EFTA00257027

Mk r EFTA00257027 MySpace.com - Female - LOX =I, Florida - www.myspace.cona Page 1 of 13 Sponsored Links Bob Dylan Collection A [tarsi-have! 5 decades of maw & videos. Sample the collection now tob:SyLanhyfruak corvfree User Shortcuts: M-Base Ringtones 10000. Rincones! Gel Free Ringtones WM 999/m SubSaiOlion Free FestRmgDovinloads corn Find Sexy Girls Make an Instant Canny(Aion Find Sexy Singles near you tuosexysing es corn People Im A Barbie Girl Ringtone Get Comolimenlary Ringtones Download The Coos You Want RinctonesDownbaowsimMarbieGn Search Goosir home I browse I search f invi re I film I moil I blobs I favorites I forum I Oreu0s I even's I misoace tv I music I corneas, I classifieds mood: excited view my: plc, I videos CRT Send Message ca. Forward to Friend +8 Add to Friends MI. Add to Favorites IM / CaN c8 Block User ;14; Add to Group :8 Rank User myspace url: hIlo://www.myspace.comae 28 07 ...fin Ihe day we Ms I : and thoIS 0 promise http://profile.myspace.com/index.cfm?fuseaction=user.viewprofiladriendidH 2/1/2008 EFTA00257028 MySpacc.com - M- 17 - Fcmalc - LOX 1, Florida - www.myspace.conlIMI M/2 of 13 v abyvourmy uerything displaying 50 01 291 comments ( view all add comment ) on 30 2008 1:37 orn hey how ore you? http://profile.myspace.com/index.cfm?fuseaction=usenviewprofile&friendidH 2/1/2008 EFTA00257029 MySpace.com - - 17 - Female - LOX 1, Florida - www.myspace.conv Page 3 of 13 BEST FRIEND. SISTER. OTHER HALF. ion 29 2008 4:47 pm ion 19 2008 9:03 om .111111 ion 29 2008 8:58 on' inn 29 7008 ft:50 am ion 27 2008 9:37 am http://profile.myspace.com/index.efin?fuseaction=user.viewprofilatfriendith 21/2008 EFTA00257030 MySpace.com - 17 - Female - LOX =], Florida - www.myspace.eon THIS iS WHAT BESTFRIENDS LOOK LIKE • Page 4 of 13 ,on 2. 30083:56 or. Ion it 2008 on, IMp://profile.myspace.com/index.cfm?fuseaction=user.viewprofile.iendid 2/1/2008 EFTA00257031 MySpace.com - 17 - Female - LOX =), Florida - www.myspa.ce.comA Page 5 of 13 married 51rOtghl lOuruS ion 23 2000 10:52 QM 1 on 23 7008 1 1,55 are on 22 2008 9:34 on, on 21 2008 8:57 on, on 22 2008 10:15 OM on 22 2008 9'32 am http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid 2/1/2008 EFTA00257032 MySpace.com -■- 17 - Female - LOX =1, Florida - unvw.myspace.comi Page 6 of 13 on 22 2008 9:27 Om inn 21 7008 9:48 pm on 1 7008 9.13 Dm ion 21 2008 8:32 om http://profile.myspace.com/index.c fm?fuseaction—userviewprolile&friendid= 2/1/2008 EFTA00257033 MySpace.com - - 17 - Female - LOX 1, Florida - www.myspace.com Page 7 0113 00 21 2008 8.20 pm ion 21 2008 7:59 pm 1 ion 21 2008 7:56 pm http://profIle.myspace.com/index.cfm?fuseaction=user.viewproffle&friendid 2/1/2008 EFTA00257034 MySpace.com -■ - 17 - Female - LOX =], Florida - www.myspace.coml Page 8 of 13 on 21 2008 7:53 0m on 21 2008 7:48 om http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid=. 2/1/2008 EFTA00257035 MySpace.com - 17 - Female - LOX =], Florida - www.myspace.comi Page 9 0113 ion 21 20C8 6:26 Om on 21 2008 5,50 Dm on 21 008 5;33 pm on 21 008 5:76 nrn http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid 2/1/2008 EFTA00257036 MySpace.com - ■- 17 - Female - LOX =], Florida - www.myspace.con] Page 10 of 13 ion 21 2008 4: 10 pm on 21 2008 3:55 om ian 21 2008 . 47 am on 21 2008 10:40 urn 'an 2 2908 10: 4 am ion 21 2008 9:31 am an 21 2008 9:16 am http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid= 2/1/2008 EFTA00257037 MySpace.com - ■ - 17 - Female - LOX =], Florida - www.myspace.comil Page 11 of 13 an 21 2008 9:24 om on 21 008 9 08 am on 21 2008 8:49 am ion 1i 2008 8:35 om ion 21 2008 8:37 om I Ian 20 2008 7'48 Dm http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendidH 2/1/2008 EFTA00257038 MySpace.com - ■ - 17 - Female - LOX 1, Florida - www.myspace.com] Page 12 of 13 on 21 2008 8:22 om On 21 2008 6: 2 om on 20 2008 7: 17 Dm ion 20 2008 2:43 Pm ion z0 2008 10 om add comment g.tmg 1 1R,A I Mu I RfiXRAY. I RISIX..tigk I Siatakcit.10M9ct I fg1220 .... PAY.8.04.9. 18XSPAKIUDAP10.0tiR0S0 I alLsASIU.A21-82.9. http://protile.myspace.com/index.cfm?fuseaction=user.viewprofilettfriendid 2/1/2008 EFTA00257039 MySpace.com - - 17 - Female - LOX =I, Florida - www.myspace.co Page 13 of 13 02003-2008 myspace.com. all rights reserved. http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid 2/1/2008 EFTA00257040 Florida D.A.V.I.D. Individual Summary Page Page 1 of 2 STATE OF FLORIDA Department of Highway Safety & Motor Vehicles Driver And Vehicle Information Database (DAVID) I DIGITAL IMAGES ARE FtESTHic IED TO LAW ENFORCEMENT USE PURSUANT TO S. 322.142(4), FLORIDA STATUTES - IMAGES INCLUDE PHOTOGRAPHS AND SIGNATURES Individual Summary Page DI. ID Number Stows Pia A . , Date of Birth Sex VALID All Addresses On File Height 6'00 Restrictions Endorsements Issue Date Duplicate Expiration Date 05-30-06 Date 03-23-13 SSN Conditional Messages: MOTORCYCLE TEMPORARY PERMIT UNTIL: Prtrm IJilmhor '.iate Of Birth Florida AFE DRIVER Law enforcement officers may continue to accept the insurance card indicating Property Damage only, as also including PIP% until June 30. 2008. Vehicle Information Record VIN 1.9e Color Body Make Acquired Date Reg ALUMINUM/ TRUCK SILVER DODGE 08-31-05 TRUCK View View MOTORCYCLE RED MOTORCYCL ' HONDA U7-I8-07 Record DI:ID Number Transaction Date 11-14-07 05.30.06 12-09-05 04-28-05 river License Transactions Issue Date Update Time 05-30 06 05-30- 06 05-31-06 18:25:23 06-20- 12-12-05 00 17:47:22 04-29-05 00:06:53 Issue 1\pc Exam Only Renmal/CIPS Address Chan e/CIPS I II I II 1 hups://www.hsmv.flejn.net/serviet/DLSummary 1/2512008 EFTA00257041 Florida D.A.V.I.D. Individual Summary Page Page 2 of _ ( Vehicle Insurance 03-23-01 06-20-00 06-20- 10-24-03 UU 15:56:05 06-20- 00 Historical Driver License Activity 03-23-01 10:07:42 Photo Array ( New Search Duplicate Nnne Replacement Original ( Signature Array ( Main Menu Lost Previous Vehicles https://www.hsmv.flejn.net/servletIDLSurnmary 1/25/2008 EFTA00257042 EFTA00257043 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: JANE DOE NO. 1, by and through JANE DOE's FATHER as parent and natural guardian, and JANE DOE's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defendant. ot3- 80069 CiV-MARIA IAMISTRAIE JUDGE 1OHNSON D.C. FILED by INTAKE JAN 2 4 2008 0CLELArttcRENuCE.8.. IADisTADDO.G.TX. S.D. OF FLA.. PT. LAUD. COMPLAINT Plaintiff, Jane Doe No. 1 ("Jane" or "Jane Doe"), by and through Jane Doe's Father as parent and natural guardian, and Jane Doe's Father and Jane Doe's Stepmother, individually, bring this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue 1. Jane Doe is a citizen and resident of the State of Florida. She is a minor under the age of 18 years. 2. Jane Doe's Father brings this action individually and as parent and natural guardian of Jane Doe. Jane Doe's Father is a citizen and resident of the State of Florida. 3. Jane Doe's Stepmother brings this action individually. Jane Doe's Stepmother is a citizen and resident of the State of Florida. 4. This Complaint is brought under fictitious names to protect the identity of the Minor Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a HERMAN St MERMELSTEIN, P. A. www.hermanlaw.com EFTA00257044 minor. 5. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 6. This is an action for damages in excess of $50 million. 7. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs; and (ii) is between citizens of different states. 8. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this District. Factual Allegations 9. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach. 10. Upon information and belief, Epstein has a sexual preference and obsession for underage minor girls. He engaged in a plan and scheme in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave them money. In or about 2005, Jane Doe, then 14 years old, fell into Epstein's trap and became one of his victims. 11. Upon information and belief; Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas. 12. An integral player in Epstein's Florida scheme was a Palm Beach HERMAN & MERMELSTEIN, P. A. - 2 - www.hermanlaw.com EFTA00257045 Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's plan, Ms. Robson would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf directed Ms. Robson to bring one or more underage girls to the residence. Ms. Robson, upon information and belief, generally sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas who would be enticed by the money being offered - generally $200 to $300 per "massage" session - and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made. This was an important element of Epstein's plan. 13. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, Mr. Robson would introduce each victim to Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. There were photographs of nude women lining the stairway hall and in the bedroom. Ms. Kellen would then leave the girl alone in this room, whereupon Epstein would enter wearing only a towel. He would then remove his towel, lay down naked on the massage table, and direct the girl to remove her clothes. He then would perform one or more lewd, lascivious and sexual acts, including masturbation and touching the girl's vagina with a vibrator. 14. Consistent with the foregoing plan and scheme, Ms. Robson recruited Jane Doe to give Epstein a massage for monetary compensation. Ms. Robson brought Jane to Epstein's mansion in Palm Beach. Jane was introduced to who led her up the flight of stairs to the room with the massage table. She was alone in the room when Epstein arrived wearing only a towel. He HERMAN 5, MERMELSTEIN, P. A. - 3 - www.hermanlaw.com EFTA00257046 removed his towel, and laid down naked on the massage table. He demanded that Jane remove her clothes. In shock, fear and trepidation, Jane complied, removing her clothes except for her underwear. Epstein then sexually assaulted Jane. 15. After Epstein had completed the assault, he left the room. Jane was then able to get dressed, leave the room and go back down the stairs. She then met Ms. Robson again who brought Jane home. Jane was paid $300 by Epstein. Ms. Robson was paid $200 by Epstein for bringing Jane to him. 16. As a result of this encounter with Epstein, the 14-year old Jane experienced confusion, shame, humiliation, embarrassment and the assault sent her life into a downward spiral. COUNT I Sexual Assault 17. Plaintiff Jane Doe by and through her Father, as parent and natural guardian, repeats and realleges paragraphs 1 through 16 above. 18. Epstein tortiously assaulted Jane Doe sexually in or about 2005. 19. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane. 20. As a direct and proximate result of Epstein's assault on Jane, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, Plaintiff Jane Doe, by and through her Father, as parent and natural guardian, deniands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this Court deems just and proper. HERMAN & MERMELSTEIN, P. A. - 4 - vtnivw.hermanlaw.com EFTA00257047 COUNT II Intentional Infliction of Emotional Distress 21. Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother, individually, repeat and reallege paragraphs 1 through 16 above. 22. Epstein's conduct was intentional or reckless. 23. Epstein's conduct was outrageous, going beyond all bounds of decency. 24. Epstein's conduct caused severe emotional distress not only to Jane Doe, but also to her parents, Jane Doe's Father and Jane Doe's Stepmother. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe's parents. 25. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Do; Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother demand judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper. COUNT HI Loss of Parental Consortium 26. Plaintiff Jane Doe's Father repeats and realleges paragraphs 1 through 16 above. 27. Epstein's tortious conduct is the direct and proximate cause of damages to Jane Doe's Father, consisting of parental loss of comfort, companionship and society and healthcare costs HERMAN & MERMEI-STEIN, P. A. - 5 - whrw.hermanlaw.com EFTA00257048 associated with the treatment of Jane. 28. Jane Doe's Father experienced and will continue to experience great mental anguish, pain and suffering from the time that Defendant's tortious conduct occurred. WHEREFORE, Plaintiff Jane Doe's Father demands judgment for loss of consortium damages, costs and such other and further relief as this Court deems proper. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: January ‘211, 2008 Respectfully submitted, HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 By: Je M. Herman [email protected] Florida Bar No. 521647 Stuart S. Mermelstein [email protected] Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 ahorowitz@hennaniawsom HERMAN & MERMELSTEIN, P. A. - 6 - www.hermanlaw.com EFTA00257049 Billionaire investor sued for alleged sexual assault of teen Page 1 of 3 HOME' SARASOTA ffieraliffilta p sa sptirdwiestraoRnwsiNfPRM W ATI9/4FR Become a member of HeraldTribune.com I Join now I Login f VENICE MANATEE EAST MANATEE CHARLOTTE NORTH PORT ENG NewsoaDer ads I Browse rlassifieds Slibcrriber se ii .ers I Magazines NEWS I COMMUNITY BUSINESS SPORTS A&E OPINION JOBS AUTOS REAL ESTATE CLASSI Local Florida Nation World Politics Health Weather Crime Photos SNN Video Obit c9 Discus his article 0 Letter to editor MI Print this article e E-mail this article Too nation Southern Residents Assess Tornado Damage University norms Smashed at Tenn Schen Death and Damage From Tornadoes No Fatalities in Gas Plant Fxolosion Too news 51058814defll31USPeSt Jias troubled history with WILLI Sarasota County P ler t Inn c chief drawing more fire School nmierts mild start on hormwed dime Risk issue worries Florida insurance panel Sarasota County_mayeS ahead on greenhouse gag glen fogs tartlet emoloyment of gleaal immigrants Time_to_clean uoitorthTrati (14) State considers how to refer to evolution in schools (209) Stiav marriage ban opts on WWI= (34) Tax on stria clubs would hell, seniors. (19) jennincis cups foul.. (37) Md. Boy Srout Charged In Familys Deaths (9) The news and informati Sarasota, Manatee & Ch Subscribe tod Billionaire investor sued for alleged sexual assault of teen THE ASSOCIATED PRESS WEST PALM BEACH, Fla. -- Mother woman is suing a New York billionaire, claiming he sexually assaulted her when she was underage. The unidentified woman says she was 16 when she was brought to Jeffrey Epstein's Palm Beach mansion and paid $200 to give the money manager a massage. Instead, she claims he abused her. The suit filed Wednesday in federal court is seeking more than $50 million in damages from Epstein. Another teenage girl made similar claims against Epstein in a lawsuit filed last month. Epstein also faces a felony charge of solicitation of prostitution. A conviction could send him to prison for five years. Epstein's attorney has denied the allegations, but did not return phone messages Wednesday. Last modified: February 06. 2008 12:01PM SI Adver Adver http://www.heraldtribune.com/article/20080206/APN/802060750 2/6/2008 EFTA00257050 Billion4ire investor sued for alleged sexual assault of teen Page 2 of 3 Touch times for region tensmads (9) Abortion (270) No butts on the beach (25) Pu blix? (37) Sarasota County moves &bead nn oreenhoutie oaf elan (2) Fxrhanae of fire reportedly fatal (8) Pont make beach volunteers Day (2) School nrolertc mild start on borrowed dime (1) czettIno help to net to the Rgyfrcint (5) The imaained olow Qt Reagan era (43) bush wants 3.1 trillion for budoet (17) president Grist? Woman loces fiance In Motorcycle crash (32) earents try to save oroararn for disabled (24) Sponsored Links Prepare to be Shocked Millions have already taken this amazing test. What's your RealAge? \vow. ReatAge.com SalrebtX.AIIIIIWATIODAY Get an Extended Auto Warranty & Protect Your Car Hassle Free. CARCHEX.com lattterWatIslAa Nationwide 24/7 Roadside Assistance Compare our Services! Eco-Friendly. WWW.BetterWorldClub.com http://www.heraldtribune.com/article/20080206/APN/802060750 2/6/2008 EFTA00257051 Billionaire investor sued for alleged sexual assault of teen Page 3 of 3 Ad• SCl site_instex I csultastils HeraldTribune.com I Ab_o_ut_Us I AgteditejtaliU.s I jobs With U.s I ME I Join Newsletter I RSS I 'S. Serving the Herald-Tribune newspaper and SNN Channel 6 © Sarasota Herald-Tribune. All rights reserved. privacy Colley I Member http://www.heraldtribune.com/article/20080206/APN/802060750 2/6/2008 EFTA00257052 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. COMPLAINT Plaintiff, Jane Doe No. 2 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue 1. Jane Doe No. 2 is a citizen and resident of the Commonwealth of Virginia, and is sui juris. 2. This Complaint is brought under a fictitious name to protect the identity of the Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs; and (ii) is between citizens of different states. 6. This Court has venue of this action pursuant to 28 U.S.C. §139I(a) as a substantial HERMAN 5. MERMELSTEIN, P. A. - I - www.hermanlaw.com EFTA00257053 part of the events or omissions giving rise to the claim occurred in this District. Factual Allegations 7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach. 8. Upon information and belief, Epstein has a sexual preference and obsession for underage minor girls. He engaged in a plan and scheme in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave them money. In or about 2004-2005, Jane Doe, then approximately 16 years old, fell into Epstein's trap and became one of his victims. 9. Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas. 10. Epstein's scheme involved the use of young girls to recruit underage girls. (Upon information and belief, the young girl who brought Jane Doe to Epstein was herself a minor victim of Epstein, and will therefore not be named in this Complaint). Under Epstein's plan, underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf would direct the recruiter to bring one or more underage girls to the residence. The recruiter, upon information and belief, generally sought out economically disadvantaged underage girls from western Palm Beach County who would be enticed by the money being offered - generally $200 to $300 per HERMAN & MERMELSTEIN, P. A. - 2 - www.hermanlaw.com EFTA00257054 "massage" session - and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made. This was an important element of Epstein's plan. 11. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, the underage victim would be introduced to Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. There were photographs of nude women lining the stairway hall and in the bedroom. The girl would then find herself alone in the room with Epstein, who would be wearing only a towel. He would then remove his towel and lie naked on the massage table, and direct the girl to remove her clothes. Epstein would then perform one or more lewd, lascivious and sexual acts, including masturbation and touching the girl's vagina. 12. Consistent with the foregoing plan and scheme, Jane Doe was recruited to give Epstein a massage for monetary compensation. Jane was brought to Epstein's mansion in Palm Beach. Once at the mansion, Jane was introduced to who led her up the flight of stairs to the room with the massage table. In this room, Epstein told Jane to take off her clothes and give him a massage. Jane kept her panties and bra on and complied with Epstein's instructions. Epstein wore only a towel around his waste. After a short period of time, Epstein removed the towel and rolled over exposing his penis. Epstein began to masturbate and he sexually assaulted Jane. 13. After Epstein had completed the assault, Jane was then able to get dressed, leave the room and go back down the stairs. Jane was paid $200 by Epstein. The young girl who recruited Jane was paid $100 by Epstein for bringing Jane to him. 14. As a result of this encounter with Epstein, Jane experienced confusion, shame, HERMAN & MERMELSTEIN, P. A. - 3 - www.hermanlaw.com EFTA00257055 humiliation and embarrassment, and has suffered severe psychological and emotional injuries. COUNT I Sexual Assault 15. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 16. Epstein tortiously assaulted Jane Doe sexually. Epstein's acts were intentional, unlawful, offensive and harmful. 17. Epstein's plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously. 18. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane. 19. As a direct and proximate result of Epstein's assault on Jane, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, Plaintiff Jane Doe No. 2 demands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this Court deems just and proper. COUNT II Intentional Infliction of Emotional Distress 20. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 21. Epstein's conduct was intentional or reckless. 22. Epstein's conduct was outrageous, going beyond all bounds of decency. 23. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe. HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com - 4 - EFTA00257056 t 24. As a direct and proximate result of Epstein's intentional or reckless con ct, Jane Doe, has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiff Jane Doe No. 2 demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: February 2008 Respectfully submitted, HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 By: Jeffrey M. Herman [email protected] Florida Bar No. 521647 Stuart S. Mermelstein [email protected] Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 ahorowitz@hennan law.com HERMAN & MERMELSTEIN, P. A. - 5 - www.hermanlaw.com EFTA00257057 MySpace.com - View Photo Page 1 of 3 MySpace.com Privacy I Help I SlynOut DISCOVER MUSIC WINEH~USE et RETIE MUSIC. MONKEYS User Shortcuts People Search c"" Home I Browse I Search I Invite I Film I Mail I Slogs I Favorites I Forum I Groups I Events I MySpace TV I Music I Comedy I Classifieds tli photos I Upload Photos My Photos - View Photo Assoc. Back to Profile Back to Albums Previous I Next http://viewmorepics.myspace.com/index.cfm?fuseaction=viewlmage& friendl &al buml D=151911&imagel D=116... 1/25/2008 EFTA00257058 MySpace.com - View Photo . - • Page 2 of 3 And my twins LOVE ME hahahaha!!!! 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Privacy I Help I SignOut People Search powered by Google Home I Browse I Search I Invite I Film I Mail I Blogs I Favorites I Forum I Groups I Events I MySpace TV I Music I Comedy I Classifieds 4 photos I Upload Photos My Photos Listing 41-60 of 64 1 Comment(s) 1 2 3 4 of 4 ), Post A Comment 1 Comment(s) 0 Comment(s) Back to Profile Back to Albums (Previous i blext> 0 Comment(s) http://viewmorepies.myspace.com/index.cfm?fuseaction=user.viewPicture&friendID albumId=151911 1/25/2008 EFTA00257061 View More Pictures Page 2 of 4 0 Comment(s) 3 Comment(s) 2 Comment(s) o Comment(s) 0 Comment(s) 1 Comment(s) i comment(s) 1 comment(s) http://viewmorepics.myspace.com/index.cfm?fuseaction=usenviewPicture&friendID= albumld=151911 1'25/2008 EFTA00257062 View More Pictures Page 3 of 4 post A Comment 0 Comment(s) 0 Comment(s) 0 Comment(s) 0 Comment(s) 1 Comment(s) http://viewmorepics.myspace.com/index.cfin?fuseaction=user.viewPicture&friendlD= albumld=151911 1/25/2008 EFTA00257063 **View More Pictures Page 4 of 4 Listing 41-60 of 64 tib 1 a Let lte_O Upload Your Video To OurStage. 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Search powered Google Home I Browse I Search I Invite I Film I Mall I Blogs I Favorites I Forum I Groups I Events I MySpace TV I Music I Comedy I Classifieds Back to Profile Sack to Albums photos I Upload Photos My Photos - View Photo Previous I Next http://viewmorepies.myspace.com/index.cfmffuseaction=viewimage&friendIEMalbumID= 151911&imageID=116... 1/25/2008 EFTA00257065 MySpace.com - View Photo Page 2 of 3 From Comment Usdng 1 - 1 of 1 Sponsored links Wee Forest Folk Free Shipping on all Orders Quick Ship • 5/6 Club http://viewmorepics.myspace.com/index.cfm?fuseaction=viewImage&friendlD= lbum1D-1519116timagelD-116... 1/25/2008 EFTA00257066 MySpace.com - View Photo Page 3 of 3 X0X0 wwwchertylanecollaction.com Folk Music that Rocks Dave Rowe Trio.Maine fok music Sounds like lobster tastes www daverowetno con- Rosourco Entertainment The Md-South entertainment experts Great bands, prices, and service. www REGmemphis.com Folk Ringtones Get the top Folk music ringtones Pick any Folk music ringtone now FokMusic RogtonezFinder. corn About I FAQ I Terms Privacy I Safety Tips I Contact MySpace I Advertise I MySpace International I MySpace Latino ©2003-2008 MySpace.com. All Rights Reserved. http://viewmorepics.myspace.com/index.cfm?fuseaction-viewlmagadriendl lbwn1D= 151911&image1D-116... 1/25/2008 EFTA00257067 ViEw More Pictures Page 1 of 2 ii photos I Upload Photos MySp. User Shortcuts: Privacy I Help I SignOut People Search pbuwerti Goosle Home I Browse I Search I Invite I Film I Mail I Blogs I Favorites I Forum I Groups I Events I MySpace TV I Music I Comedy I Classifieds Back to Profile Back to Albums My Photos Listing 61-64 of 64 1 2 3 4 of 4 st A Comment os Commen 1 Comment(s) 1 Comment(s) 0 Comment(s) Listing 61-64 of 64 1 2 3 4 of 4 Previous » Post A Comment 1 Comment(s) < Previous hup://viewmorepics.myspace.com/index.cfm?fuseaction=user.viewPicture&friendID= bumld=151911 1/25/2008 EFTA00257068 'V•tew More Pictures Page 2 of 2 Sponsored Links Upload Music Video Upload Your Video To OurStage. Compete with Others for Free! www.OurStage.com Don't Buy Gold Learn how to make 200 gold an hour. 100% Legit Gold Guide. 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All Rights Reserved. http://viewmorepics.myspace.com/index.cfm?fuseaction=user.viewPicture&friendlD= &albumid=151911 1/25/2008 EFTA00257069 - View Photo Page 1 of 4 People • Search) 41 photos I Upload Photos MySpace.com User Shortcuts: Privacy I Help I SignOut Google Home I Browse I Search I Invite I Film I Mail I Blogs I Favorites I Forum I Groups I Events I MySpace N I Music I Comedy I Classifieds Back to Profile Back to Albums The peeps I RiDe Or DiE for!!!! - View Photo Previous I Next http://viewmorepies.myspace.com/index.cfm?fuseaction=viewImage&friendID= &albumID=1093092&imageID=13... 1/25/2008 EFTA00257070 . —MySpace.com - View Photo Page 2 of 4 http://viewmorepics.my space.com/index.cfm?fuseaction=viewl mage8c friendID=S78calbuml D=10930928cimagelD=13... 1/25/2008 EFTA00257071 ....aiMySpace.corn - View Photo Page 3 of 4 From Post A Comment E-man to a Friend listing 1 - 2 of 2 Report This Imag—el Comment January 23, 2008 8:02 PM hahah thats sum good shlt January 23, 2008 7:08 PM It says ... omg !!! yummmmmmmmyy love this pic.. you guys look hott together !I Sponsored Links No Seeing, No Convincing Or Explaining with my Revolutionary Unique Online Business Opportunity. FiettdonuTIncuyhAction corn Credit Reports Check Your Credit Report Online. Look For Signs of Identity Theft. www-ReportsCredif info Stop Your Divorce Stop by Step Instructions on How To Stop Your Divorce Right Now. www StOpYourDvorce con Immediate Love Results I Free Reading 1865 503 5454 JAYDEN Stops Divorce.Breakup.Creaung Lies '/N/W BRINCS0ACKLOVER COM http://viewmorepics.myspace.com/index.cfm?fuseaction=yiewImage&friendID= bumla=10930928c imagel D-13... 1/25/2008 EFTA00257072 . • MySpace.com - View Photo Page 4 of 4 amid I FAQ I terms I Privacy 1 Safety Tips I ContactittySone I Advertise I MySpace International I Mlfrantin0 ©2003.2008 MySpace.com. All Rights Reserved. http://viewmorepics.myspace.com/index.cfm?fuseaction=viewlmageltfriendID album11 1093092ecimagell>13... 1/25/2008 EFTA00257073 re,,,,..:14ySpace.com -M. 17 - Female - LOX =], Florida - www.myspace.com Page 1 of 11 glittery texts by blilliggbred Links Practice Engine from CLI 100'/o Web-based. Enterprise level CPA firm practice management. noniron too corn User Shortcuts: The Future Of Payment Sell Your Future Payments We've got the Top Sites Listed mood: excited view my: oics I videos ET Send Message +8 Add to Friends O / tall 4•&, Add to Group rrirsooce VII: hIl0://www.mri$00Ce.cbm conloc On= People Search ...ti I the dov we die I and Mots o oromise about me: Forward to Friend AM to Favorites Block User Rank User http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid 2/13/200s EFTA00257074 lisSlySpace.com - 17 - Female - LOX =], Florida - www.myspace.com Page 2 of 11 eroes interests r 230 Days Sint:. v.:, 4C uttn tuyttnct who I'd like lo moot. 1 50 of 304 comments I view oil I odd comment I feb 9 2008 4:15 pm I like this detuoli better :) feb 8 2008 9:13 pm I your workinn next tn. right) 9 1 feb 7 2008 8:13 om hahah you finally mode ur page SOrnetnig worth going http://profile.myspace.com/index.cfm'?fuseaction=userviewprofile&friendidl 2/13/2008 EFTA00257075 alletySpace.com - - 17 - Female - 1.OX =I, Florida - www.myspace.co Page 3 of 11 to ... y000 lot. what u u0 to hoe.. hey guess what i love you v feb 6_2008 9:39 urn teb 6 2008 9:31 am hoyy what the hell u doing.. so u cord fuckn talk to ut sitter no more.. what the fuck is this shill Wee set) 6 2008 8:10 am yes ill b woken tonight...ueoctually u wont cux im geltin off the Camp now 101 peace too 6 2038 7:40 om hey loser leg 5 2000 1:37 pm heyy hoee what it do bitchh ..1O1 soo yeah i went to go hup://prolile.myspace.cotn/index.efm?fuseaction—user.viewprolile&friendid 2/13/2008 EFTA00257076 MySpace.com -MI- 17 - Female - 1.OX -1, Florida - wvzw.myspace.co Page 4 of 11 1071 A 200A 7 fel) 4 2008 7:00 OM not too much fob 4 2008 6:50 am hey you! ;an 30 2008 I:37 pm l hey how ore you; Ion 29 2008 4 447 ton 29 2008 9.03 orn I hup://profile.myspace.com/index.cfm?fuseaction=userviewprofilacfriendid= 2/13/2008 EFTA00257077 MySpace.com -al- 17 - Female - LOX =], Florida - www.myspace.co Page 5 of 11 on 29 2008 8:58 am an 29 20)8 8:50 om an 27 2008 9:37 am gimme a call ion 24 2008 8:16 om I I Old It went to voice mall.. on 24 2008 7:56 http://protile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid= 2/13/2008 EFTA00257078 MySpace.com - M- 17 - Female - LOX =), Florida - www.myspace.con] Pave 6 of I that 101. . u 01 I ft on 24 2008 1:18 on 24 2008 6:48 11 jon 24 2008 12:51 pm well heeler:el' 13.52 pm http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid 2/13/2008 EFTA00257079 MySpace.com - - 17 - Female - LOX Florida - www.myspace.co Page 7 of I 1 an 23 2008 8:51 am hey purl... how u been? Is been o long while lol..jus woo sum Iwli jon 22 2008 10:15 am] hot where u tolkin bou' amber railey is 5 not 4 hulk?? ion 22 2008 9:32 omj its oil good 101 that was s0 funny that you thought that y0ut too funnnyl<3 an 22 2008 9:2? orn http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid= 2/13/2008 EFTA00257080 MySpace.com MI- 17 - Female - LOX =I, Florida - www.myspace.co Page 8 of 11 Ion 21 2008 9:48 pm ohh shiiyy f neecha move in mesh ion 21 2008 9:13 pm wot up stronger iOn 21 2008 9:16 pm wo mocha loft about the oprt. kk voxo on 21 2008 8:32 pm hohoh i rood It woww it all i can toy an 21 2008 8:20 pm http://profile.myspace.comfindex.cfm?fuseaction=user.viewprofile&friendid= 2/13/20os EFTA00257081 MySpace.com 17 - Female - LOX 1, Florida - www.myspace.coa Page 9 of 11 ion 21 2008 7:59 pm everything olwoys does you know Jon 21 2008 7:56 pm iv know him forever we grew up together hoho on 21 2008 7:53 pm hoho thanks lan 21 2008 7:48 PM I l tp://prothe.myspace.com/index.cfm?fuseaction—user.viewprofile&friendicP 2/13/2008 EFTA00257082 MySpace.com - 17 - Female - LOX =I, Florida - www.myspace.eoml Page looi I I on 21 2008 6:26 pm whots up? 00 21 2008 5:50 m Ian 21 2008 5:33 pm hot do I hove to do 10 get it though.. go lo oim.Com or sum shit .. on 21 2008 5:29 pm how did the oportmont th ngy go on sendoy? On 21 2008 4:10 •m http://profile.myspace.com/index.cfm?fuseaction—user.viewprofile&friendith 2/13/2008 EFTA00257083 , MySpace.com -M 17 - Female - LOX =], Florida - www.myspace.com Page 11 of 11 odd comment jon 21 20D8 3:5S pm wnot's gOOO Ion 21 2008 11:47 am ay beautiful thanks for the odd.. Cheek us out and leave some love.. let us know what yo think.. 'an 21 2008 10:40 am 'an 21 2003 10:14 am about I faq I terms I pr vocy I safely lips I contact myspoce report abuse I advertise I rnyspoce international I myspoce lotino C2003-2008 myspace.com. all rights reserved. http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid=1 2/13/2008 EFTA00257084 Florida D.A.V.I.D. Individual Summary Page Page ot STATE OF FLORIDA Department of Highway Safety & Motor Vehicles Driver And Vehicle Information Database (DAVID) DIGHAL IMAGES ARE RES IRIC IED I O LAW ENFORCEMENT USE PURSUANT TO S. 322.142(41, FLORIDA STATUTES - IMAGES INCLUDE PHOTOGRAPHS AND SIGNATURES Individual Summary Page Conditional Messages: UNDER 21 UNTIL: DL. ID Number Class Status ID CARD VALID LOXAHATCHEE FL 334704014 Date of Birth Sex F All Addresses On File Height 5'03 Restrictions Endorsements Issue Date Duplicate Expiration Date 05-12-06 Date 05-13-10 SSN AFE DRIVER ORGAN DONOR Form Number State Of Birth Florida I .an enforcement officers may continue to accept the insurance card indicating Property Damage only. as also including until lune 30. 2008. Record VIN Vehicle Information ('olor Body j Make Acquired Date I Reg I) fiver LICCIISC 1 Record View View DL/ID Number Transaction Issue Date Date Update Time 02-01-07 05-12-06 05-12-06 05-12-06 Lie pe ID ID Issue Type F Duplicate/CI PS Original II Historical Driver License Activity [ Vehicle Insurance Photo Array [ Previcus Vehicles Signature Array New Search Main Menu Change Type None FL Disp https://www.hsmv.flejn.nethervlet/DLSummar 2/20/2008 EFTA00257085 • .! UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. COMPLAINT Plaintiff, Jane Doe No. 2 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue 1. Jane Doe No. 2 is a citizen and resident of the Commonwealth of Virginia, and is sui juris. 2. This Complaint is brought under a fictitious name to protect the identity of the Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. § 1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs; and (ii) is between citizens of different states. • 6. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial HERMAN 5. MERMELSTEIN, P. A. - 1 - www.hermanlaw.com EFTA00257086 part of the events or omissions giving rise to the claim occurred in this District. Factual Allegations • 7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach. 8. Upon information and belief, Epstein has a sexual preference and obsession for underage minor girls. He engaged in a plan and scheme in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave them money. In or about 2004-2005, Jane Doe, then approximately 16 years old, fell into Epstein's trap and became one of his victims. 9. Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas. 10. Epstein's scheme involved the use of young girls to recruit underage girls. (Upon information and belief, the young girl who brought Jane Doe to Epstein was herself a minor victim of Epstein, and will therefore not be named in this Complaint). Under Epstein's plan, underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf would direct the recruiter to bring one or more underage girls to the residence. The recruiter, upon information and belief, generally sought out economically disadvantaged underage girls from western Palm Beach County who would be enticed by the money being offered - generally $200 to $300 per HERMAN & MERMELSTEIN, P. A. - 2 - MAY. hermanlaw.com EFTA00257087 "massage" session - and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made. This was an important element of Epstein's plan. 11. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, the underage victim would be introduced to-Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. There were photographs of nude women lining the stairway hall and in the bedroom. The girl would then find herself alone in the room with Epstein, who would be wearing only a towel. He would then remove his towel and lie naked on the massage table, and direct the girl to remove her clothes. Epstein would then perform one or more lewd, lascivious and sexual acts, including masturbation and touching the girl's vagina. 12. Consistent with the foregoing plan and scheme, Jane Doe was recruited to give Epstein a massage for monetary compensation. Jane was brought to Epstein's mansion in Palm Beach. Once at the mansion, Jane was introduced toa who led her up the flight of stairs to the room with the massage table. In this room, Epstein told Jane to take off her clothes and give him a massage. Jane kept her panties and bra on and complied with Epstein's instructions. Epstein wore only a towel around his waste. After a short period of time, Epstein removed the towel and rolled over exposing his penis. Epstein began to masturbate and he sexually assaulted Jane. 13. After Epstein had completed the assault, Jane was then able to get dressed, leave the room and go back down the stairs. Jane was paid $200 by Epstein. The young girl who recruited Jane was paid $100 by Epstein for bringing Jane to him. 14. As a result of this encounter with Epstein, Jane experienced confusion, shame, HERMAN & MERMELSTEIN, P. A. - 3 - www.hermanlaw.com EFTA00257088 humiliation and embarrassment, and has suffered severe psychological and emotional injuries. COUNT I Sexual Assault 15. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 16. Epstein tortiously assaulted Jane Doe sexually. Epstein's acts were intentional, unlawful, offensive and harmful. 17. Epstein's plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously. 18. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane. 19. Asa direct and proximate result of Epstein's assault on Jane, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, Plaintiff Jane Doe No. 2 demands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this Court deems just and proper. COUNT II Intentional Infliction of Emotional Distress 20. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 21. Epstein's conduct was intentional or reckless. 22. Epstein's conduct was outrageous, going beyond all bounds of decency. 23. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe. HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com - 4 - EFTA00257089 Y.. net • 1/4. gkar 24. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiff Jane Doe No. 2 demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: February , 2008 Respectfully submitted, HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 By: Jeffrey M. Herman [email protected] Florida Bar No. 521647 Stuart S. Mermelstein smermelstein®hermanlaw.com Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 ahorowitz ennanlaw.com HERMAN & MERMELSTEIN, P. A. - 5 - www.hermanlaw.com EFTA00257090