Jane Doe No. 4
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Jeffrey Epstein
|
Abuser victim |
5
|
1 | |
|
person
Hayley Robson
|
Friend |
2
|
2 | |
|
person
Epstein
|
Legal representative |
2
|
2 | |
|
person
Jeffrey Epstein
|
Defendant seeking deposition of jane doe no 4 |
1
|
1 | |
|
person
Jeffrey Epstein
|
Intimidator victim |
1
|
1 | |
|
person
Adam D. Horowitz
|
Client |
1
|
1 | |
|
person
Jeffrey Epstein
|
Adversarial plaintiff defendant |
1
|
1 | |
|
person
Jeffrey Epstein
|
Adversarial |
1
|
1 | |
|
organization
IDA
|
Employment |
1
|
1 | |
|
person
Jeffrey Epstein
|
Legal representative |
1
|
1 | |
|
person
Florida Realty
|
Former employment |
1
|
1 | |
|
person
Preston Vinyard
|
Business associate |
1
|
1 | |
|
person
Jeffrey Epstein
|
Defendant plaintiff victim |
1
|
1 | |
|
person
Adam Horowitz
|
Client |
1
|
1 | |
|
person
Jeffrey Epstein
|
Litigant deponent |
1
|
1 | |
|
person
Kenneth A. Marra
|
Judge presiding over case involving |
1
|
1 | |
|
person
Jeffrey Epstein
|
Seeking deposition of |
1
|
1 | |
|
person
Vinyard
|
Friend |
1
|
1 | |
|
person
Ex-boyfriend
|
Romantic |
1
|
1 | |
|
person
Jeffrey Epstein
|
Defendant vs plaintiff |
1
|
1 | |
|
person
Jen
|
Friend |
1
|
1 | |
|
person
MR. EPSTEIN
|
Defendant plaintiff in lawsuit |
1
|
1 | |
|
person
Stuart S. Mermelstein
|
Counsel for jane doe no 4 |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Epstein 'accidentally' crossed paths with Jane Doe No. 4, stopped, stared, and intimidated her un... | On way to court-mandated de... | View |
| N/A | N/A | Psychiatric sessions for Jane Doe No. 4 at age sixteen or seventeen. | N/A | View |
| 2019-09-03 | N/A | Court Hearing (Case 1:19-cr-00490-RMB) | Southern District of New Yo... | View |
| 2014-12-30 | N/A | Ms. Giuffre (Jane Doe No. 3) and Jane Doe No. 4 filed a motion to join the case. | Court | View |
| 2009-09-17 | N/A | Jeffrey Epstein intimidated Jane Doe No. 4 by staring at her, causing her to become terrified, cr... | A building | View |
| 2009-09-16 | N/A | Deposition of Jane Doe No. 4, which Jeffrey Epstein will not attend. | N/A | View |
| 2009-09-16 | N/A | Lobby Incident / Confrontation | Lobby of 250 Australian Ave... | View |
| 2009-09-16 | N/A | Scheduled Deposition of Jane Doe No. 4 | 250 Australian Avenue South... | View |
| 2009-09-16 | N/A | Intimidation incident in the lobby. Epstein crossed paths with Jane Doe No. 4, stared her down, a... | Lobby of 350 Australian Ave... | View |
| 2009-09-16 | N/A | Scheduled deposition of Jane Doe No. 4. Jeffrey Epstein was stipulated not to attend in person bu... | 350 Australian Ave. South, ... | View |
| 2009-09-16 | N/A | Scheduled deposition of Jane Doe No. 4 at 1:00 p.m. Plaintiff's counsel advised Jane Doe No. 4 co... | Prose Court Reporting, 250 ... | View |
| 2009-08-19 | N/A | Defendant sent a Notice for Taking the Deposition of Jane Doe No. 4 | N/A | View |
| 2009-08-16 | N/A | Deposition of Jane Doe No. 4 was noticed for September 16, 2009. | N/A | View |
| 2009-07-17 | N/A | Jane Doe No. 4 signs declaration regarding harassment by Epstein's investigators. | Unknown | View |
| 2004-01-01 | N/A | Domestic violence file opened regarding Vinyard and Jane Doe No. 4. | N/A | View |
| 2004-01-01 | N/A | Battery report filed regarding Jane Doe No. 4 and Vinyard. | N/A | View |
| 2003-01-01 | N/A | Vinyard arrested for reckless driving and leaving the scene of an accident with Jane Doe No. 4. | N/A | View |
| 2002-01-01 | N/A | Serious relationship between Jane Doe No. 4 and Vinyard began. | N/A | View |
Jeffrey Epstein Part 22 of 22.pdf
This document contains court filings from September 2009 regarding a dispute over the deposition of 'Jane Doe No. 4' in the civil case Jane Doe No. 2 v. Jeffrey Epstein. The plaintiff's attorney, Adam Horowitz, cancelled the deposition after an alleged intimidation incident where Epstein and his driver, Igor Zinoviev, crossed paths with the plaintiff in the building lobby. Epstein's legal team (Critton and Luttier) filed for sanctions, arguing the encounter was coincidental as Epstein was leaving his office (Florida Science Foundation, same building) to avoid the deposition. The document includes affidavits from Epstein and Zinoviev denying interaction, invoices for the cancelled deposition costs, and a 2008 plea conference transcript defining 'no contact' orders.
Epstein_Part_22.pdf
This document contains a partial transcript from a plea conference for Jeffrey Epstein in Palm Beach County, Florida, on June 30, 2008, where the court detailed strict no-contact orders with victims. It also includes a declaration from Adam D. Horowitz dated September 16, 2009, describing a stipulation for Jeffrey Epstein not to physically attend Jane Doe No. 4's deposition, but to listen remotely, and an incident where Epstein crossed paths with Jane Doe No. 4 in a lobby.
017-01.pdf
This document is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Jane Doe in the United States District Court for the Southern District of Florida against Jeffrey Epstein. The plaintiff argues that Epstein's blanket invocation of Fifth Amendment privileges to refuse producing documents (such as phone records, tax returns, and correspondence) is improper and that he should be compelled to answer or provide a privilege log. The motion details specific discovery requests and Epstein's uniform response asserting his constitutional rights against self-incrimination.
016-13.pdf
This document is a Motion for Sanctions filed by Plaintiff Jane Doe No. 3 against Jeffrey Epstein on January 4, 2010. The motion alleges that Epstein flagrantly violated multiple court orders, including a No-Contact Order, by deliberately appearing at the location of the Plaintiff's Independent Medical Examination (IME) on November 24, 2009. The Plaintiff requests sanctions, attorney's fees, and a protective order moving the remainder of her IME to a different city, citing the trauma caused by the encounter.
016-12.pdf
This document is a Motion for Sanctions filed by Plaintiff Jane Doe No. 4 against Jeffrey Epstein for violating a no-contact order and a written stipulation. On September 16, 2009, Epstein appeared in the lobby of the building where Jane Doe No. 4's deposition was scheduled, staring her down and causing her to flee in distress, despite an agreement that he would not attend. The document includes a declaration from attorney Adam Horowitz, a transcript of the cancelled deposition where defense counsel Robert Critton argues Epstein was simply leaving his office in the same building, and an email confirming the prior stipulation.
016-05.pdf
This document is a motion filed on June 30, 2010, by Plaintiff Jane Doe requesting the modification of a court order regarding an upcoming settlement conference with Jeffrey Epstein. Doe requests that Epstein be kept in a secure, separate room to prevent any contact or intimidation, citing his status as a convicted sex offender and previous incidents where he intimidated victims, specifically Jane Doe No. 4, during court proceedings. The motion references Epstein's 2008 guilty plea and strict no-contact orders issued by both state and federal courts.
052.pdf
This document is a Motion for Protective Order filed on July 29, 2009, in the Southern District of Florida by Plaintiffs 'Jane Does 2-7' against Jeffrey Epstein. The plaintiffs allege that Epstein hired private investigators to harass and intimidate them by contacting their former employers, ex-boyfriends, and friends to ask intrusive personal questions and potentially 'out' them as sexual abuse victims. The motion seeks a court order to stop Epstein's investigators from making ex parte contacts with nonparties associated with the plaintiffs.
052-02.pdf
This document is a legal declaration by Jane Doe No. 4, filed on July 29, 2009. The declarant states that three investigators working for Jeffrey Epstein have been harassing her former employer (Florida Realty), a former co-worker, and her ex-boyfriend, asking intrusive personal questions. She expresses fear that this conduct exposes her identity as a plaintiff in a sexual abuse lawsuit to her social circle, potentially damaging her future employment and educational opportunities.
050.pdf
This document is a Notice of Compliance filed by Jeffrey Epstein's legal team (Burman, Critton, Luttier & Coleman) on July 28, 2009, in the US District Court for the Southern District of Florida. It addresses a court order regarding the preservation of evidence and a protective order, noting that while the parties agreed on many sections, they could not finalize a joint order, leading Epstein to submit his own proposed order separately. The document lists numerous related civil cases involving Jane Doe plaintiffs and provides a comprehensive service list of attorneys involved in the various Epstein-related litigations at that time, including Bruce Reinhart representing Sarah Kellen.
045.pdf
This document is a Motion to Compel filed by Plaintiff Jane Doe against Jeffrey Epstein on July 10, 2009, in the Southern District of Florida. The plaintiff lists 23 specific interrogatories regarding Epstein's finances, properties, travel, and alleged sexual abuse of minors, all of which Epstein refused to answer by invoking his Fifth and Sixth Amendment rights. The motion argues that Epstein's blanket refusals are improper and requests the court force him to answer or provide a privilege log.
043.pdf
This document is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the United States District Court, Southern District of Florida (Case No. 08-CV-80119-MARRA/JOHNSON). The motion argues that Epstein has improperly asserted blanket Fifth Amendment privileges in response to sixteen specific requests for production of documents, including telephone records, appointment books, financial records, and correspondence. The Plaintiff requests the Court to order Epstein to answer the requests, provide a particularized justification for his Fifth Amendment invocations, and produce a privilege log.
021.pdf
This document is a Notice of Filing Proposed Order submitted to the U.S. District Court for the Southern District of Florida on May 27, 2009. It lists eleven separate civil cases filed against Jeffrey Epstein by various plaintiffs, including Jane Does 2-7, 101, 102, C.M.A., and Doe II. The filing serves to submit a proposed order related to case no. 08-80119 and includes a service list of attorneys involved in the litigation.
006.pdf
This document is a Court Order from the United States District Court Southern District of Florida, dated April 28, 2009, presided over by Judge Kenneth A. Marra. The order grants the Plaintiffs' motion for a protective order against piecemeal depositions, limiting Jeffrey Epstein (Defendant) to a single deposition of each plaintiff across ten related civil cases. It also consolidates four specific cases (08-80119, 08-80232, 08-80380, and 08-80993) for the purposes of discovery and orders parties in the remaining six cases to show cause why they should not also be consolidated.
040.pdf
This document is a Motion to Compel filed on July 10, 2009, in the US District Court for the Southern District of Florida by Plaintiff Jane Doe (represented by Bradley Edwards). The motion requests the court to force Jeffrey Epstein to answer a set of interrogatories regarding his financial assets, net worth, foreign travel, property ownership, and alleged interactions with the plaintiff and other minor females. Epstein refused to answer nearly all questions (except for providing the name/address of the person answering), invoking his Fifth and Sixth Amendment rights against self-incrimination and right to counsel.
039.pdf
This legal filing is a Motion to Compel submitted by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the United States District Court for the Southern District of Florida. The motion requests the court to order Epstein to answer 23 specific requests for admission regarding his net worth, asset transfers, and allegations of sexual abuse and trafficking of minors, which he had previously refused to answer by asserting Fifth Amendment privileges. The plaintiff argues that Epstein's blanket assertion of the privilege is improper and that he must provide a particularized justification for each refusal or face an adverse inference.
030.pdf
This document is a 'Notice of Joinder' filed on June 8, 2009, in the US District Court for the Southern District of Florida, where Plaintiffs Jane Does 2-7 join a motion for a no-contact order against Jeffrey Epstein. The filing alleges that Epstein's associate and recruiter, Hayley Robson, has been harassing victims Jane Does 4 and 7 through text messages and in-person threats while claiming to be financially supported by and cooperating with Epstein. The plaintiffs request a court order prohibiting Epstein from any direct or indirect contact with the victims.
024.pdf
This document is a legal motion filed on May 29, 2009, in the Southern District of Florida by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein. The plaintiffs request leave to file their response to Epstein's motion to stay under seal because it references the confidential Non-Prosecution Agreement (NPA), or alternatively, to unseal the NPA. The document includes a comprehensive service list detailing the legal representation for Epstein (including Robert Critton and Jack Goldberger), Sarah Kellen (represented by Bruce Reinhart), and numerous other Jane Doe plaintiffs.
020.pdf
This document is a 'Notice of Limited Appearance' filed on May 29, 2009, in the United States District Court for the Southern District of Florida. It lists multiple civil cases involving Jane Doe plaintiffs against Jeffrey Epstein. The United States, represented by Assistant U.S. Attorney A. Marie Villafaña (under U.S. Attorney R. Alexander Acosta), files this notice to respond to a court order regarding Epstein's 'Motion to Stay Proceedings,' while explicitly stating the U.S. is not becoming a party to the litigation.
016-03.pdf
This document is a Court Order from the Southern District of Florida, dated May 26, 2009, granting a motion to preserve evidence in multiple civil cases against Jeffrey Epstein. Judge Kenneth A. Marra orders Epstein and his associates to preserve a wide range of materials, specifically highlighting records of domestic and international travel (including private airplanes), phone communications, financial records, and evidence related to the October 25, 2005 police search of his Palm Beach mansion. The order explicitly prohibits the destruction, alteration, or deletion of potential evidence dating back to 1998.
013.pdf
This document is a legal notice filed on May 20, 2009, in the U.S. District Court for the Southern District of Florida, involving multiple consolidated cases against Jeffrey Epstein. Plaintiff C.M.A. formally withdraws her objections to Epstein's motion to identify her by her legal name in the case style and in third-party subpoenas, rendering the motion to dismiss moot, though she continues to object to dismissal on alternative grounds. The document lists numerous 'Jane Doe' plaintiffs and provides a service list of attorneys representing both the plaintiffs (Jack Scarola, Jack P. Hill) and the defendant (Richard Willits, Robert Critton, Jack Goldberger, Bruce Reinhart).
066-02.pdf
A declaration by Jane Doe No. 4 filed on July 29, 2009, stating that three investigators working for Jeffrey Epstein had recently contacted her former employer, Florida Realty. She alleges these investigators harassed her former employer, a co-worker, and her ex-boyfriend with personal questions, threatening her anonymity in the sexual abuse lawsuit.
064.pdf
This document is a 'Notice of Compliance' filed on July 28, 2009, by Jeffrey Epstein's legal team in the U.S. District Court for the Southern District of Florida. It pertains to multiple civil cases filed by 'Jane Doe' plaintiffs against Epstein. The filing states that while the court ordered the parties to agree on a preservation of evidence order, they were unable to reach a full agreement, leading Epstein to submit his own proposed order. The document includes a comprehensive service list detailing the attorneys representing the various plaintiffs and defendants, including Sarah Kellen.
064-01.pdf
This document is a Court Order from the Southern District of Florida (Exhibit A), signed by Judge Kenneth A. Marra, granting a motion to preserve evidence in multiple civil cases against Jeffrey Epstein. The order mandates that Epstein and his agents preserve a wide range of materials, specifically including records of domestic and international travel on private airplanes, phone communications, computer data, and items resulting from the October 25, 2005 search of his Palm Beach home. It establishes preservation timelines ranging from 1998 to 2005 depending on the specific plaintiff and defines sanctions for wrongful destruction of evidence.
061.pdf
This document is a Motion to Compel filed on July 10, 2009, in the Southern District of Florida by Plaintiff Jane Doe against Defendant Jeffrey Epstein. The motion seeks to force Epstein to answer 23 specific Requests for Admission regarding his net worth (specifically if it exceeds $1 billion), his financial support of modeling agency MC2, his ownership of Caribbean property, and specific allegations of sexual battery, assault, and sex trafficking of minors. Epstein had previously refused to answer these questions by invoking his Fifth Amendment privilege against self-incrimination.
045.pdf
This document is a 'Notice of Joinder' filed on June 8, 2009, in the US District Court for the Southern District of Florida, where Plaintiffs Jane Does 2-7 join a motion for a 'No-Contact Order' against Jeffrey Epstein. The filing alleges that Epstein's associate, Hayley Robson (who originally recruited the victims), has been harassing Jane Does 4 and 7 via text messages and in-person threats while claiming to be financially supported by Epstein. The plaintiffs argue that a court order is necessary to prevent Epstein from contacting or harassing victims through third parties like Robson.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| N/A | Received | Epstein | Jane Doe No. 4 | $0.00 | Claims being pursued by Jane Doe No. 4 against ... | View |
Epstein Case
I just met with my lawyer today and I’m finally done with the Epstein case. LOL. I knew you were suing Jeffrey all along and I’ve learned so much about you in the meantime. LOL.
Epstein Case
I just met with my lawyer today and I’m finally done with the Epstein case. LOL. I knew you were suing Jeffrey all along and I’ve learned so much about you in the meantime. LOL.
Harassment
Various messages seeking information about Jane Doe 4's private life, lawsuit, and lawyer's strategy (Since February 2009).
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