UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
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055.pdf
This document is a Motion for Protective Order filed on November 9, 2009, by Igor Zinoviev, a third-party witness and Jeffrey Epstein's driver/bodyguard since November 2005. Zinoviev seeks to prevent or limit his deposition, arguing he has no knowledge relevant to the civil cases as his employment with Epstein began after the alleged events, and he has not discussed Epstein's criminal or civil cases with him. The motion cites legal precedents on the scope of discovery and includes a list of attorneys involved in various related cases.
053.pdf
This is an unopposed motion filed on October 29, 2009, in the US District Court for the Southern District of Florida by Jeffrey Epstein's legal team. Epstein requests an extension until November 16, 2009, to respond to a complaint filed by 'Jane Doe No. 102' on May 1, 2009, citing that the parties are working together to potentially resolve the case. The document lists legal counsel for both sides, including Robert Critton and Jack Goldberger for Epstein, and Robert Josefsberg and Katherine Ezell for the plaintiff.
053-01.pdf
This document is a Court Order from the Southern District of Florida dated October 29, 2009, in the case of Jane Doe No. 102 v. Jeffrey Epstein. Judge Kenneth A. Marra granted Epstein's unopposed motion for an extension of time, setting a new deadline of November 16, 2009, for the defendant to file a responsive pleading to the complaint.
051.pdf
This document is an unopposed motion filed on October 15, 2009, by Jeffrey Epstein's legal team requesting an extension of time until October 30, 2009, to respond to a complaint filed by Jane Doe No. 102. The document indicates that the parties are working together to potentially resolve the case. It lists legal counsel for both the plaintiff (Podhurst Orseck, P.A.) and the defendant (Burman, Critton, Luttier & Coleman; Atterbury Goldberger & Weiss, P.A.).
051-01.pdf
This document is a court order (likely a proposed order attached to a motion) from the United States District Court for the Southern District of Florida in the case of Jane Doe No. 102 v. Jeffrey Epstein. The order grants Epstein's unopposed motion for an extension of time, setting a new deadline of October 30, 2009, for him to file a responsive pleading to the plaintiff's complaint.
048-01.pdf
This document is a court order from the U.S. District Court for the Southern District of Florida, dated August 7, 2009. Judge Kenneth A. Marra granted Jeffrey Epstein's unopposed motion for an extension of time, setting a deadline of October 15, 2009, for him to file a responsive pleading to the complaint of Plaintiff Jane Doe No. 102.
040.pdf
This document is a Motion to Compel filed on July 10, 2009, in the US District Court for the Southern District of Florida by Plaintiff Jane Doe (represented by Bradley Edwards). The motion requests the court to force Jeffrey Epstein to answer a set of interrogatories regarding his financial assets, net worth, foreign travel, property ownership, and alleged interactions with the plaintiff and other minor females. Epstein refused to answer nearly all questions (except for providing the name/address of the person answering), invoking his Fifth and Sixth Amendment rights against self-incrimination and right to counsel.
039.pdf
This legal filing is a Motion to Compel submitted by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the United States District Court for the Southern District of Florida. The motion requests the court to order Epstein to answer 23 specific requests for admission regarding his net worth, asset transfers, and allegations of sexual abuse and trafficking of minors, which he had previously refused to answer by asserting Fifth Amendment privileges. The plaintiff argues that Epstein's blanket assertion of the privilege is improper and that he must provide a particularized justification for each refusal or face an adverse inference.
034.pdf
This document is an unopposed motion filed on June 18, 2009, in the US District Court for the Southern District of Florida (Case No. 09-80656) by Jeffrey Epstein's legal team. Epstein requests an extension until July 5, 2009, to respond to a complaint filed by Jane Doe No. 102, citing the workload from multiple concurrent cases where he is a defendant. The document confirms that Plaintiff's counsel agreed to this extension and lists the legal representatives for both parties.
034-01.pdf
A court order from the U.S. District Court for the Southern District of Florida in the case of Jane Doe No. 102 v. Jeffrey Epstein. Judge Kenneth A. Marra grants Epstein's unopposed motion for an extension of time, setting a new deadline of July 5, 2009, for him to file a responsive pleading to the complaint.
030.pdf
This document is a 'Notice of Joinder' filed on June 8, 2009, in the US District Court for the Southern District of Florida, where Plaintiffs Jane Does 2-7 join a motion for a no-contact order against Jeffrey Epstein. The filing alleges that Epstein's associate and recruiter, Hayley Robson, has been harassing victims Jane Does 4 and 7 through text messages and in-person threats while claiming to be financially supported by and cooperating with Epstein. The plaintiffs request a court order prohibiting Epstein from any direct or indirect contact with the victims.
022.pdf
This document is a legal reply brief filed on May 29, 2009, by Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida. The plaintiffs seek to proceed anonymously in their lawsuit against Jeffrey Epstein, arguing that revealing their identities would subject them to harassment, shame, and further trauma, particularly given their status as victims of sexual exploitation as minors. The filing also discusses the Non-Prosecution Agreement (NPA), statutory minimum damages under 18 U.S.C. § 2255, and accuses Epstein of using the threat of publicity to intimidate victims into settling.
020.pdf
This document is a 'Notice of Limited Appearance' filed on May 29, 2009, in the United States District Court for the Southern District of Florida. It lists multiple civil cases involving Jane Doe plaintiffs against Jeffrey Epstein. The United States, represented by Assistant U.S. Attorney A. Marie Villafaña (under U.S. Attorney R. Alexander Acosta), files this notice to respond to a court order regarding Epstein's 'Motion to Stay Proceedings,' while explicitly stating the U.S. is not becoming a party to the litigation.
016.pdf
This document is a Motion for an Order for the Preservation of Evidence filed by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein in May 2009. The motion requests the court to order Epstein to preserve evidence related to allegations of sexual abuse, specifically citing evidence seized during a 2005 police search and other electronic/physical records located across his six international properties. The document lists numerous attorneys involved in related cases and references Epstein's previous guilty plea in 2008.
016-03.pdf
This document is a Court Order from the Southern District of Florida, dated May 26, 2009, granting a motion to preserve evidence in multiple civil cases against Jeffrey Epstein. Judge Kenneth A. Marra orders Epstein and his associates to preserve a wide range of materials, specifically highlighting records of domestic and international travel (including private airplanes), phone communications, financial records, and evidence related to the October 25, 2005 police search of his Palm Beach mansion. The order explicitly prohibits the destruction, alteration, or deletion of potential evidence dating back to 1998.
013.pdf
This document is a legal notice filed on May 20, 2009, in the U.S. District Court for the Southern District of Florida, involving multiple consolidated cases against Jeffrey Epstein. Plaintiff C.M.A. formally withdraws her objections to Epstein's motion to identify her by her legal name in the case style and in third-party subpoenas, rendering the motion to dismiss moot, though she continues to object to dismissal on alternative grounds. The document lists numerous 'Jane Doe' plaintiffs and provides a service list of attorneys representing both the plaintiffs (Jack Scarola, Jack P. Hill) and the defendant (Richard Willits, Robert Critton, Jack Goldberger, Bruce Reinhart).
009.pdf
This document is an Order of Transfer from the United States District Court, Southern District of Florida, dated May 2009. Judge Kenneth L. Ryskamp transfers the case of Jane Doe No. 102 v. Jeffrey Epstein to Judge Kenneth A. Marra because it is related to multiple other actions pending before Judge Marra against Epstein. Judge Marra formally accepts the transfer on the second page.
006.pdf
Legal document filed on May 11, 2009, in the US District Court for the Southern District of Florida (Case 09-80656). Attorneys Robert D. Critton, Jr. and Michael J. Pike of the firm Burman, Critton, Luttier & Coleman formally entered their appearance as counsel for the defendant, Jeffrey Epstein, in a civil suit brought by Jane Doe No. 102. The document includes a certificate of service listing other counsel involved, including Jack Alan Goldberger for the defense and attorneys from Podhurst Orseck, P.A. for the plaintiff.
002.pdf
A summons issued by the United States District Court for the Southern District of Florida on May 1, 2009, for Case Number 09-80656. The summons is directed to Jeffrey Epstein, located at the Palm Beach County Stockade, notifying him of a lawsuit filed by Plaintiff Jane Doe 102. It lists his defense counsel as Jack A. Goldberger and Robert D. Critton, Jr., and requires a response to the plaintiff's attorneys, Podhurst Orseck, P.A., within 20 days.
089.pdf
This document is a Stipulation of Dismissal with Prejudice filed on December 7, 2009, in the United States District Court for the Southern District of Florida for Case No. 09-CV-80591. The plaintiff, Jane Doe No. 101, and defendant, Jeffrey Epstein, agreed to dismiss the lawsuit following a settlement, the terms of which the court retains jurisdiction to enforce. The document is signed by Robert Critton (representing Epstein) and Katherine W. Ezell (representing Jane Doe No. 101).
087.pdf
This document is a Motion for Extension of Time filed on December 2, 2009, by Jeffrey Epstein's legal team in the case of Jane Doe No. 101 v. Jeffrey Epstein. The defense requested an extension until December 15, 2009, to file a reply, citing ongoing settlement negotiations and the need to investigate the implications of the 'Rothstein Rosenfeldt & Adler, PA' firm implosion on the Plaintiff's counsel. The document notes that Plaintiff's counsel opposed this extension request.
087-01.pdf
This document is a proposed court order from the United States District Court for the Southern District of Florida in the case of Jane Doe No. 101 v. Jeffrey Epstein (Case No. 09-80591). The order grants Epstein's unopposed motion for an extension of time, setting a deadline of December 15, 2009, for him to file a responsive pleading to the plaintiff's response regarding a motion to dismiss.
086.pdf
This document is a response filed by Plaintiff Carolyn M. Andriano on November 28, 2009, opposing a motion by third-party witness Igor Zinoview to prevent his deposition. Zinoview, who worked as Epstein's driver, bodyguard, and trainer starting in November 2005, claims he has no relevant knowledge of legal matters involving Epstein. The Plaintiff argues that because Zinoview worked for Epstein during the active police investigation (2005-2006), he likely possesses relevant information regarding activities at the Epstein residence, and that a complete bar on his deposition is legally unjustified.
082.pdf
This document is a Reply filed by Jeffrey Epstein's legal team in November 2009 requesting a permanent order for the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), which was undergoing restructuring. The filing highlights that the Department of Justice had seized approximately 40 boxes of documents from RRA, including about 13 boxes related to Epstein cases, amidst concerns of 'serious ethical and potentially criminal issues' at the firm. The document also argues against delaying the deposition of RRA's Chief Restructuring Officer, Herbert Stettin, citing upcoming trial deadlines.
081-01.pdf
This document is a proposed court order (Document 81-1) from the case Jane Doe No. 101 v. Jeffrey Epstein in the Southern District of Florida, entered on the docket on November 16, 2009. The order grants Jeffrey Epstein's unopposed motion for an extension of time, setting a deadline of November 27, 2009, for him to file a responsive pleading to the Plaintiff's response regarding the Motion to Dismiss the Amended Complaint. The document lists Kenneth A. Marra as the presiding United States District Judge.
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