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 |
076.pdf
This document is a legal memorandum filed by the Plaintiffs (Jane Does 2-8) in response to Jeffrey Epstein's appeal of a Magistrate Judge's order compelling him to produce his income tax returns for the years 2003-2008. The Plaintiffs argue that the tax returns are relevant for determining punitive damages and are not protected by the Fifth Amendment privilege against self-incrimination, citing the 'required records' exception. The document also notes Epstein's attempt to avoid producing records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs reject as insufficient.
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.
071.pdf
A 2009 legal motion filed in the Southern District of Florida on behalf of Jeffrey Epstein requesting permission to attend mediation in a case involving Carolyn Andriano (C.M.A.). The motion notes that a prior 'no contact order' exists regarding Andriano, but states that neither she nor her counsel object to Epstein's presence at depositions, mediation, or trial. The document includes a comprehensive service list of attorneys involved in multiple related cases against Epstein.
069.pdf
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.
061.pdf
This document is Jeffrey Epstein's Answer and Affirmative Defenses to a civil complaint filed by Jane Doe II in the Southern District of Florida in October 2009. Epstein pleads the Fifth Amendment against self-incrimination in response to most factual allegations. He asserts multiple affirmative defenses, claiming the plaintiff consented to the acts, that he believed she was 18 years or older, and that the claims are barred by the statute of limitations and various constitutional challenges to the retroactivity and application of 18 U.S.C. §2255.
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.
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.
044.pdf
This document is a Motion to Compel filed on July 10, 2009, in the Southern District of Florida, requesting the court to force Jeffrey Epstein to answer 23 specific requests for admission in a civil suit brought by Jane Doe No. 2. Epstein had previously asserted his Fifth Amendment privilege against self-incrimination to refuse answering questions regarding his net worth (alleged to be over $1 billion), his financial support of modeling agency MC2, his ownership of foreign property, and specific allegations of sexual assault, battery, and sex trafficking of minors. The plaintiff argues that the Fifth Amendment cannot be used as a blanket refusal in a civil case and demands Epstein answer or provide specific justification for his silence.
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.
040.pdf
This document is a 'Notice of Reliance' filed on June 19, 2009, in the case of Jane Doe II v. Jeffrey Epstein (Case No. 09-CIV-80469) in the Southern District of Florida. Epstein's legal team informs the court that despite the Plaintiff filing an Amended Memorandum of Law on June 12, 2009, Epstein will not file a new supplemental reply but will instead rely on his previous arguments filed on June 1, 2009. The document outlines the procedural history of the motion to dismiss and includes a certificate of service listing attorneys for both parties.
031.pdf
This document is a Reply by Defendant Jeffrey Epstein to Plaintiff Jane Doe II's opposition to his motion to dismiss a civil suit (Case 09-CIV-80469). Epstein's defense argues that a concurrent state action requires dismissal of the federal case, that the 2006 amendment to 18 U.S.C. §2255 ('Masha's Law') cannot be applied retroactively to conduct from 2003-2005 to increase damages, and that the Plaintiff misrepresents the terms of Epstein's non-prosecution agreement with the US Attorney's Office. The document details specific dates in 2003 and 2004 where the Plaintiff alleges she received payments for acts of prostitution.
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.
013.pdf
This document is a Motion to Dismiss filed by Jeffrey Epstein's defense team in the U.S. District Court for the Southern District of Florida on May 6, 2009, against Plaintiff Jane Doe II. The defense argues that the federal case should be dismissed because a nearly identical state case was filed 10 months prior, and because the plaintiff is improperly applying a 2006 amendment to 18 U.S.C. §2255 retroactively to conduct alleged to have occurred between 2003 and 2005, thereby violating the Ex Post Facto clause. Additionally, the motion argues that the statute does not allow for multiplying damages per incident and that the plaintiff failed to allege the necessary interstate commerce elements required for federal jurisdiction.
009.pdf
This document is a legal response filed by Jeffrey Epstein's attorneys on May 4, 2009, in the Southern District of Florida. Epstein opposes the court's potential order to consolidate multiple civil lawsuits (filed by various 'Jane Doe' plaintiffs) for all discovery purposes, arguing that while consolidating depositions is acceptable, full consolidation would confuse distinct facts and defenses unique to each case. The filing lists numerous related case numbers and requests clarification on how consolidation would operate regarding motion practice.
007.pdf
This document is an unopposed motion filed on May 1, 2009, in the Southern District of Florida (Case 09-CIV-80469) by Jeffrey Epstein's attorneys requesting a five-day extension to file a response to Jane Doe II's complaint. The extension (until May 6, 2009) was requested because Epstein's counsel, Robert D. Critton, Jr., was preparing for an unrelated state court trial. The document confirms that Plaintiff's counsel, Isidro M. Garcia, agreed to this extension.
030.pdf
This document is a Notice of Withdrawing Subpoena filed on June 14, 2010, in the United States District Court for the Southern District of Florida. Plaintiff C.L., represented by attorney Spencer T. Kuvin, withdrew a subpoena and cancelled the deposition of Maritza Milagros Vasquez, which had been scheduled for June 15, 2010. The document includes a certificate of service listing legal counsel for various parties involved in the primary case (Jane Doe No. 2 v. Jeffrey Epstein) and related cases.
028.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) in the case Jane Doe No. 2 vs. Jeffrey Epstein (Case No. 08-CV-80119-MARRA/JOHNSON). The memorandum opposes Epstein's appeal of a Magistrate Judge's order compelling him to produce his income tax returns for the years 2003-2008. The Plaintiffs argue that the tax returns are not protected by the Fifth Amendment (citing the 'required records' exception and 'foregone conclusion' doctrine) and are critical for determining punitive damages given the allegations of sexual molestation and Epstein's refusal to provide net worth discovery beyond a stipulation of 'nine figures.'
022.pdf
This document is an unopposed motion filed on December 3, 2009, by Plaintiff Jane Doe No. 8 in the Southern District of Florida, requesting an extension of time until December 14, 2009, to file an Amended Complaint against Jeffrey Epstein. The request cites obligations of the plaintiff's counsel, Stuart Mermelstein and Adam Horowitz, in other matters, including other Epstein cases. The defendant's counsel, identified in the service list as Jack Alan Goldberger and Robert D. Critton, did not object to the extension.
021.pdf
This document is a legal response filed by Plaintiff Carolyn M. Andriano (Jane Doe No. 2) opposing a motion by third-party witness Igor Zinoview to avoid deposition. Zinoview, who worked as Epstein's driver, bodyguard, and trainer starting in November 2005, claimed he had no relevant knowledge of Epstein's legal matters. The Plaintiff argues that Zinoview worked for Epstein during the police investigation period and likely has relevant observations, regardless of whether he discussed legal matters with Epstein.
017.pdf
Legal filing from November 2009 in the case of Jane Doe No. 2 v. Jeffrey Epstein. Epstein's attorneys reply to a response regarding the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), which was undergoing restructuring. The document notes that the Department of Justice had seized approximately 40 boxes of documents from RRA, including 13 boxes related to the Epstein case, and alludes to serious ethical and criminal issues involving the RRA firm that could impact the validity of the cases against Epstein.
016.pdf
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.
015.pdf
This document is a Reply Memorandum filed by Jeffrey Epstein's legal team on August 20, 2009, in the case of Jane Doe No. 8 v. Jeffrey Epstein. The defense argues that the plaintiff's claims of 'Sexual Assault and Battery' (Count I) and 'Coercion and Enticement' (Count III) should be dismissed because they are barred by the statute of limitations. Epstein's lawyers contend that because the plaintiff was aware of the injury at the time of the alleged incident in 2001 (when she was 16) and turned 18 in 2003, the time limits for filing suit (4 years and 6 years respectively) had expired by the time the complaint was filed in 2009.
011.pdf
Legal motion filed on August 11, 2009, in the Southern District of Florida, requesting to consolidate the case of Jane Doe No. 8 v. Jeffrey Epstein with the lead case Jane Doe No. 2 v. Jeffrey Epstein for discovery purposes. The document states that the case involves alleged sexual abuse in Palm Beach, Florida, in 2001. The motion was unopposed by the Defendant's counsel.
009.pdf
This document is an Unopposed Motion for Enlargement of Time filed on July 30, 2009, in the case of Jane Doe No. 8 vs. Jeffrey Epstein in the Southern District of Florida. The plaintiff's counsel, Stuart S. Mermelstein, requests an extension until August 12, 2009, to respond to Epstein's Motion to Dismiss, citing obligations in other matters including related cases against Epstein. The document confirms that Epstein's counsel does not oppose this request.
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