Isidro Manuel Garcia
PersonRelationship Network
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.
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.
032.pdf
This document is a legal reply filed on June 4, 2009, by Plaintiffs Jane Doe No. 101 and 102 in the US District Court for the Southern District of Florida. The plaintiffs are requesting a court order prohibiting Jeffrey Epstein and his agents from contacting them directly or indirectly, citing his status as a convicted sex offender and their fear of intimidation. The document also includes a service list detailing the legal representation for various parties, including Bruce E. Reinhart representing co-defendant Sarah Kellen.
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.
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.'
020.pdf
This document is an agreed motion filed on May 13, 2010, in the Southern District of Florida by Plaintiff Jane Doe No. 103 against Defendant Jeffrey Epstein. The plaintiff requests a one-week extension to file a response to Epstein's motion to dismiss because the parties are in the process of resolving the matter via settlement, which would render the motion moot. The document includes a comprehensive service list detailing legal counsel for Epstein, Co-Defendant Sarah Kellen (represented by Bruce Reinhart), and plaintiffs in several related cases.
016.pdf
This document is an agreed motion for an extension of time filed on April 22, 2010, in the case of Jane Doe No. 103 vs. Jeffrey Epstein (Case No. 10-80309-WJZ). Plaintiff's counsel, Katherine W. Ezell, requests an extension until May 13, 2010, to file a response to Epstein's motion to dismiss because she is leaving for a vacation in Italy the following day. The motion notes that Epstein's counsel, Robert Critton, agrees to the extension, and the document includes a service list of attorneys involved in this and related cases.
012.pdf
This document is a Motion to Transfer filed on April 1, 2010, by Plaintiff Jane Doe No. 103 in the US District Court, Southern District of Florida. The plaintiff seeks to transfer her case against Jeffrey Epstein to Judge Marra's division to consolidate it with other similar pending cases, specifically 'Jane Doe No. 2 vs. Jeffrey Epstein'. The document includes a service list detailing legal counsel for Epstein, co-defendant Sarah Kellen (represented by Bruce Reinhart), and plaintiffs in several related cases.
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.
024.pdf
This document is a legal motion filed on May 29, 2009, in the Southern District of Florida by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein. The plaintiffs request leave to file their response to Epstein's motion to stay under seal because it references the confidential Non-Prosecution Agreement (NPA), or alternatively, to unseal the NPA. The document includes a comprehensive service list detailing the legal representation for Epstein (including Robert Critton and Jack Goldberger), Sarah Kellen (represented by Bruce Reinhart), and numerous other Jane Doe plaintiffs.
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. ยง 2255, and accuses Epstein of using the threat of publicity to intimidate victims into settling.
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.
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.
010.pdf
This document is a 'Notice of Striking Docket Entry' filed on May 4, 2009, in the United States District Court for the Southern District of Florida, case Jane Doe No. 101 v. Jeffrey Epstein. The plaintiff's counsel, Katherine W. Ezell of Podhurst Orseck, P.A., notifies the court that a previous docket entry was filed without a signature and has been re-filed correctly. The document includes a Certificate of Service listing numerous attorneys involved in this case and related cases against Epstein, including Bruce Reinhart (defense), Jack Scarola, and Brad Edwards.
008.pdf
This document is a legal response filed by Plaintiff Jane Doe 101 in the United States District Court for the Southern District of Florida on May 1, 2009. The plaintiff agrees to the court's order to consolidate ten separate cases filed by various Jane Does and C.M.A. against Jeffrey Epstein for the purposes of discovery. The document includes a service list detailing the contact information for attorneys representing the various plaintiffs and the defendant.
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