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eve that crucial relevant evidence may be present in some or all of the computers in perhaps each of his six mansions (in Palm Beach, New York City, Santa Fe, London, Paris, and the U.S. Virgin Islands). Finally, in the other pending Jane Doe cases with active discovery, Defendant, Jeffrey Epstein, has
w.com [email protected] Counsel.for PlaintiffC.MA. 13 Case 9:08-cv-80119-KAM Document 114 Entered on FLSD Docket 05/26/2009 Page 14 of 15 Adam Horowitz, Esq. Stuart Mermelstein, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Blvd., Suite 2218 Miami, FL 33160 Phone: (305) 931-2200 Fax: (305) 9
f the extravagant world Epstein built over time. In New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch outside Santa Fe. Many believed it to be the largest home in the state. In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre private
aded guilty in July 2008 to procuring a minor for prostitution and soliciting prostitution. He served 13 months of an 18- month sentence. Attorney Adam Horowitz, who represents seven of the roughly 18 women who have filed civil suits against Epstein, said the new information could trump the so- called non-p
16. As previously stated in paragraph 14, Defendant displayed photographs of nude underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and belief, some of the photographs Defendant's possession of Defendant were taken with hidden camer
Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: (561) 383-9456 ounse or mu .M.A. Adam Horowitz, Esq. Stuart Mermelstein, Esq. Herman & Mermelstein 18205 Biscayne Blvd. Suite 2218 Miami, FL 33160 21 EFTA00221587 Case 9:09-cv-80591-KAM
Entities connected to both Santa Fe and Adam Horowitz

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSON
Bill Richardson
PERSONLarry Visoski
PERSON
George W. Bush
PERSONLeon Black
PERSON
Prince Andrew
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Bill Clinton
PERSON
Donald Trump
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSONJane Doe
PERSON
John F. Kennedy
PERSON
Palm Beach
LOCATIONFBI
ORGANIZATIONDarren Indyke
PERSON