Helaine S. Goodner
PersonRelationship Network
027.pdf
Legal stipulation filed on December 13, 2010, in the Southern District of Florida, dismissing the case of M.J. vs. Jeffrey Epstein and Sarah Kellen with prejudice. The document confirms a settlement was reached, with the court retaining jurisdiction to enforce its terms, and states that each party will bear their own attorney's fees.
025.pdf
This document is an unopposed motion filed on November 29, 2010, by Jeffrey Epstein's legal team requesting a 10-day extension to respond to two plaintiff motions regarding protective orders and evidence preservation. The motion states that the parties are currently in discussions to resolve the matters and that plaintiff's counsel, Gary Farmer, does not oppose the extension. The document lists M.J. as the plaintiff and Jeffrey Epstein and Sarah Kellen as defendants.
022.pdf
This document is a legal motion filed on November 23, 2010, in the United States District Court for the Southern District of Florida (Case 9:10-CV-81111-WPD). Attorney Bradley J. Edwards requests the court to admit Paul G. Cassell (a member of the Utah Bar) to appear pro hac vice as co-counsel for the plaintiff, identified as M.J., in a civil suit against Jeffrey Epstein and Sarah Kellen. The document documents the payment of a $75 admission fee and lists the defense counsel for Jeffrey Epstein from the firm Fowler White Burnett PA.
020.pdf
This document is a Reply in Support of a Motion to Quash Service of Process filed by Jeffrey Epstein's legal team in November 2010. The defense argues that the plaintiff failed to properly serve Epstein because the papers were left with an individual named 'Mark' at Epstein's New York home (9 East 71st St), but the plaintiff failed to prove 'Mark' resided there or was of suitable discretion. The filing also seeks to strike allegations regarding obstruction of justice in prior litigation and opposes sanctions against Epstein.
016.pdf
This document is a Motion for a Protective Order filed by plaintiff M.J. on November 11, 2010, requesting the court bar Jeffrey Epstein from direct or indirect contact. The motion details a pattern of Epstein using private investigators to harass and intimidate victims and witnesses, specifically citing an incident on July 1, 2010, where a PI named Thaddeus Knowles followed 'Jane Doe' and flashed lights into her home. It also references Epstein's intimidation of other witnesses including Sarah Kellen, Leslie Groff, and Alfredo Rodriguez, and his history of violating no-contact orders.
014.pdf
A legal motion filed on November 10, 2010, by Jeffrey Epstein's attorneys requesting the court to quash service of process in the case of M.J. v. Epstein. The defense argues that leaving an unmarked envelope in the mailbox of Epstein's New York vacation home and claiming to leave papers with a non-existent person named 'Mark' violates Federal, New York, and Florida service laws. The document includes arguments citing specific statutes and an affidavit from Richard Barnett denying the presence of anyone named 'Mark' at the residence.
010.pdf
This document is a legal notice filed on November 2, 2010, in the United States District Court for the Southern District of Florida (Case 9:10-cv-81111) by the plaintiff, identified as M.J. The filing strikes two previous certificates of service (DE 5 and DE 6) related to a summons and a subpoena for defendant Jeffrey Epstein due to incorrect filing. The document names Jeffrey Epstein and Sarah Kellen as defendants and lists contact information for attorneys representing both sides.
007.pdf
This document is a Motion to Quash Service of Process filed by Jeffrey Epstein's legal team on October 29, 2010, in the Southern District of Florida. Epstein's lawyers argue that the plaintiff, 'M.J.', failed to properly serve Epstein with the lawsuit because the documents were merely left in an unmarked envelope in the mailbox of his New York residence (9 East 71st Street) rather than being delivered personally as required by law. The document details the specific dates of the attempted service and cites Florida, New York, and Federal laws to support the argument that the service was legally ineffective.
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