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.
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).
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.
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.
This document is a legal motion filed on June 9, 2009, by Plaintiff Jane Doe No. 101 requesting an extension of time and page limits to respond to Jeffrey Epstein's Motion to Dismiss. The request is based on an upcoming court hearing scheduled for June 12, 2009, in a related case (Jane Doe No. 2 vs. Jeffrey Epstein) which addresses potential breaches of Epstein's Non-Prosecution Agreement. The document includes certificates of conference and service, listing legal counsel for both parties, including Bruce Reinhart as counsel for a co-defendant named Sarah.
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.
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.
This document is a 'Notice of Filing Withdrawal of Previously Raised Objections' filed on May 20, 2009, in the US District Court for the Southern District of Florida. Plaintiff C.M.A. withdraws her objections to Jeffrey Epstein's motion to compel her to identify herself by her legal name in the case style and third-party subpoenas, though she maintains her objection to the case being dismissed sua sponte. The document lists numerous related cases involving Jane Doe plaintiffs and provides a service list of attorneys involved.
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.
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.
This document is a Plaintiff's Notice of Serving Second Amended Answers to Interrogatories in a 2009 civil case against Jeffrey Epstein in the Southern District of Florida. The plaintiff, whose name is redacted, details her residence history and her interactions with Epstein between 2002 and 2003, stating she visited his Florida home roughly twice a week to provide massages after being introduced by a friend. The document reveals she recruited other females for Epstein in exchange for payment, used drugs (Morning Glory, Angel Trumpets, cocaine, marijuana) during the relevant period, and lists various legal counsel and law enforcement entities involved in the investigation.
This document is a page from a legal filing, listing contact information for various attorneys and their respective clients in several related court cases. It details counsel for plaintiffs, including C.M.A., and counsel for defendants Sarah Kellen and Jeffrey Epstein, along with their law firms and contact details.
This document is a page from a court filing, Case 9:08-cv-80119-KAM, dated September 17, 2009, listing multiple attorneys and their respective law firms, contact information, and the specific related cases they represent plaintiffs in. It details legal counsel for various plaintiffs, including 'Jane Doe' and 'C.M.A.', across several related case numbers, providing contact details for each attorney and their firm.
This document is a service list for the 2008 court case No. 50 2008 CA 006596 XXXX MB AB. It provides the names, law firms, and contact information for the attorneys representing various parties in the case. Key parties and their counsel include the State of Florida (represented by Lanna Belohlavek), Jeffrey Epstein (represented by Jack A. Goldberger and Robert Critton), Sarah Kellen (represented by Bruce E. Reinhart), and Haley Robson (represented by Douglas M. McIntosh and Jason A. McGrath).
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