Epstein Secrets

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

y extended period, and there is no basis for your assertion that the judge is the cause of any past or future delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is rat an adequate basis for delay. Three weeks ago I also asked you to provide our Office with

subject case now under consideration by the SDFL. Recently, I learned that there is a reference to the law firm of "Herman Sluman & Mermelstein" on the Florida Bar website, under a section called "Find A Lawyer." This reference appears when Stuart Mennelstein's name and information is accessed. To reiterate, s

statements, their credibility and the foundations. il' any. for claiming personal istiory. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in the Ponta of prior inconsistent statements made by these women before they learned of any financial benefit that may be avai

P MIA 000017 EFTA00209063 • • • JAY P. I.EFKOWITZ, ESQ. DFCEMBER 6,2007 PAGE 2 OF 4 any past or future delay. Mr. Epstein currently has four Florida Bar members on his defense learn, so attorney scheduling is not an adequate basis for delay. Three weeks ago I also asked you to provide our Office wit

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

d met with the father of one of the prospective plaintiffs, Saige Gonzalez.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

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

ai lerman, had met with the father of one of the prospective plaintiffs, .5 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 na

ed to provide the draft indictmatt. We understand that we have no statutory right to a FRI 302 that inculpates Mr. Epstein (although we believe that Brady principles would encourage the disclosure of P131 302 reports that exonerate him). We are Lammed that there is information that could be rebutted i

judge is the cause of EFTA01718528 JAY P. LEFKOWITZ, ESQ. DECEMBER 6, 2007 PAGE 2 OF 4 any past or future delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay. Three weeks ago I also asked you to provide our Office with

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

l chain titled Things to do in West Palm 11/4/2008 Villafafia Senior Email thanking Villafatia for her 11/3/08 email advising she spoke with the Florida Bar 11/4/2008 Correspondence from Florida Bar Ethics Counsel regarding Florida Ethics Rules involved in distributing victim notification letters 11/1

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

3 FAX 305 630 8440 EXECUTIVE OFFICE JAY P. LEEKOWITZ, ESQ. DECEMBER 6, 2007 PACE 2 OF 4 any past or figure delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay. Three weeks ago I also asked you to provide our Office with

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

3 FAX 305 630 8440 EXECUTIVE OFFICE JAY P. LEEKOWITZ, ESQ. DECEMBER 6, 2007 PACE 2 OF 4 any past or figure delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay. Three weeks ago I also asked you to provide our Office with

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

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 lawsuits, each asking for $50 mil