UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
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Jeffrey Epstein Part 22 of 22.pdf
This document contains court filings from September 2009 regarding a dispute over the deposition of 'Jane Doe No. 4' in the civil case Jane Doe No. 2 v. Jeffrey Epstein. The plaintiff's attorney, Adam Horowitz, cancelled the deposition after an alleged intimidation incident where Epstein and his driver, Igor Zinoviev, crossed paths with the plaintiff in the building lobby. Epstein's legal team (Critton and Luttier) filed for sanctions, arguing the encounter was coincidental as Epstein was leaving his office (Florida Science Foundation, same building) to avoid the deposition. The document includes affidavits from Epstein and Zinoviev denying interaction, invoices for the cancelled deposition costs, and a 2008 plea conference transcript defining 'no contact' orders.
Epstein_Part_12_(Redacted).pdf
This document is an excerpt from a federal indictment (Case No. 00-8124CR - HURLEY) from the Southern District of Florida, detailing charges of mail fraud and bank fraud against an individual named HURLEY. The defendant, a mortgage broker at Mortgage Express, Inc., is accused of submitting false and fraudulent information, including fictitious leases and false verifications of employment/deposit, to financial institutions like Bank of America, Republic Consumer Lending Group, and Ohio Savings Bank to obtain mortgage financing for himself and customers.
Epstein_Part_22.pdf
This document contains a partial transcript from a plea conference for Jeffrey Epstein in Palm Beach County, Florida, on June 30, 2008, where the court detailed strict no-contact orders with victims. It also includes a declaration from Adam D. Horowitz dated September 16, 2009, describing a stipulation for Jeffrey Epstein not to physically attend Jane Doe No. 4's deposition, but to listen remotely, and an incident where Epstein crossed paths with Jane Doe No. 4 in a lobby.
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.
027-01.pdf
A Final Order of Dismissal with Prejudice from the United States District Court Southern District of Florida for Case No. 9:10-cv-81111. The case, involving plaintiff 'M.J.' against defendants Jeffrey Epstein and Sarah Kellen, was dismissed following a settlement between the parties on December 13, 2010. Judge William P. Dimitrouleas ordered the case closed while retaining jurisdiction to enforce the settlement terms.
026.pdf
This document is a Court Order from the Southern District of Florida dated December 6, 2010, in the case of M.J. v. Jeffrey Epstein and Sarah Kellen. Magistrate Judge Lurana S. Snow granted Jeffrey Epstein's unopposed motion for an extension of time to respond to the Plaintiff's motions regarding a protective order and preservation of evidence. The new deadline for Epstein's response was set for December 13, 2010.
024.pdf
A court order from the Southern District of Florida dated November 23, 2010, in the case of M.J. vs. Jeffrey Epstein and Sarah Kellen. Judge William P. Dimitrouleas granted a motion allowing attorney Paul G. Cassell to appear on behalf of the Plaintiff and receive electronic filings.
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.
020-01.pdf
This document is a Supplemental Affidavit filed on November 22, 2010, in the US District Court for the Southern District of Florida (Case 9:10-cv-81111-WPD). Richard Barnett, the property manager of 9 East 71st Street in New York, testifies that he does not reside at the property, that no one resided there on October 8, 2010, and specifically that Jeffrey Epstein was not present at that location on that date.
019.pdf
A court order from the Southern District of Florida in the case of M.J. vs. Jeffrey Epstein and Sarah Kellen, dated November 12, 2010. Judge William P. Dimitrouleas refers two motions—one for a protective order barring contact by Epstein and another for preservation of evidence regarding correspondence with the U.S. Attorneys Office—to Magistrate Judge Lurana S. Snow.
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.
017-08.pdf
This is a court order from the Southern District of Florida dated February 11, 2010, in the case of Jane Doe No. 2 vs. Jeffrey Epstein. Judge Kenneth A. Marra grants in part Epstein's motion for an extension, setting a new deadline of February 26, 2010, for Epstein to appeal Magistrate Judge Johnson's prior order compelling document production. The order also stipulates that if the appeal fails, Epstein must produce the documents within three business days.
017-05.pdf
This document is an Omnibus Order from the US District Court for the Southern District of Florida dated February 4, 2010, in the civil case of Jane Doe No. 2 vs. Jeffrey Epstein. The Magistrate Judge rules on the Plaintiff's motions to compel answers to interrogatories, admissions, and production requests. The court upholds Epstein's Fifth Amendment privilege against self-incrimination regarding questions about his financial history, assets, and potential witnesses, but orders him to produce documents that are already known to the government (tax returns, passport, and documents provided to him during plea negotiations), ruling that these fall under the 'foregone conclusion' doctrine.
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.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.
016-06.pdf
This document is a court order dated July 1, 2010, from the Southern District of Florida in the case of Jane Doe v. Jeffrey Epstein. Judge Peter R. Palermo grants the plaintiff's motion to modify the scheduling of a settlement conference set for July 6, 2010, to ensure Jane Doe does not come into contact with Epstein, citing existing no-contact orders. The order stipulates specific arrival times for Epstein (8:30 AM), dismissal procedures, and explicitly forbids communication or harassment between the parties.
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.
016-02.pdf
This document is a Motion for No-Contact Order filed by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein in the Southern District of Florida on May 22, 2009. The plaintiffs argue that despite a state plea agreement prohibiting contact, Epstein's counsel refused to confirm he would not contact federal victims. The filing includes exhibits of correspondence between attorneys and a transcript of the 2008 plea conference where Judge Pucillo explicitly defined 'indirect contact' to include Facebook and MySpace.
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.
013.pdf
A court order from the U.S. District Court for the Southern District of Florida dated November 8, 2010, in the case of M.J. vs. Jeffrey Epstein and Sarah Kellen. Judge William P. Dimitrouleas denied Jeffrey Epstein's motion to quash service of process without prejudice because the motion failed to comply with local rules requiring a certification of good faith effort to confer with opposing parties.
012-01.pdf
This document is a legal affidavit filed on November 3, 2010, in the case of M.J. v. Jeffrey Epstein and Sarah Kellen. The affiant, Richard Barnett, states that he was present at Epstein's residence at 9 East 71st Street, NYC, for the entire day of October 8, 2010. He testifies that no individual named 'Mark' worked, resided, was present, or received a subpoena at that location on that date.
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.
007-01.pdf
This document is an affidavit by Richard Barnett filed on October 29, 2010, in the case of M.J. v. Jeffrey Epstein and Sarah Kellen in the Southern District of Florida. Barnett testifies that on October 13, 2010, he discovered an unmarked envelope containing legal documents (Summons, Complaint, Civil Rico Statement) in the mailbox of Epstein's home at 9 East 71st Street, NYC. He asserts that service was never personally delivered to anyone at the residence.
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