Robert D. Critton Jr.; Jessica Cadwell
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Jeffrey Epstein
|
Client |
7
|
7 | |
|
person
Jeffrey Epstein
|
Legal representative |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2010-06-14 | N/A | Filing of Emergency Motion for Protective Order by Jeffrey Epstein. | Southern District of Florida | View |
| 2010-03-23 | N/A | Service of Motion for Extension of Time via CM/ECF | Electronic Filing | View |
| 2010-03-23 | N/A | Videotaped Deposition of Bradley J. Edwards | 2139 Palm Beach Lakes Boule... | View |
| 2009-11-16 | N/A | Motion for Extension of Time filed | Southern District of Florida | View |
| 2009-07-02 | N/A | Electronic filing of the Motion for Extension of Time. | US District Court Southern ... | View |
| 2009-06-18 | N/A | Filing of Motion for Extension of Time | Southern District of Florida | View |
| 2009-05-13 | N/A | Start of state court trial (Cardiopulmonary vs Lewis) involving Defense counsel | State Court (Florida) | View |
060.pdf
This document is a response filed by Palm Beach Newspapers, Inc. (The Palm Beach Post) to an emergency petition for writ of certiorari by Jeffrey Epstein. The Post argues that the trial court correctly unsealed a Non-Prosecution Agreement (NPA) and its addendum related to Epstein's solicitation of minors, asserting that the documents were improperly sealed in the first instance and that no valid legal basis exists for their continued closure.
053.pdf
This document is a court order from June 26, 2009, issued by Judge Jeffrey J. Colbath in the Circuit Court of Palm Beach County, Florida. The order denies Jeffrey Epstein's motion to stay the disclosure of his Non-Prosecution Agreement and sets a deadline of July 2, 2009, for the Clerk to release the documents, allowing time for an appeal to the 4th DCA. The document includes a service list of attorneys involved, including U.S. Attorney R. Alexander Acosta and defense attorneys like Jack Goldberger.
041.pdf
This document is a 'Motion to Make Court Records Confidential' filed by Jeffrey Epstein's attorneys on June 11, 2009, in the Circuit Court of Palm Beach County. The defense seeks to maintain the seal on the Non-Prosecution Agreement (filed July 2008) and its Addendum, citing threats to the administration of justice and privacy rights of third parties. The motion references interventions by the Palm Beach Post and a non-party identified as 'EW' (whose name is redacted in one section) seeking access to these records.
017-19.pdf
Plaintiff Jane Doe filed an emergency motion to hold Jeffrey Epstein in contempt for failing to comply with discovery orders in a civil case (08-CV-80893). The motion alleges that Epstein failed to produce state criminal discovery materials and provided only heavily redacted correspondence with the U.S. Attorney's Office, obscuring the defense counsel's side of the communications. Doe seeks immediate production of unredacted documents, sanctions of $5,000 against Epstein's counsel, and a ruling that withheld materials be deemed admissible at trial.
017-13.pdf
This document is a protective response filed by Plaintiff Jane Doe on May 27, 2010, in the Southern District of Florida case against Jeffrey Epstein. The plaintiff requests the court to promptly order the production of tax returns and other documents that Epstein has withheld on Fifth Amendment grounds, emphasizing that the trial date is set for July 19, 2010. The filing notes that negotiations with Epstein's counsel failed and lists numerous related cases and attorneys involved.
017-01.pdf
This document is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Jane Doe in the United States District Court for the Southern District of Florida against Jeffrey Epstein. The plaintiff argues that Epstein's blanket invocation of Fifth Amendment privileges to refuse producing documents (such as phone records, tax returns, and correspondence) is improper and that he should be compelled to answer or provide a privilege log. The motion details specific discovery requests and Epstein's uniform response asserting his constitutional rights against self-incrimination.
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.
016-05.pdf
This document is a motion filed on June 30, 2010, by Plaintiff Jane Doe requesting the modification of a court order regarding an upcoming settlement conference with Jeffrey Epstein. Doe requests that Epstein be kept in a secure, separate room to prevent any contact or intimidation, citing his status as a convicted sex offender and previous incidents where he intimidated victims, specifically Jane Doe No. 4, during court proceedings. The motion references Epstein's 2008 guilty plea and strict no-contact orders issued by both state and federal courts.
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.
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.
076.pdf
This document is a legal memorandum filed by the Plaintiffs (Jane Does 2-8) in response to Jeffrey 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 relevant for determining punitive damages and are not protected by the Fifth Amendment privilege against self-incrimination, citing the 'required records' exception. The document also notes Epstein's attempt to avoid producing records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs reject as insufficient.
052.pdf
This document is a Motion for Protective Order filed on July 29, 2009, in the Southern District of Florida by Plaintiffs 'Jane Does 2-7' against Jeffrey Epstein. The plaintiffs allege that Epstein hired private investigators to harass and intimidate them by contacting their former employers, ex-boyfriends, and friends to ask intrusive personal questions and potentially 'out' them as sexual abuse victims. The motion seeks a court order to stop Epstein's investigators from making ex parte contacts with nonparties associated with the plaintiffs.
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.
045.pdf
This document is a Motion to Compel filed by Plaintiff Jane Doe against Jeffrey Epstein on July 10, 2009, in the Southern District of Florida. The plaintiff lists 23 specific interrogatories regarding Epstein's finances, properties, travel, and alleged sexual abuse of minors, all of which Epstein refused to answer by invoking his Fifth and Sixth Amendment rights. The motion argues that Epstein's blanket refusals are improper and requests the court force him to answer or provide a privilege log.
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.
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.
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.
020.pdf
This document is the Plaintiff's Memorandum of Law in Opposition to Defendant Epstein's Motion to Dismiss in a civil case. The Plaintiff argues that the federal court has jurisdiction alongside state claims, that the 2006 amendments to 18 U.S.C. §2255 regarding damages should apply retroactively or are procedural, and that interstate commerce requirements were met via phone calls made by co-defendant Sarah Kellen from a New York number. The document details specific dates of solicitation between 2003 and 2005 and alleges a conspiracy involving Epstein, Kellen, and Haley Robson to procure minors for prostitution.
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.
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.
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.
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.
Motion to Amend
Service of the Motion to Amend Defendant's Motion to Dismiss via CM/ECF
Fwd: Fw: Epstein -- I apologize if you have received this...
Epstein forwards a prior email chain, noting delivery issues.
Motion for Extension of Time
Filing of the motion and service to listed attorneys.
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