WEST PALM BEACH, FLORIDA
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013-02.pdf
This document is a Notice of Withdrawal of Motion for Partial Summary Judgment filed on April 8, 2016, in a Florida Circuit Court case between Bradley J. Edwards/Paul G. Cassell and Alan M. Dershowitz. The plaintiffs withdraw their motion pursuant to a confidential settlement agreement but explicitly state that their client, Virginia Giuffre, reaffirms her allegations and that the withdrawal is not an admission that her allegations were mistaken. They concede that filing certain allegations in a separate Crime Victims' Rights Act case was a 'tactical mistake' that caused distractions.
010-12.pdf
This document is a Protective Order designated as Exhibit L (and Exhibit 1) in Case 08-80736-CIV-MARRA/JOHNSON, filed in May 2014. Issued by Judge Kenneth Marra, it grants a motion by Intervenors (led by Roy Black) to keep correspondence between themselves and the United States Attorney's Office confidential ('CDM'). The order establishes strict protocols for the handling, marking, and limited disclosure of these materials during the litigation between Jane Does #1-2 and the United States.
010-11.pdf
This is a court order from September 2014 in the case of Jane Doe v. United States, concerning Jeffrey Epstein's intervention. Judge Kenneth Marra granted in part and denied in part Epstein's motion for a protective order regarding correspondence between his lawyers and the US Attorney's Office. While the court agreed to restrict dissemination of materials to the press to avoid publicity in this 'high profile' case, it rejected Epstein's request to automatically require court permission to seal every future filing.
006.pdf
This document is a motion filed on June 29, 2016, by attorneys for Ghislaine Maxwell in the Southern District of Florida. The motion requests permission to file specific exhibits (A, G, H, I, and N) under seal because they were designated as confidential in the underlying case (Giuffre v. Maxwell) in the Southern District of New York. The document includes a certificate of service indicating the motion was served electronically to attorney Jack Scarola representing Bradley J. Edwards.
001-01.pdf
Legal declaration by attorney Bradley J. Edwards filed on June 13, 2016, in support of a motion to quash a subpoena from Ghislaine Maxwell. Edwards details his representation of Virginia Giuffre and the undue burden of reviewing over 200,000 emails for communications with journalists. He explicitly states that Ghislaine Maxwell and Jeffrey Epstein share a joint defense agreement and mentions Giuffre's association with the organization 'Victims Refuse Silence, Inc.'
080-01.pdf
This document is a Final Order of Dismissal with Prejudice from the U.S. District Court for the Southern District of Florida, dated June 2010 (entered on docket June 30, 2010). Judge Kenneth A. Marra dismissed the case brought by Plaintiff Jane Doe II against Defendants Jeffrey Epstein and Sarah Kellen following a settlement stipulation by the parties. The court retained jurisdiction specifically to enforce the terms of said settlement.
074.pdf
An Omnibus Order from the U.S. District Court for the Southern District of Florida in the case of Jane Doe No. 2 v. Jeffrey Epstein. The order, signed by Magistrate Judge Linnea R. Johnson, addresses eight specific motions filed between March and November 2009 across multiple related case numbers. Most motions were stricken for not being filed in the Lead Case No. 08-80119, while one defendant motion was granted nunc pro tunc and a third-party motion by 'Zinoview' was denied as moot.
073.pdf
This document is a legal response filed on November 28, 2009, by Plaintiff Carolyn M. Andriano (Jane Doe No. 2) in her civil case against Jeffrey Epstein. The filing opposes a motion by third-party witness Igor Zinoview—Epstein's driver, bodyguard, and trainer since November 2005—who sought to avoid being deposed by claiming he had no knowledge of relevant facts. The Plaintiff argues that Zinoview must be deposed because he worked for Epstein during the active Palm Beach Police investigation (2005-2006) and likely possesses knowledge regarding activities at the Epstein residence, especially since Epstein himself invoked the Fifth Amendment.
056-01.pdf
A court order from the Southern District of Florida dated August 2009 in the case of Jane Doe II vs. Jeffrey Epstein and Sarah Kellen. Judge Kenneth A. Marra grants Sarah Kellen's request to adopt co-defendant Jeffrey Epstein's Motion to Dismiss and Reply as her own arguments in the case.
048.pdf
This is a legal reply filed by Sarah Kellen's attorney in July 2009, requesting the court set aside a default judgment in the case brought by Jane Doe II. The document argues that service of process in New York was legally deficient because the 'nail and mail' method was used without proper due diligence (attempts were made when Kellen was known to be out of town) and that the default was entered prematurely before the response deadline. Kellen also asserts a meritorious defense, stating she did not conspire with Jeffrey Epstein to commit sexual battery and was unaware of what occurred privately between Epstein and the Plaintiff.
047.pdf
This document is a Plaintiff's Memorandum of Law filed on July 14, 2009, in the case of Jane Doe II v. Jeffrey Epstein and Sarah Kellen. The Plaintiff opposes Sarah Kellen's motion to set aside a default judgment, arguing that Kellen was properly served via 'nail and mail' in New York on April 23, 2009, after six attempts, and deliberately ignored the lawsuit. The filing asserts Kellen has provided no evidence she didn't receive service and has failed to present a meritorious defense as required by law.
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.
005.pdf
This document is a court order from March 30, 2009, in the case of Jane Doe II vs. Jeffrey Epstein and Sara Kellen (Case No. 09-80469-CIV-MARRA) in the Southern District of Florida. Judge Kenneth A. Marra orders counsel to confer and file a joint scheduling and discovery report pursuant to Federal Rules of Civil Procedure. The order outlines specific deadlines for pretrial discovery planning and scheduling conferences.
004.pdf
This document is an Order of Transfer from the United States District Court for the Southern District of Florida, dated March 2009. Judge Kenneth L. Ryskamp transfers the case of Jane Doe II v. Jeffrey Epstein and Sarah Kellen (Case No. 09-80469) to Judge Kenneth A. Marra. The transfer is ordered because the case is related to several lower-numbered cases already assigned to Judge Marra (including 08-80069, 08-80119, etc.).
003.pdf
This document is an 'Order of Pretrial Procedures' from the U.S. District Court, Southern District of Florida, dated March 25, 2009, in the civil case of Jane Doe II vs. Jeffrey Epstein and Sarah Kellen. It outlines the procedural requirements for the case, including deadlines for scheduling meetings, reports, and discovery planning, and warns of sanctions for non-compliance. The document also includes a sample 'Scheduling Order' template detailing rules for pretrial stipulations, jury instructions, and witness lists.
021.pdf
This document is an 'Opposition to Remand Motion' filed by defendants Jeffrey Epstein and Sarah Kellen in September 2008 in the Southern District of Florida. The defendants argue that the case should remain in federal court because the plaintiff fraudulently joined co-defendant Haley Robson (a Florida resident) solely to destroy diversity jurisdiction. The filing contends that the plaintiff has no valid cause of action against Robson for civil conspiracy, intentional infliction of emotional distress (IIED), or civil RICO under Florida law, arguing that Robson's alleged actions do not meet the legal standards for these torts.
019.pdf
Defendant Jeffrey Epstein moves to dismiss Counts I (sexual assault), II (civil conspiracy), and IV (civil RICO) of Jane Doe's amended complaint. The motion argues that the sexual assault claim improperly relies on a criminal statute with no private right of action, the conspiracy claim lacks an actionable underlying tort, and the RICO claim fails to allege a direct injury resulting from a predicate act. The document outlines relevant Florida case law and statutes to support the dismissal of these claims.
018.pdf
This document is a Motion for Stay filed by defendants Jeffrey Epstein and Sarah Kellen in a civil lawsuit brought by Jane Doe. They argue that a stay is mandatory under federal law because of a pending federal criminal investigation/action (the deferred prosecution agreement). Attached is a declaration from AUSA A. Marie Villafana detailing the government's interaction with victims (T.M., C.W., S.R.) and providing copies of notification letters sent to them and their attorneys regarding their rights and the non-prosecution agreement.
017.pdf
This document is a Motion to File Under Seal submitted by defendants Jeffrey Epstein and Sarah Kellen on July 25, 2008, in the case of Jane Doe v. Epstein et al. The defendants request to seal their 'motion for stay' to protect a confidential agreement between Epstein and the U.S. Attorney's Office for the Southern District of Florida. The document includes certificates of compliance and service, noting that the plaintiff opposes the motion, and lists the legal counsel representing all parties involved.
014.pdf
This document is a legal response filed on August 22, 2008, by Jeffrey Epstein's legal team in the case of Jane Doe vs. Jeffrey Epstein, Haley Robson, and Sarah Kellen. Epstein's lawyers state they have no opposition to the plaintiff's Motion to Preserve Evidence (DE 12). However, they dispute the plaintiff's certification of compliance, arguing that plaintiff's counsel filed the motion prematurely without properly conferring with the defense or waiting for a return call regarding Epstein's position.
006.pdf
This document is a court order from August 5, 2008, in the case of Jane Doe v. Jeffrey Epstein, Haley Robson, and Sarah Kellen. Judge Kenneth A. Marra denied the defendants' motion to file documents under seal, ruling that the U.S. Attorney's objections and confidentiality clauses did not outweigh the public's right to access court records, ordering the clerk to unseal specific docket entries.
001.pdf
This document is a Notice of Removal filed by defendants Jeffrey Epstein, Sarah Kellen, and Haley Robson, seeking to move a civil lawsuit filed by Jane Doe from the Circuit Court of the Fifteenth Judicial Circuit in Palm Beach County, Florida, to the United States District Court for the Southern District of Florida. The defendants argue that the non-diverse defendant, Haley Robson, was fraudulently joined solely to defeat diversity jurisdiction and prevent removal. Attached as Exhibit A is a deposition transcript of Jane Doe (whose name is redacted) taken on February 20, 2008, in a related criminal case, where she is questioned about her age, MySpace profiles, inconsistencies in her statements to police regarding sexual contact with Epstein, and her interactions with various attorneys and law enforcement officials.
010.pdf
This is a Final Order of Dismissal from the United States District Court, Southern District of Florida, dated February 28, 2008. The case (08-80069-CIV-MARRA/JOHNSON) involves Jane Doe No. 1 and family members as Plaintiffs against Jeffrey Epstein as Defendant. Judge Kenneth A. Marra dismissed the case without prejudice and denied all pending motions as moot following the Plaintiff's Notice of Voluntary Dismissal.
003.pdf
This document is a court order from the U.S. District Court for the Southern District of Florida in the case of Jane Doe No. 1 vs. Jeffrey Epstein (Case No. 08-80069-CIV-MARRA). Dated January 28, 2008, Judge Kenneth A. Marra orders counsel to confer and file a joint scheduling and discovery report. It outlines procedural deadlines for pretrial discovery and scheduling conferences pursuant to Federal Rules of Civil Procedure.
032.pdf
This is a Final Order of Dismissal with Prejudice from the US District Court for the Southern District of Florida, dated June 25, 2010. Judge Kenneth A. Marra dismissed the civil lawsuit brought by Jane Doe No. 8 against Jeffrey Epstein following a settlement agreement between the parties. The court retained jurisdiction specifically to enforce the terms of that settlement.
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