This document is a legal motion filed on November 9, 2009, by Igor Zinoviev, a third-party witness and employee of Jeffrey Epstein, seeking a protective order to prevent or limit his deposition in the civil case 'Jane Doe No. 2 v. Jeffrey Epstein'. Zinoviev claims he has no relevant information for the civil cases as his employment with Epstein began in November 2005, after the period of the alleged misconduct, and he has not discussed Epstein's criminal or civil cases with him.
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.
This document is a motion filed by Jeffrey Epstein's legal team on August 8, 2008, requesting an extension to file a response to the complaint in the case of Jane Doe #1. Epstein's lawyers argue that the deadline should be aligned with parallel cases (Jane Doe Nos. 2-5) to September 4, 2008, to promote judicial economy. The document notes that co-defendants Haley Robson and Sarah Kellen had not yet been served at the time of filing.
Defendants Jeffrey Epstein and Sarah Kellen filed a request for oral argument on July 25, 2008, in the Southern District of Florida regarding a motion to stay civil proceedings pending the resolution of a criminal action. The document lists legal representation for all parties, including Jane Doe (Plaintiff) and Haley Robson (Co-Defendant). Attorneys Michael R. Tein and Guy A. Lewis are the primary signatories for Epstein.
This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, seeking a protective order to prevent or limit his deposition in the case of Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, a driver and bodyguard for Epstein since November 2005, claims he has no relevant information regarding Epstein's criminal or civil cases, particularly concerning events prior to September 2005. The motion cites legal precedents regarding the scope of discovery and Federal Rules of Civil Procedure Rule 26(c) to argue against the deposition.
This document is an Emergency Motion filed on June 14, 2010, by Jeffrey Epstein's legal team to quash a subpoena and prevent the deposition of Maritza Milagros Vasquez, scheduled for the following day. Epstein's lawyers argue that the subpoena issued by C.L.'s counsel (Spencer Kuvin) is premature under Rule 26(d) and that the cross-notice by Jane Doe's counsel (Brad Edwards) is invalid because discovery in the Jane Doe case had already concluded on May 31, 2010. The document includes the motion, a subpoena exhibit, and a cross-notice exhibit.
This document is an architectural blueprint or floor plan for a property, likely part of the Epstein estate given the context (EFTA bates stamp). It details the layout of a level at 'LEV + 120 FT', featuring an office, library, staircase, water gardens (with lotus), garden fountains, loggia, dining area, kitchen, sound/music room, and a courtyard. Handwritten notes and dimensions are annotated over the printed plan.
This document is a legal notice from Ricci~Leopold, P.A., dated June 18, 2008, informing all counsel that hearings scheduled for that day have been cancelled. The hearings pertained to Defendant Jeffrey Epstein's Motion for Enlargement of Time and Defendant Haley Robson's Motion to Quash Service of Process in the case of Jane Doe vs. Jeffrey Epstein, Haley Robson, and Sarah Kellen, filed in Palm Beach County, Florida.
This is a letter dated February 5, 2008, from attorney Theodore J. Leopold of the Ricci~Leopold law firm to Judge Sandra K. McSorley. The letter serves as a cover for the enclosed 'Motion For Protective Order' filed on behalf of 'Jane Doe' in the criminal case of State of Florida v. Jeffrey Epstein (Case No. 2006 CF 009454 A). Leopold requests ten minutes of the court's time to present the motion.
This is a letter dated February 21, 2008, from attorney Theodore J. Leopold to attorney Jack A. Goldberger regarding the case of 'Jane Doe v. Epstein'. Leopold expresses serious ethical concerns about Goldberger's co-counsel, who refused to share copies of exhibits after a direct examination the previous day. Leopold writes to confirm a prior agreement that Goldberger will provide copies of all exhibits to him and the State Attorney, highlighting a potential conflict or lack of cooperation among the legal team.
This document appears to be page 92 of a manuscript or memoir, stamped by the House Oversight Committee (likely from the Epstein investigation). The text is a first-person philosophical reflection on the after-effects of using "entheogenic agents" (psychedelics), describing how they enhanced the author's aesthetic sensitivity to nature (Boboli Gardens) and art (Guggenheim Museum). The author references religious and philosophical concepts, citing Mircea Eliade, Abraham Abulafia, and Rudolf Otto to describe a state of "hierophany" or sacred revelation.
A scanned page from an address book containing contact details for individuals with surnames starting with 'S' and 'T'. Entries include names, addresses, phone numbers, and email addresses for people such as Allison & Leonard Stern, Hugo Swire, and Paul Taaffe.
This document is a page from a contact book or 'black book' (page 55), oriented sideways. It contains alphabetical entries for individuals with surnames starting with 'S', including Susie Shuster, Peggy Siegal, William Siegel, Henry Silverman, and Rupert Soames. The entries include high-profile business contacts, listing home and work addresses (NYC, London, Indianapolis), phone numbers (including specific lines for 'Boat phone' and 'Car phone'), and email addresses.
This document is a page from an address book (likely Jeffrey Epstein's 'Little Black Book') containing contact information for individuals with surnames starting with R and S. It lists high-profile figures including members of the Rothschild family, the Duke and Duchess of Rutland, Jeffrey Sachs, and Edmund Safra, along with personal notes such as 'Catherine's friend' for Natalie Rucellai and 'Cute S african' for Wayne Safro. The page includes residential and business addresses in New York, London, and Paris, as well as phone numbers and email addresses.
This document is page 47 from an address book (likely Epstein's 'Little Black Book') containing contact information for individuals with surnames starting with O and P. It lists high-profile individuals such as Andres Pastrana (Ex-President of Colombia), hedge fund manager John Paulson, and venture capitalist Alan Patricof. The entries include detailed addresses in New York, London, Paris, Bogota, and Madrid, along with extensive phone numbers and some email addresses. The document bears the stamp 'GIUFFRE001619' and 'HOUSE_OVERSIGHT_014173'.
This document is a page from a contact book (likely Jeffrey Epstein's 'Black Book') containing entries for individuals with surnames starting with K and L. Notable entries include Henry Kissinger (listed with multiple addresses including Washington DC), David Koch, and 'Boby Kotic' (linked to an Activision email address, likely Bobby Kotick). The list contains detailed contact information including home and work addresses, phone numbers, and email addresses for individuals in London, New York, Paris, and Lagos.
This document is a page (marked 31) from an address book, likely Jeffrey Epstein's 'Little Black Book'. It contains contact information for individuals sorted alphabetically from 'H', including notable figures such as actor Dustin Hoffman, India Hicks, and beer magnate Fredie Heineken. The entries include addresses in New York, London, France, and the Bahamas, along with phone numbers and occasional email addresses.
This document is a page from an address book (likely Jeffrey Epstein's 'Little Black Book') containing contact information for individuals alphabetized under 'Fe' and 'Fi'. Notable entries include actor Ralph Fiennes, musician Brian Ferry, hairstylist Frederic Fekkai, and Princess Firyal of Jordan. The page lists addresses, multiple phone numbers (home, work, cell, fax), and email addresses for various high-profile individuals in London, New York, and Italy.
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