UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
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010-03.pdf
This is a court order from Judge Kenneth A. Marra denying motions by Jane Doe 3 and Jane Doe 4 to join an existing lawsuit filed by Jane Doe 1 and 2 against the US Government regarding violations of the Crime Victims' Rights Act in the Epstein case. The judge ruled that adding new parties was unnecessary as their claims were duplicative and they could instead serve as witnesses. Significantly, the Judge sua sponte ordered the striking of 'lurid details' and allegations made by Jane Doe 3 regarding being trafficked to high-profile non-parties (including politicians and world leaders), deeming them impertinent to the specific legal claim against the government. Consequently, Alan Dershowitz's motion to intervene to strike these same allegations was denied as moot.
007.pdf
This document is a 'Notice of Filing' submitted to the U.S. District Court for the Southern District of Florida on June 29, 2016. It serves to notify the court and opposing counsel that Defendant Ghislaine Maxwell has filed Exhibits A, G, H, I, and N under seal. These exhibits are attached to a declaration by her attorney, Jeffrey S. Pagliuca, in support of her opposition to Bradley J. Edwards' motion to quash a subpoena.
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.
005.pdf
This document is a Motion to Appear Pro Hac Vice filed on June 29, 2016, in the Southern District of Florida. Attorney Denise D. Riley requests that attorney Jeffrey S. Pagliuca of the Colorado firm Haddon, Morgan and Foreman be admitted to represent Defendant Ghislaine Maxwell in matters related to a subpoena issued to Bradley J. Edwards. The document includes contact information for the attorneys involved and a certificate of service to opposing counsel Jack Scarola.
005-02.pdf
This document is a proposed court order filed on June 29, 2016, in the Southern District of Florida, granting attorney Jeffrey S. Pagliuca permission to appear Pro Hac Vice on behalf of Ghislaine Maxwell. The order relates to a subpoena issued to Bradley J. Edwards in connection with the underlying case of Virginia L. Giuffre v. Ghislaine Maxwell. It also establishes electronic filing notifications for Pagliuca and his legal assistant, Nicole Simmons, at the firm Haddon, Morgan and Foreman, P.C.
005-01.pdf
This document is a formal certification filed by attorney Jeffrey S. Pagliuca in the United States District Court for the Southern District of Florida on June 29, 2016. It pertains to a subpoena issued to Bradley J. Edwards in relation to the underlying case of Virginia L. Giuffre v. Ghislaine Maxwell. Pagliuca certifies his compliance with local rules and his good standing with the Colorado bar.
081.pdf
Legal filing from July 2, 2010, in the case of Jane Doe II vs. Jeffrey Epstein and Sarah Kellen. Plaintiff's counsel Isidro Garcia responds to a court order, apologizing for delays in filing a scheduling report, partly attributing the delay to difficulty serving Sarah Kellen who was 'believed to have been avoiding service.' The document announces that a settlement has been reached resolving all claims in this federal case and a companion state court case.
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.
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.
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.
075.pdf
A legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party Jean Luc Bruhnel (spelled 'Bruhnel' in document) in the case of Jane Doe v. Jeffrey Epstein. The filing opposes a motion to compel Bruhnel's deposition, arguing that he is a French citizen who has left the U.S. with no plans to return and cannot be compelled to appear under Federal Rules. The document alleges misrepresentation and nonfeasance by the Plaintiff's counsel and suggests using the Hague Convention to secure testimony abroad.
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.
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.
071-01.pdf
This is a United States District Court Agreed Order from November 2009 in the Southern District of Florida. It grants Jeffrey Epstein's motion to attend mediation and explicitly states that a previous no-contact order does not prevent him from attending the deposition, mediation, or trial of Plaintiff Carolyn Andriano. The order references multiple related case numbers.
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.
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.
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.
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.
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.
042.pdf
This document is a Motion to Set Aside Order of Default filed by attorney Bruce E. Reinhart on behalf of defendant Sarah Kellen in the case Jane Doe No. 2 v. Sarah Kellen. Kellen argues that the default judgment entered on June 17, 2009, is invalid because the plaintiff failed to properly serve the summons under New York law (specifically regarding timing of filing the affidavit of service) and because the time for a responsive pleading had not yet expired when the default was entered.
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.
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