Burman, Critton, Luttier & Coleman, LLP
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068.pdf
This document is a Mandate from the Fourth District Court of Appeal of Florida, dated September 18, 2009, regarding the case of Jeffrey Epstein v. State of Florida. The mandate follows an opinion issued on September 2, 2009, where the court affirmed the lower court's decision, treating Epstein's petition for writ of certiorari as a full appeal. The document lists numerous attorneys involved, including R. Alexander Acosta on the distribution list, and identifies Palm Beach Newspapers, Inc. as an appellee alongside the State and a redacted party.
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.
047.pdf
Legal motion filed on June 25, 2009, by Jeffrey Epstein's defense team (Critton, Pike, Goldberger) in Palm Beach County Circuit Court. Epstein requests a stay on the disclosure of his Non-Prosecution Agreement (NPA) pending an appellate review, arguing that unsealing the document would cause irreparable harm to privacy rights and innocent third parties. The motion opposes efforts by the Palm Beach Post and a redacted non-party to unseal these court records.
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.
017-17.pdf
This document is a Motion for Protective Order filed on June 30, 2010, by Jeffrey Epstein's defense team in the civil case Jane Doe v. Jeffrey Epstein. Epstein seeks permission to redact specific portions of his tax returns regarding investment vehicles, claiming they contain trade secrets and confidential business information. The motion argues that Plaintiff's counsel, Brad Edwards, has a history of sharing discovery material with media and investigators, specifically citing an instance involving Alfredo Rodriguez's journal.
017-15.pdf
This document is a Motion for Protective Order filed on June 28, 2010, by Jeffrey Epstein's legal team in the case of Jane Doe No. 2 vs. Jeffrey Epstein. The motion requests that the court issue an order of confidentiality regarding information Epstein was compelled to produce, specifically his tax returns, passport, and information provided by the federal government during prior criminal proceedings. The defense seeks to prevent this information from being disclosed to third parties or the media and to limit its use strictly to the current litigation.
017-09.pdf
This document contains a Motion for Reconsideration filed by Jeffrey Epstein's legal team in February 2010, arguing against a Magistrate's order compelling him to produce sensitive documents. The motion relies heavily on Fifth Amendment protections against self-incrimination, arguing that despite a Non-Prosecution Agreement, Epstein faces real risks of prosecution in other jurisdictions. Attached exhibits include the Plaintiff's 2009 requests for production of massage logs, photos of Epstein's Palm Beach home, financial records, and medical records from Dr. Stephan Alexander, to which Epstein consistently objected.
017-02.pdf
This document is a legal response filed by Jeffrey Epstein's legal team on October 6, 2009, opposing a Motion to Compel discovery filed by Plaintiff Jane Doe No. 2. Epstein asserts his Fifth Amendment privilege against self-incrimination to refuse the production of photographs of his Palm Beach home (specifically massage rooms), financial records, tax returns, passport/travel records, and medical records from Dr. Stephan Alexander. The defense argues that despite the Non-Prosecution Agreement (NPA), the threat of federal prosecution remains real and substantial, particularly in districts outside the Southern District of Florida, and that the act of producing these documents would be testimonial and incriminating.
016-12.pdf
This document is a Motion for Sanctions filed by Plaintiff Jane Doe No. 4 against Jeffrey Epstein for violating a no-contact order and a written stipulation. On September 16, 2009, Epstein appeared in the lobby of the building where Jane Doe No. 4's deposition was scheduled, staring her down and causing her to flee in distress, despite an agreement that he would not attend. The document includes a declaration from attorney Adam Horowitz, a transcript of the cancelled deposition where defense counsel Robert Critton argues Epstein was simply leaving his office in the same building, and an email confirming the prior stipulation.
020.pdf
This document is a Motion to Dismiss filed by Jeffrey Epstein's legal team on June 16, 2010, in the case of L.M. v. Epstein. Epstein's lawyers argue the case should be dismissed because the plaintiff failed to serve the complaint within the required 120 days (Rule 4(m)). Furthermore, the motion alleges that the complaint filed by L.M. (represented by Bradley Edwards) was used as a prop in Scott Rothstein's massive $1.2 billion Ponzi scheme to lure investors with fabricated settlement agreements. The document cites depositions where L.M. contradicts allegations made in her complaint regarding sexual acts and travel.
019.pdf
A Notice of Appearance filed on June 16, 2010, in the US District Court for the Southern District of Florida (Case 09-CIV-81092-Marra/Johnson). Attorneys Robert D. Critton, Jr. and Michael J. Pike of Burman, Critton, Luttier & Coleman, LLP formally enter their appearance as counsel for the Defendant, Jeffrey Epstein. The document includes a certificate of service to Brad Edwards, counsel for the Plaintiff.
018.pdf
This document is a Notice of Appearance filed on June 16, 2010, in the United States District Court for the Southern District of Florida for Case No. 09-CIV-81092 (L.M. v. Jeffrey Epstein). The law firm Burman, Critton, Luttier & Coleman, LLP, specifically attorneys Robert D. Critton, Jr. and Michael J. Pike, formally enters their appearance as legal counsel for the defendant, Jeffrey Epstein. The document includes a certificate of service indicating that the notice was electronically served to Brad Edwards, attorney for the plaintiff.
017.pdf
This document is a legal notice filed on June 14, 2010, in the United States District Court for the Southern District of Florida, regarding the case of Jane Doe No. 2 v. Jeffrey Epstein. The filing, submitted by attorney Spencer T. Kuvin on behalf of Plaintiff 'C.L.', serves to withdraw a subpoena and cancel the scheduled deposition of Maritza Milagros Vasquez, which was set for the following day, June 15, 2010. The document also includes a certificate of service listing various attorneys representing different parties in related cases against Epstein.
010.pdf
This is a motion filed by Defendant Jeffrey Epstein's attorneys requesting a court order to allow him to attend mediation, deposition, and trial in the case of Jane Doe No. 2 v. Jeffrey Epstein. The motion notes that a prior no-contact order involving Carolyn Andriano might technically preclude this, but states that Plaintiff's counsel and Ms. Andriano have no objection. The document includes a certificate of service listing numerous attorneys involved in related cases.
009.pdf
Legal filing from November 2009 in the case of Jane Doe No. 2 v. Jeffrey Epstein. Epstein's attorneys argue for the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), noting that the DOJ has seized boxes of documents from RRA, including 13 boxes related to Epstein. The document also disputes delays in the deposition of RRA's Chief Restructuring Officer, Herbert Stettin, citing upcoming trial deadlines.
080.pdf
This document is a Stipulation of Dismissal with Prejudice filed on June 30, 2010, in the case of Jane Doe II v. Jeffrey Epstein and Sarah Kellen in the Southern District of Florida. The parties agreed to dismiss the lawsuit with prejudice, meaning it cannot be refiled, with each party bearing their own legal costs. The document notes that a settlement was reached, and the court retains jurisdiction to enforce its terms.
078.pdf
This document is a legal notice filed on June 14, 2010, in the case of Jane Doe No. 2 v. Jeffrey Epstein. The notice, filed by attorney Spencer T. Kuvin on behalf of Plaintiff C.L., withdraws a subpoena and cancels the deposition of Maritza Milagros Vasquez, which was scheduled for the following day, June 15, 2010. The document also includes a certificate of service listing legal counsel for various parties involved in related cases.
071.pdf
A 2009 legal motion filed in the Southern District of Florida on behalf of Jeffrey Epstein requesting permission to attend mediation in a case involving Carolyn Andriano (C.M.A.). The motion notes that a prior 'no contact order' exists regarding Andriano, but states that neither she nor her counsel object to Epstein's presence at depositions, mediation, or trial. The document includes a comprehensive service list of attorneys involved in multiple related cases against Epstein.
061.pdf
This document is Jeffrey Epstein's Answer and Affirmative Defenses to a civil complaint filed by Jane Doe II in the Southern District of Florida in October 2009. Epstein pleads the Fifth Amendment against self-incrimination in response to most factual allegations. He asserts multiple affirmative defenses, claiming the plaintiff consented to the acts, that he believed she was 18 years or older, and that the claims are barred by the statute of limitations and various constitutional challenges to the retroactivity and application of 18 U.S.C. §2255.
050.pdf
This document is a Notice of Compliance filed by Jeffrey Epstein's legal team (Burman, Critton, Luttier & Coleman) on July 28, 2009, in the US District Court for the Southern District of Florida. It addresses a court order regarding the preservation of evidence and a protective order, noting that while the parties agreed on many sections, they could not finalize a joint order, leading Epstein to submit his own proposed order separately. The document lists numerous related civil cases involving Jane Doe plaintiffs and provides a comprehensive service list of attorneys involved in the various Epstein-related litigations at that time, including Bruce Reinhart representing Sarah Kellen.
040.pdf
This document is a 'Notice of Reliance' filed on June 19, 2009, in the case of Jane Doe II v. Jeffrey Epstein (Case No. 09-CIV-80469) in the Southern District of Florida. Epstein's legal team informs the court that despite the Plaintiff filing an Amended Memorandum of Law on June 12, 2009, Epstein will not file a new supplemental reply but will instead rely on his previous arguments filed on June 1, 2009. The document outlines the procedural history of the motion to dismiss and includes a certificate of service listing attorneys for both parties.
031.pdf
This document is a Reply by Defendant Jeffrey Epstein to Plaintiff Jane Doe II's opposition to his motion to dismiss a civil suit (Case 09-CIV-80469). Epstein's defense argues that a concurrent state action requires dismissal of the federal case, that the 2006 amendment to 18 U.S.C. §2255 ('Masha's Law') cannot be applied retroactively to conduct from 2003-2005 to increase damages, and that the Plaintiff misrepresents the terms of Epstein's non-prosecution agreement with the US Attorney's Office. The document details specific dates in 2003 and 2004 where the Plaintiff alleges she received payments for acts of prostitution.
015-01.pdf
This document is a Motion to Stay proceedings filed by Jeffrey Epstein's legal team in a civil case brought by a plaintiff identified as C.M.A. Epstein argues that the civil case should be paused until late 2010, when his Non-Prosecution Agreement (NPA) with federal prosecutors expires, to avoid forcing him to waive his 5th Amendment rights against self-incrimination while facing potential ongoing criminal liability. The filing includes an affidavit from his criminal defense attorney, Jack Goldberger, and an Indictment from 2006 for Felony Solicitation of Prostitution.
013.pdf
This document is a Motion to Dismiss filed by Jeffrey Epstein's defense team in the U.S. District Court for the Southern District of Florida on May 6, 2009, against Plaintiff Jane Doe II. The defense argues that the federal case should be dismissed because a nearly identical state case was filed 10 months prior, and because the plaintiff is improperly applying a 2006 amendment to 18 U.S.C. §2255 retroactively to conduct alleged to have occurred between 2003 and 2005, thereby violating the Ex Post Facto clause. Additionally, the motion argues that the statute does not allow for multiplying damages per incident and that the plaintiff failed to allege the necessary interstate commerce elements required for federal jurisdiction.
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