UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
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039.pdf
A court order from the Southern District of Florida dated June 16, 2009, granting a default judgment against Sarah Kellen in a civil case filed by Jane Doe II. Judge Kenneth A. Marra ruled that Kellen failed to respond to the complaint despite being properly served under New York state law. Jeffrey Epstein is listed as a co-defendant in the case header.
037.pdf
This document is a Plaintiff's Motion for Default filed on June 12, 2009, in the Southern District of Florida against Sarah Kellen in the case of Jane Doe II vs. Jeffrey Epstein and Sarah Kellen. The motion asserts that Kellen has been avoiding service but was successfully served according to New York law and failed to respond. Notably, it alleges that Kellen is aware of the legal action and has visited Jeffrey Epstein at the Palm Beach County Jail on several occasions.
037-01.pdf
This document is an Affidavit of Service filed in the Southern District of Florida for the case Jane Doe II v. Jeffrey Epstein. It details multiple attempts by process server Joseph Sanchez in April 2009 to serve Sarah Kellen (a/k/a Sarah Bonk) at her New York apartment. After several failed attempts where the doorman stated she was out of town or not home, service was eventually effected on April 25, 2009, by leaving the papers with the doorman, identified as Hector 'Doe', followed by a mailed copy.
027.pdf
This document is a Motion for Leave to File Under Seal submitted on May 29, 2009, by attorneys for Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida. The plaintiffs request permission to file their response to Epstein's Motion to Stay under seal, or alternatively, request the court to unseal the Non-Prosecution Agreement (NPA) so they can adequately respond. The document includes a comprehensive service list detailing attorneys representing Epstein, co-defendant Sarah Kellen (represented by Bruce Reinhart), and various other Jane Doe plaintiffs.
025.pdf
This document is a legal reply filed on May 29, 2009, by Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida, arguing for the right to proceed anonymously in their lawsuit against Jeffrey Epstein. The plaintiffs contend that Epstein aims to reveal their identities to harass and intimidate them, and they cite various legal precedents and the Non-Prosecution Agreement (NPA) to support their request for privacy due to the sexual nature of the crimes committed against them as minors. The document also includes a service list detailing the attorneys representing various parties in related cases against Epstein.
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.
016.pdf
This document is a legal motion filed on May 15, 2009, in the Southern District of Florida, case number 09-80469-CIV-MARRA. Plaintiff Jane Doe II requests an extension until May 22, 2009, to file a reply to Defendant Jeffrey Epstein's Motion to Dismiss, citing complex issues and other business. Epstein's counsel, Robert Critton, was consulted and did not oppose the extension.
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.
006.pdf
This document is a Court Order from the United States District Court Southern District of Florida, dated April 28, 2009, presided over by Judge Kenneth A. Marra. The order grants the Plaintiffs' motion for a protective order against piecemeal depositions, limiting Jeffrey Epstein (Defendant) to a single deposition of each plaintiff across ten related civil cases. It also consolidates four specific cases (08-80119, 08-80232, 08-80380, and 08-80993) for the purposes of discovery and orders parties in the remaining six cases to show cause why they should not also be consolidated.
005.pdf
This document is a court order from March 30, 2009, in the case of Jane Doe II vs. Jeffrey Epstein and Sara Kellen (Case No. 09-80469-CIV-MARRA) in the Southern District of Florida. Judge Kenneth A. Marra orders counsel to confer and file a joint scheduling and discovery report pursuant to Federal Rules of Civil Procedure. The order outlines specific deadlines for pretrial discovery planning and scheduling conferences.
004.pdf
This document is an Order of Transfer from the United States District Court for the Southern District of Florida, dated March 2009. Judge Kenneth L. Ryskamp transfers the case of Jane Doe II v. Jeffrey Epstein and Sarah Kellen (Case No. 09-80469) to Judge Kenneth A. Marra. The transfer is ordered because the case is related to several lower-numbered cases already assigned to Judge Marra (including 08-80069, 08-80119, etc.).
003.pdf
This document is an 'Order of Pretrial Procedures' from the U.S. District Court, Southern District of Florida, dated March 25, 2009, in the civil case of Jane Doe II vs. Jeffrey Epstein and Sarah Kellen. It outlines the procedural requirements for the case, including deadlines for scheduling meetings, reports, and discovery planning, and warns of sanctions for non-compliance. The document also includes a sample 'Scheduling Order' template detailing rules for pretrial stipulations, jury instructions, and witness lists.
030.pdf
This document is a Clerk's Notice from the United States District Court for the Southern District of Florida regarding Case No. 08-CV-80804-JIC (Pruco Life Insurance Company vs. Wells Fargo Bank, N.A.). It certifies that on May 25, 2011, the court received a deposit of $112,301.53 from Wells Fargo into the court registry.
028.pdf
This document is a transmittal letter dated October 6, 2008, from the US District Court for the Southern District of Florida to the 15th Judicial Circuit of Florida. It encloses an 'Order of Remand' for case number 08-CIV-80804-KAM, returning the matter to the state court under case number 50 2008 CA 006596. The document includes an acknowledgment of receipt signed by Deputy Clerk Carol Morano on October 17, 2008.
027.pdf
This document is a formal transmittal letter dated October 6, 2008, from Steven M. Larimore, Clerk of the US District Court for the Southern District of Florida, to the Clerk of the 15th Judicial Circuit of Florida. It encloses a certified copy of an Order of Remand for case number 08-CIV-80804-KAM (state case number 50 2008 CA 006596) and requests acknowledgement of receipt. The letter is signed by Deputy Clerk Bonnie J. Bernard on behalf of Larimore.
024.pdf
This document is an unopposed motion filed on September 18, 2008, by Plaintiff Jane Doe in the Southern District of Florida (Case 08-80804) against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The plaintiff requests an extension of time to respond to Epstein's Motion to Dismiss until 15 days after the court rules on a pending motion to remand the case to state court due to alleged lack of federal jurisdiction. The document lists legal counsel for all parties, including Bruce Reinhart representing Sarah Kellen.
024-01.pdf
A Proposed Order from the U.S. District Court for the Southern District of Florida in the case of Jane Doe vs. Jeffrey Epstein, Haley Robson, and Sarah Kellen. The document grants the Plaintiff's unopposed motion to extend the deadline for responding to Epstein's Motion to Dismiss until 15 days after a pending motion to remand is decided. The document was entered on the docket on September 18, 2008.
021.pdf
This document is an 'Opposition to Remand Motion' filed by defendants Jeffrey Epstein and Sarah Kellen in September 2008 in the Southern District of Florida. The defendants argue that the case should remain in federal court because the plaintiff fraudulently joined co-defendant Haley Robson (a Florida resident) solely to destroy diversity jurisdiction. The filing contends that the plaintiff has no valid cause of action against Robson for civil conspiracy, intentional infliction of emotional distress (IIED), or civil RICO under Florida law, arguing that Robson's alleged actions do not meet the legal standards for these torts.
019.pdf
Defendant Jeffrey Epstein moves to dismiss Counts I (sexual assault), II (civil conspiracy), and IV (civil RICO) of Jane Doe's amended complaint. The motion argues that the sexual assault claim improperly relies on a criminal statute with no private right of action, the conspiracy claim lacks an actionable underlying tort, and the RICO claim fails to allege a direct injury resulting from a predicate act. The document outlines relevant Florida case law and statutes to support the dismissal of these claims.
017.pdf
This document is a Motion to File Under Seal submitted by defendants Jeffrey Epstein and Sarah Kellen on July 25, 2008, in the case of Jane Doe v. Epstein et al. The defendants request to seal their 'motion for stay' to protect a confidential agreement between Epstein and the U.S. Attorney's Office for the Southern District of Florida. The document includes certificates of compliance and service, noting that the plaintiff opposes the motion, and lists the legal counsel representing all parties involved.
016-01.pdf
This document contains a Proposed Order and an Unopposed Motion for Enlargement of Time filed by Plaintiff Jane Doe in a civil case against Jeffrey Epstein, Haley Robson, and Sarah Kellen (Case No. 08-80804). Filed on August 13, 2008, the motion requests an extension to file a Civil RICO Case Statement until after the court rules on an upcoming motion to remand the case back to state court. The plaintiff argues the case was improperly removed to federal court and lacks federal jurisdiction. The document includes a service list identifying legal counsel for all parties, including Bruce Reinhart representing Sarah Kellen.
014.pdf
This document is a legal response filed on August 22, 2008, by Jeffrey Epstein's legal team in the case of Jane Doe vs. Jeffrey Epstein, Haley Robson, and Sarah Kellen. Epstein's lawyers state they have no opposition to the plaintiff's Motion to Preserve Evidence (DE 12). However, they dispute the plaintiff's certification of compliance, arguing that plaintiff's counsel filed the motion prematurely without properly conferring with the defense or waiting for a return call regarding Epstein's position.
013.pdf
Court order from the Southern District of Florida dated August 21, 2008, in the case of Jane Doe vs. Jeffrey Epstein, Haley Robson, and Sarah Kellen. Judge Kenneth A. Marra orders defendant Jeffrey Epstein to respond to the Plaintiff's Motion to Preserve Evidence and Expedite Certain Discovery by August 26, 2008.
008.pdf
This document is a motion filed by Jeffrey Epstein's legal team on August 8, 2008, requesting an extension to file a response to the complaint in the case of Jane Doe #1. Epstein's lawyers argue that the deadline should be aligned with parallel cases (Jane Doe Nos. 2-5) to September 4, 2008, to promote judicial economy. The document notes that co-defendants Haley Robson and Sarah Kellen had not yet been served at the time of filing.
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