This document is a legal motion filed on November 23, 2010, in the United States District Court for the Southern District of Florida (Case 9:10-CV-81111-WPD). Attorney Bradley J. Edwards requests the court to admit Paul G. Cassell (a member of the Utah Bar) to appear pro hac vice as co-counsel for the plaintiff, identified as M.J., in a civil suit against Jeffrey Epstein and Sarah Kellen. The document documents the payment of a $75 admission fee and lists the defense counsel for Jeffrey Epstein from the firm Fowler White Burnett PA.
This document is a Motion for a Protective Order filed by plaintiff M.J. on November 11, 2010, requesting the court bar Jeffrey Epstein from direct or indirect contact. The motion details a pattern of Epstein using private investigators to harass and intimidate victims and witnesses, specifically citing an incident on July 1, 2010, where a PI named Thaddeus Knowles followed 'Jane Doe' and flashed lights into her home. It also references Epstein's intimidation of other witnesses including Sarah Kellen, Leslie Groff, and Alfredo Rodriguez, and his history of violating no-contact orders.
This document is a Plaintiff's Response to Defendant Jeffrey Epstein's Motion to Quash Service of Process. The plaintiff, M.J., argues that service was properly effected on October 8, 2010, when a private investigator handed the papers to an employee named 'Mark' at Epstein's New York mansion. The filing accuses Epstein and his associate Richard Barnett of fraud and perjury for submitting an affidavit claiming service never occurred, and details a pattern of obstruction by Epstein and his associates (including Ghislaine Maxwell and Jean Luc Brunel) in similar civil cases.
This document is a legal notice filed on November 2, 2010, in the United States District Court for the Southern District of Florida (Case 9:10-cv-81111) by the plaintiff, identified as M.J. The filing strikes two previous certificates of service (DE 5 and DE 6) related to a summons and a subpoena for defendant Jeffrey Epstein due to incorrect filing. The document names Jeffrey Epstein and Sarah Kellen as defendants and lists contact information for attorneys representing both sides.
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