Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80119-MARRNJOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I AFFIDAVIT OF JEFFREY HERMAN STATE OF FLORIDA SS COUNTY OF MIAMI-DADE Jeffrey Herman deposes and states as follows I am the attorney of record for Jane Doe No and have knowledge of the status and history of this case The Complaint filed in this action alleges that Defendant Epstein is a financier and money manager to billionaires who himself is a man of tremendous wealth power and influence It alleges that Defendant Epstein preys on young teenage girls by inducing them to give him massages for compensation in his Palm Beach mansion and then sexually assaulting them Plaintiff Jane Doe No seeks damages for sexual assault against Defendant Epstein This case was filed on February On that day I attended a press conference in West Palm Beach Florida concerning the filing of this suit Accusations relating to Mr Epsteins sexual misconduct with underage girls has been reported extensively in the press since The filing of Jane Doe No 2s case received extensive press coverage as did a prior related case filed on January EXHIBIT HERMAN MERMELSTEIN A I A w.hermanlaw.com Case Document Entered on FLSD Docket Page of making similar allegations Jack A Goldberger Esq Mr Epsteins attorney attended a press conference in January on Mr Epsteins behalf which concerned the filing of the first civil case In March I advised Mr Goldberger in writing that I represent the woman who is Jane Doe No A redacted copy of this letter is attached hereto as Exhibit A Mr Goldberger is attorney ofrecord for Mr Epstein in a criminal case pending against Mr Epstein in Palm Beach County I subsequently wrote to Mr Goldberger again and asked for his consent to conducting a single deposition of Jane Doe No to be used in both criminal and civil matters A redacted copy of this letter is attached hereto as Exhibit Mr Goldberger was also asked if he would accept service on behalf of Mr Epstein but he failed to respond Shortly thereafter Plaintiffs process server made numerous attempts to serve Mr Epstein with the Summons and Complaint at his New York residence without success It is my understanding that Defendant Epsteins principal residence is an approximate square foot luxury townhouse in Manhattan He also has an estate home in Palm Beach an island in St Thomas and a residence in New Mexico I was later provided with information that Mr Epstein was out of the country in and about April in the State oflsrael I was further advised that he returned to the United States in late April early May In response to this information my firm instructed the New York process server to step up efforts to serve process on Defendant Epstein Service was finally obtained on May at Defendant Epsteins New York residence on the fifth attempt to serve Defendant Epstein in a span of days It was not until June when the Clerk denied Plaintiffs Motion for Entry of Default that I became aware that the Clerk had an issue with service of process in this action In two HERMAN MERMELSTEIN A w.hermanlaw.com Case Document Entered on FLSD Docket Page of other related cases Clerks defaults were entered based on the same service At every step my firm has acted promptly and diligently to comply with the rules of the court attempt to properly effect service and move this case forward expeditiously FURTHERAFFIANT Case Document Entered on FLSD Docket Page of HERMAN MERMELSTEIN PA ATTORNEYS AT LAW Via Facsimile and U.S Mail Jack A Goldberger Esq Australian Avenue South Suite West Palm Beach FL March Re State of Florida Jeffrey Epstein Case No Dear Mr Goldberger Please be advised we represent intended for her to our office Thank you for your attention to this matter JMH/lr Jeffrey Herman Tel Fax jherman hermanlaw.com Biscayne Blvd Suite Miami Florida w.hermanlaw.com Please direct all communications Case Document Entered on FLSD Docket Page of HERMAN MERMELSTEIN PA ATTORNEYS AT LAW Via Facsimile and U.S Mail Jack A Goldberger Esq Australian Avenue South Suite West Palm Beach FL March Re State of Florida Jeffrey Epstein Case No Dear Mr Goldberger Jeffrey Herman Tel Fax jherman hermanlaw.com Biscayne Blvd Suite Miami Florida w.hermanlaw.com As you know we represent in all matters pertaining to Jeffrey Epstein If you plan on scheduling-for deposition please contact us to schedule to a date convenient for and myself In addition we would like to conduct a single deposition to be used for both the criminal and the civil matters Please let us know if you will agree to this or if we should seek court approval for same Of course we understand that the State Attorneys Office will need to agree to this as well and we have not yet contacted them for approval JMH/lr effrey Herman cc Lanna Leigh Belohlavek Asst State Attorney
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