Jack Alan Goldberger
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Jeffrey Epstein
|
Client |
19
Very Strong
|
19 | |
|
person
Jeffrey Epstein
|
Legal representative |
9
Strong
|
5 | |
|
person
Marc S. Nurik
|
Legal representative |
7
|
2 | |
|
person
Christopher E. Knight
|
Legal representative |
6
|
1 | |
|
person
Jeffrey Epstein
|
Counsel for defendant |
1
|
1 | |
|
person
SARAH KELLEN
|
Client |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2010-03-23 | N/A | Videotaped Deposition of Bradley J. Edwards | 2139 Palm Beach Lakes Boule... | View |
| 2009-11-09 | N/A | Third Party Witness, Igor Zinoviev's Motion for Protective Order and Incorporated Memorandum of L... | Southern District of Florid... | View |
| 2009-11-01 | N/A | Filing of Third Party Witness, Igor Zinoviev's Motion for Protective Order and Incorporated Memor... | Southern District of Florida | View |
| 2009-09-17 | N/A | Deposition scheduled but canceled due to an incident involving Jeffrey Epstein and the plaintiff. | Florida Science Foundation ... | View |
061.pdf
This document is a Supplemental Appendix filed by Palm Beach Newspapers, Inc. in a Florida state court case involving Jeffrey Epstein. It contains a transcript of a June 2009 hearing regarding the unsealing of court records, administrative orders, case law, and federal court filings including a declaration by AUSA A. Marie Villafana regarding the federal Non-Prosecution Agreement (NPA). The appendix documents the legal arguments surrounding the transparency of the Epstein proceedings and the government's interaction with victims under the Crime Victims' Rights Act.
060.pdf
This document is a response filed by Palm Beach Newspapers, Inc. (The Palm Beach Post) to an emergency petition for writ of certiorari by Jeffrey Epstein. The Post argues that the trial court correctly unsealed a Non-Prosecution Agreement (NPA) and its addendum related to Epstein's solicitation of minors, asserting that the documents were improperly sealed in the first instance and that no valid legal basis exists for their continued closure.
035.pdf
This document is a motion filed on June 2, 2009, by The Palm Beach Post seeking to intervene in the criminal case against Jeffrey Epstein to unseal a non-prosecution agreement and its addendum. The Post argues that the sealing was improper, lacked necessary legal findings, and that the documents are of significant public interest given the accusations of soliciting minors. The document cites numerous civil lawsuits against Epstein and criticizes the secrecy surrounding his plea deal.
017-19.pdf
Plaintiff Jane Doe filed an emergency motion to hold Jeffrey Epstein in contempt for failing to comply with discovery orders in a civil case (08-CV-80893). The motion alleges that Epstein failed to produce state criminal discovery materials and provided only heavily redacted correspondence with the U.S. Attorney's Office, obscuring the defense counsel's side of the communications. Doe seeks immediate production of unredacted documents, sanctions of $5,000 against Epstein's counsel, and a ruling that withheld materials be deemed admissible at trial.
017-17.pdf
This document is a Motion for Protective Order filed on June 30, 2010, by Jeffrey Epstein's defense team in the civil case Jane Doe v. Jeffrey Epstein. Epstein seeks permission to redact specific portions of his tax returns regarding investment vehicles, claiming they contain trade secrets and confidential business information. The motion argues that Plaintiff's counsel, Brad Edwards, has a history of sharing discovery material with media and investigators, specifically citing an instance involving Alfredo Rodriguez's journal.
017-15.pdf
This document is a Motion for Protective Order filed on June 28, 2010, by Jeffrey Epstein's legal team in the case of Jane Doe No. 2 vs. Jeffrey Epstein. The motion requests that the court issue an order of confidentiality regarding information Epstein was compelled to produce, specifically his tax returns, passport, and information provided by the federal government during prior criminal proceedings. The defense seeks to prevent this information from being disclosed to third parties or the media and to limit its use strictly to the current litigation.
017-13.pdf
This document is a protective response filed by Plaintiff Jane Doe on May 27, 2010, in the Southern District of Florida case against Jeffrey Epstein. The plaintiff requests the court to promptly order the production of tax returns and other documents that Epstein has withheld on Fifth Amendment grounds, emphasizing that the trial date is set for July 19, 2010. The filing notes that negotiations with Epstein's counsel failed and lists numerous related cases and attorneys involved.
017-09.pdf
This document contains a Motion for Reconsideration filed by Jeffrey Epstein's legal team in February 2010, arguing against a Magistrate's order compelling him to produce sensitive documents. The motion relies heavily on Fifth Amendment protections against self-incrimination, arguing that despite a Non-Prosecution Agreement, Epstein faces real risks of prosecution in other jurisdictions. Attached exhibits include the Plaintiff's 2009 requests for production of massage logs, photos of Epstein's Palm Beach home, financial records, and medical records from Dr. Stephan Alexander, to which Epstein consistently objected.
017-02.pdf
This document is a legal response filed by Jeffrey Epstein's legal team on October 6, 2009, opposing a Motion to Compel discovery filed by Plaintiff Jane Doe No. 2. Epstein asserts his Fifth Amendment privilege against self-incrimination to refuse the production of photographs of his Palm Beach home (specifically massage rooms), financial records, tax returns, passport/travel records, and medical records from Dr. Stephan Alexander. The defense argues that despite the Non-Prosecution Agreement (NPA), the threat of federal prosecution remains real and substantial, particularly in districts outside the Southern District of Florida, and that the act of producing these documents would be testimonial and incriminating.
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.
017.pdf
This document is a legal notice filed on June 14, 2010, in the United States District Court for the Southern District of Florida, regarding the case of Jane Doe No. 2 v. Jeffrey Epstein. The filing, submitted by attorney Spencer T. Kuvin on behalf of Plaintiff 'C.L.', serves to withdraw a subpoena and cancel the scheduled deposition of Maritza Milagros Vasquez, which was set for the following day, June 15, 2010. The document also includes a certificate of service listing various attorneys representing different parties in related cases against Epstein.
015.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) opposing Jeffrey Epstein's appeal of a Magistrate Judge's order compelling him to produce income tax returns for the years 2003-2008. The Plaintiffs argue that tax returns are 'required records' not protected by the Fifth Amendment privilege against self-incrimination and are critical for determining punitive damages. The document notes that Epstein attempted to avoid producing these records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs rejected as insufficient.
010.pdf
This is a motion filed by Defendant Jeffrey Epstein's attorneys requesting a court order to allow him to attend mediation, deposition, and trial in the case of Jane Doe No. 2 v. Jeffrey Epstein. The motion notes that a prior no-contact order involving Carolyn Andriano might technically preclude this, but states that Plaintiff's counsel and Ms. Andriano have no objection. The document includes a certificate of service listing numerous attorneys involved in related cases.
009.pdf
Legal filing from November 2009 in the case of Jane Doe No. 2 v. Jeffrey Epstein. Epstein's attorneys argue for the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), noting that the DOJ has seized boxes of documents from RRA, including 13 boxes related to Epstein. The document also disputes delays in the deposition of RRA's Chief Restructuring Officer, Herbert Stettin, citing upcoming trial deadlines.
008.pdf
This document contains a Motion for Protective Order filed by Igor Zinoview and Jeffrey Epstein to limit the scope of depositions in a civil case. Zinoview asserts via affidavit that he only began working for Epstein in November 2005, after the alleged events, and thus has no relevant knowledge. The filing also includes excerpts from the depositions of Epstein's pilots, Larry Visoski and Larry Eugene Morrison, where they are questioned about their personal beliefs regarding the sexual abuse allegations and whether they would trust Epstein with their own daughters. Flight logs and passenger manifests are referenced in the deposition indexes ('PLAINTIFF'S EX. 1 FLIGHT LOG BOOK' and 'JEGE, Inc., Passenger Manifest') but the actual log content is not present in these specific pages.
ORDER-SHOW%20CAUSE%20(TAG-DECLINE%20JURIS).pdf
A corrected order from the Supreme Court of Florida dated May 3, 2017, in the case of Jeffrey Epstein vs. Bradley J. Edwards. The court orders the Petitioner (Epstein) to show cause by May 18, 2017, why the court should not decline jurisdiction based on the precedent of Debrincat v. Fischer. The document lists service to several attorneys including Marc S. Nurik and Jack Alan Goldberger.
ORDER-FILING%20FEE%20DUE.pdf
A Florida Supreme Court order dated December 11, 2015, notifying Jeffrey Epstein (Petitioner) that he failed to pay the required $300.00 filing fee for his case against Bradley J. Edwards. The court set a deadline of January 11, 2016, to pay the fee or file for insolvency, warning that failure to do so would result in final dismissal of the case.
MAIL%20RETURNED.pdf
This document contains court orders from the Supreme Court of Florida dated December 15, 2015, regarding the case Jeffrey Epstein v. Bradley J. Edwards (Case No. SC15-2286). The court stayed proceedings pending the outcome of a separate case (Debrincat v. Fischer) and denied Epstein's motion for an extension of time as moot. The first page shows an envelope addressed to attorney Marc S. Nurik that was stamped 'Return to Sender' and filed/cleared by the clerk on December 28, 2015.
DISP-REV%20DY%20LACK%20JURIS%20(TAG).pdf
A 2017 Supreme Court of Florida order denying Jeffrey Epstein's petition for discretionary review in his case against Bradley J. Edwards. The court declined jurisdiction following a review of the response to a show cause order. The document lists the concurring justices and the individuals served with the order, including various attorneys and clerks.
ACKNOWLEDGMENT%20LETTER-NEW%20CASE.pdf
This document is an official 'Acknowledgment of New Case' from the Supreme Court of Florida, dated December 11, 2015. It confirms the receipt of a 'Notice to Invoke Discretionary Jurisdiction' filed on December 10, 2015, in the case of Jeffrey Epstein vs. Bradley J. Edwards (Case No. SC15-2286). The document lists relevant case numbers from the lower tribunal and copies various attorneys and clerks involved in the matter.
080.pdf
This document is a Stipulation of Dismissal with Prejudice filed on June 30, 2010, in the case of Jane Doe II v. Jeffrey Epstein and Sarah Kellen in the Southern District of Florida. The parties agreed to dismiss the lawsuit with prejudice, meaning it cannot be refiled, with each party bearing their own legal costs. The document notes that a settlement was reached, and the court retains jurisdiction to enforce its terms.
078.pdf
This document is a legal notice filed on June 14, 2010, in the case of Jane Doe No. 2 v. Jeffrey Epstein. The notice, filed by attorney Spencer T. Kuvin on behalf of Plaintiff C.L., withdraws a subpoena and cancels the deposition of Maritza Milagros Vasquez, which was scheduled for the following day, June 15, 2010. The document also includes a certificate of service listing legal counsel for various parties involved in related cases.
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