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016-13.pdf
This document is a Motion for Sanctions filed by Plaintiff Jane Doe No. 3 against Jeffrey Epstein on January 4, 2010. The motion alleges that Epstein flagrantly violated multiple court orders, including a No-Contact Order, by deliberately appearing at the location of the Plaintiff's Independent Medical Examination (IME) on November 24, 2009. The Plaintiff requests sanctions, attorney's fees, and a protective order moving the remainder of her IME to a different city, citing the trauma caused by the encounter.
015.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) opposing Jeffrey Epstein's appeal of a Magistrate Judge's order compelling him to produce income tax returns for the years 2003-2008. The Plaintiffs argue that tax returns are 'required records' not protected by the Fifth Amendment privilege against self-incrimination and are critical for determining punitive damages. The document notes that Epstein attempted to avoid producing these records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs rejected as insufficient.
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.
009.pdf
This document is a Notice of Voluntary Dismissal Without Prejudice filed on February 22, 2008, in the U.S. District Court for the Southern District of Florida (Case No. 08-80069). The plaintiffs (Jane Doe No. 1 and her parents) voluntarily dismissed their action against Jeffrey Epstein. The document includes a certificate of service indicating that notice was sent electronically to attorney Theodore Jon Leopold and by mail to Jeffrey Epstein at his New York residence.
008.pdf
This document is a Notice of Non-Opposition filed on February 14, 2008, in the case of Jane Doe No. 1 et al. v. Jeffrey Epstein in the Southern District of Florida. The plaintiffs (Jane Doe No. 1, her father, and stepmother) inform the court that they do not oppose the motion to intervene filed by Jane Doe's mother. The document lists the attorneys representing the plaintiffs from the firm Herman & Mermelstein, P.A.
028.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) in the case Jane Doe No. 2 vs. Jeffrey Epstein (Case No. 08-CV-80119-MARRA/JOHNSON). The memorandum opposes Epstein's appeal of a Magistrate Judge's order compelling him to produce his income tax returns for the years 2003-2008. The Plaintiffs argue that the tax returns are not protected by the Fifth Amendment (citing the 'required records' exception and 'foregone conclusion' doctrine) and are critical for determining punitive damages given the allegations of sexual molestation and Epstein's refusal to provide net worth discovery beyond a stipulation of 'nine figures.'
009.pdf
This document is an Unopposed Motion for Enlargement of Time filed on July 30, 2009, in the case of Jane Doe No. 8 vs. Jeffrey Epstein in the Southern District of Florida. The plaintiff's counsel, Stuart S. Mermelstein, requests an extension until August 12, 2009, to respond to Epstein's Motion to Dismiss, citing obligations in other matters including related cases against Epstein. The document confirms that Epstein's counsel does not oppose this request.
DOJ-OGR-00030392.jpg
This legal document, dated March 31, 2008, is a motion for a protective order filed by the law firm Herman & Mermelstein, P.A. on behalf of 'Witness Y. Doe'. The motion requests that the court order the witness's deposition for an unspecified criminal case and the civil case 'Jane Doe No. 3 v. Jeffrey Epstein' to be conducted simultaneously. The stated purpose is to prevent potential harassment of the witness by the defendant, Jeffrey Epstein.
DOJ-OGR-00030385.jpg
In a letter dated April 21, 2008, attorney Stuart S. Mermelstein informs attorney Jack A. Goldberger that his firm is representing a client identified as 'Jane Doe No. 5' in matters concerning the case *State of Florida v. Jeffrey E. Epstein*. Mermelstein requests that all future communication regarding his client be directed to his office and proposes scheduling a single deposition to be used for both the criminal and civil matters, subject to agreement and approval from the State Attorney's Office.
DOJ-OGR-00030996.jpg
This legal document, dated April 2, 2008, is a court filing in the case of the State of Florida versus Jeffrey Epstein. Attorneys for a witness, identified as 'Y. Doe', are formally withdrawing a Motion for a Protective Order. The withdrawal is based on the representation that the defendant, Jeffrey Epstein, has agreed to cancel the deposition of Y. Doe.
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