansion. “It’s validation of what we’re saying in the civil cases,” said Miami attorneyJeffrey Herman, who represents the alleged victims in the federal lawsuits. West Palm Beach attorney Ted Leopold represents one alleged victim in a civil suit in st

CLERK. 3/28/2023 2:27:00 PM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • • J8RsEPSl I he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very I familiar with it. It is analogous. It is a situation where there was trem

s it has identified. Because the information provided by these women goes directly to the question of Mr. Epstein’s guilt or innocence, it is classic Brady information. We understand that the U.S. Attorney might not want to disclose impeachment information about their witnesses prior to a charge or durin

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