UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
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080.pdf
This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, requesting a protective order to prevent his deposition in the case Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, who worked as a driver and bodyguard for Epstein since November 2005, argues he has no relevant information for the civil cases as his employment began after the alleged events and he never discussed the criminal or civil cases with Epstein.
078.pdf
This document is an unopposed motion filed on October 29, 2009, by Jeffrey Epstein's legal team requesting an extension of time until November 16, 2009, to file a reply to Plaintiff Jane Doe 101's response to the motion to dismiss. The document indicates that the parties are working together to find a resolution to the case. The motion was filed in the U.S. District Court for the Southern District of Florida.
078-01.pdf
This document is a proposed court order from the U.S. District Court, Southern District of Florida, in the case of Jane Doe No. 101 v. Jeffrey Epstein (Case No. 09-80591). The document grants Jeffrey Epstein's unopposed motion for an extension of time to reply to the plaintiff's response regarding a motion to dismiss. The new deadline set for Epstein's filing is November 16, 2009.
076.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 reply to Plaintiff Jane Doe 101's response to the motion to dismiss. The motion states that the parties are working together to find a resolution to the case and that the plaintiff's counsel agrees to the extension. The document includes a procedural history of filings and a service list of attorneys involved.
076-01.pdf
A court order from the Southern District of Florida in the case of Jane Doe No. 101 v. Jeffrey Epstein (Case No. 09-80591). Judge Kenneth A. Marra granted Epstein's unopposed motion for an extension of time, setting a deadline of October 30, 2009, for filing a responsive pleading.
073.pdf
This document is a Notice of Agreement filed on September 8, 2009, in the Southern District of Florida court case Jane Doe 101 v. Jeffrey Epstein. The plaintiff's counsel notifies the court that both parties have agreed to appoint Rodney Romano of Matrix Mediation, LLC as the mediator for the case. The document includes a certificate of service and a service list detailing the contact information for the attorneys representing both the plaintiff and the defendant.
070-01.pdf
This document is a court order from the United States District Court for the Southern District of Florida, dated August 2009. Judge Kenneth A. Marra grants Jeffrey Epstein's unopposed motion for an extension of time to reply to Plaintiff Jane Doe 101's response regarding a motion to dismiss. The new deadline for Epstein's responsive pleading is set for October 15, 2009.
066-03.pdf
This document is a legal declaration by Jane Doe No. 6, dated July 22, 2009. She states that on July 9, 2009, an investigator visited her former employer, A Affordable Auto Insurance in Lake Worth, Florida, asking personal questions. She expresses concern that Jeffrey Epstein is sending investigators to harass her associates and reveal her status as a plaintiff in a sexual abuse lawsuit.
064.pdf
This document is a 'Notice of Compliance' filed on July 28, 2009, by Jeffrey Epstein's legal team in the U.S. District Court for the Southern District of Florida. It pertains to multiple civil cases filed by 'Jane Doe' plaintiffs against Epstein. The filing states that while the court ordered the parties to agree on a preservation of evidence order, they were unable to reach a full agreement, leading Epstein to submit his own proposed order. The document includes a comprehensive service list detailing the attorneys representing the various plaintiffs and defendants, including Sarah Kellen.
064-01.pdf
This document is a Court Order from the Southern District of Florida (Exhibit A), signed by Judge Kenneth A. Marra, granting a motion to preserve evidence in multiple civil cases against Jeffrey Epstein. The order mandates that Epstein and his agents preserve a wide range of materials, specifically including records of domestic and international travel on private airplanes, phone communications, computer data, and items resulting from the October 25, 2005 search of his Palm Beach home. It establishes preservation timelines ranging from 1998 to 2005 depending on the specific plaintiff and defines sanctions for wrongful destruction of evidence.
061.pdf
This document is a Motion to Compel filed on July 10, 2009, in the Southern District of Florida by Plaintiff Jane Doe against Defendant Jeffrey Epstein. The motion seeks to force Epstein to answer 23 specific Requests for Admission regarding his net worth (specifically if it exceeds $1 billion), his financial support of modeling agency MC2, his ownership of Caribbean property, and specific allegations of sexual battery, assault, and sex trafficking of minors. Epstein had previously refused to answer these questions by invoking his Fifth Amendment privilege against self-incrimination.
060.pdf
This is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the Southern District of Florida. The motion seeks a court order requiring Epstein to answer 16 specific requests for production of documents (including telephone records, photos, tax returns, and passport copies) or to provide a privilege log, as Epstein has refused to produce documents by asserting a blanket Fifth Amendment privilege against self-incrimination. The plaintiff argues that Epstein's boilerplate objections are invalid, violate local rules requiring a privilege log, and that he must provide a particularized justification for his Fifth Amendment invocation for each request.
057.pdf
This document is an unopposed motion filed on July 2, 2009, by Jeffrey Epstein's legal counsel in the US District Court for the Southern District of Florida (Case No. 09-80591). Epstein's attorneys request an extension until August 21, 2009, to reply to Plaintiff Jane Doe 101's response to a motion to dismiss, citing workload from other cases involving Epstein. The document confirms that Plaintiff's counsel agreed to this extension via telephone and correspondence.
057-01.pdf
This document is a court order from the U.S. District Court for the Southern District of Florida, dated July 2009 (entered on docket July 2, 2009). Judge Kenneth A. Marra granted Defendant Jeffrey Epstein's unopposed motion for an extension of time. Epstein was given until August 21, 2009, to file a reply to Plaintiff Jane Doe No. 101's response regarding a Motion to Dismiss Amended Complaint.
053.pdf
Legal filing from June 12, 2009, in the case of Jane Doe No. 101 v. Jeffrey Epstein in the Southern District of Florida. Epstein's legal team withdraws seven specific arguments previously made in a Motion to Dismiss regarding the Plaintiff's First Amended Complaint, including arguments about the plaintiff's minority status and predicate offenses. The defense states it will now rely solely on arguments regarding count merger and subparagraph D.
046.pdf
This document is a court order from the U.S. District Court for the Southern District of Florida, dated June 7, 2009, in the case of Jane Doe 101 vs. Jeffrey Epstein (Case No. 9:09-CV-80591-KAM). The order grants a motion for the limited appearance of attorney Jay P. Lefkowitz, P.C. to represent Jeffrey Epstein and authorizes him to receive electronic filing notifications at jay.lefkowitz@kirkland.com.
045.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, Hayley Robson (who originally recruited the victims), has been harassing Jane Does 4 and 7 via text messages and in-person threats while claiming to be financially supported by Epstein. The plaintiffs argue that a court order is necessary to prevent Epstein from contacting or harassing victims through third parties like Robson.
041.pdf
This document is a Motion for Limited Appearance filed on June 4, 2009, in the case of Jane Doe 101 v. Jeffrey Epstein in the Southern District of Florida. Attorney Robert D. Critton, Jr. moves for the admission of Jay P. Lefkowitz of Kirkland & Ellis LLP to appear as co-counsel for Jeffrey Epstein. The document includes certificates of service to opposing counsel and a certificate of good standing for Lefkowitz from the District of Columbia court.
038.pdf
This document is a Motion to Reschedule Hearing filed on May 29, 2009, in the United States District Court for the Southern District of Florida. Attorney Robert C. Josefsberg, representing Plaintiffs Jane Doe 101 and 102, requests to move a hearing scheduled for June 12, 2009, because he will be attending his 50th College Reunion in Hanover, New Hampshire. The document includes a comprehensive service list detailing the legal teams associated with Jeffrey Epstein, Sarah Kellen, and various plaintiffs in related cases.
035.pdf
This document is a legal reply filed on May 29, 2009, in the US District Court for the Southern District of Florida by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein. The plaintiffs argue for the right to proceed anonymously, citing fears of harassment, public humiliation, and Epstein's alleged intent to intimidate victims by exposing their identities. The document lists numerous related cases and provides a service list of attorneys representing various parties, including Bruce Reinhart representing co-defendant Sarah Kellen.
033.pdf
This document is a 'Notice of Limited Appearance' filed by the United States government in the Southern District of Florida on May 29, 2009. The filing, signed by Assistant US Attorney A. Marie Villafaña under US Attorney R. Alexander Acosta, consolidates multiple civil cases against Jeffrey Epstein (Plaintiffs include various Jane Does and C.M.A.). The United States enters as Amicus Curiae solely to respond to a court order regarding Epstein's Motion to Stay Proceedings, explicitly stating it does not become a party to the litigation nor take a position on the outcome of the civil suits.
028-03.pdf
This document is a Court Order from the Southern District of Florida dated May 26, 2009, granting a motion by Plaintiffs (Jane Doe No. 101 and 102) to preserve evidence in their cases against Jeffrey Epstein. Judge Kenneth A. Marra orders Epstein to preserve a wide range of materials, specifically including flight logs ('travel in Defendant's private airplanes'), phone records, computer data since 1998, financial records regarding payments to victims, and evidence related to the October 25, 2005 police search of his Palm Beach mansion. The order explicitly forbids the destruction, deletion, or alteration of any such evidence.
026.pdf
This document is a Motion for Limited Appearance filed on May 21, 2009, in the US District Court for the Southern District of Florida (Case 9:09-CV-80591-KAM). Robert D. Critton, Jr. requests the court to admit Michael D. Shumsky of Kirkland & Ellis LLP as co-counsel for the defendant, Jeffrey Epstein. The document lists legal counsel for both the plaintiff (Jane Doe 101) and the defendant, along with their contact information.
025.pdf
This document is a legal motion filed on May 21, 2009, in the Southern District of Florida case Jane Doe 101 v. Jeffrey Epstein. Local counsel Robert D. Critton, Jr. requests the court to admit Jay P. Lefkowitz (of Kirkland & Ellis LLP) pro hac vice to represent Jeffrey Epstein. The document outlines Lefkowitz's qualifications, confirms payment of the admission fee, and provides service information for all counsel of record.
025-02.pdf
This document is a court order (specifically Document 25-2 entered on 05/21/2009) from the Southern District of Florida in the case of Jane Doe 101 vs. Jeffrey Epstein. The order grants Jay P. Lefkowitz, P.C. permission to appear and participate in the action on behalf of the defendant, Jeffrey Epstein, and authorizes the receipt of electronic filings at the email address jay.lefkowitz@kirkland.com. The document appears to be a proposed order as the judge's signature lines are blank.
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