Burman, Critton, Luttier & Coleman, LLP
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009.pdf
This document is a legal response filed by Jeffrey Epstein's attorneys on May 4, 2009, in the Southern District of Florida. Epstein opposes the court's potential order to consolidate multiple civil lawsuits (filed by various 'Jane Doe' plaintiffs) for all discovery purposes, arguing that while consolidating depositions is acceptable, full consolidation would confuse distinct facts and defenses unique to each case. The filing lists numerous related case numbers and requests clarification on how consolidation would operate regarding motion practice.
007.pdf
This document is an unopposed motion filed on May 1, 2009, in the Southern District of Florida (Case 09-CIV-80469) by Jeffrey Epstein's attorneys requesting a five-day extension to file a response to Jane Doe II's complaint. The extension (until May 6, 2009) was requested because Epstein's counsel, Robert D. Critton, Jr., was preparing for an unrelated state court trial. The document confirms that Plaintiff's counsel, Isidro M. Garcia, agreed to this extension.
024.pdf
This document is an unopposed motion filed on September 18, 2008, by Plaintiff Jane Doe in the Southern District of Florida (Case 08-80804) against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The plaintiff requests an extension of time to respond to Epstein's Motion to Dismiss until 15 days after the court rules on a pending motion to remand the case to state court due to alleged lack of federal jurisdiction. The document lists legal counsel for all parties, including Bruce Reinhart representing Sarah Kellen.
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.
018.pdf
This document is a Motion for Stay filed by defendants Jeffrey Epstein and Sarah Kellen in a civil lawsuit brought by Jane Doe. They argue that a stay is mandatory under federal law because of a pending federal criminal investigation/action (the deferred prosecution agreement). Attached is a declaration from AUSA A. Marie Villafana detailing the government's interaction with victims (T.M., C.W., S.R.) and providing copies of notification letters sent to them and their attorneys regarding their rights and the non-prosecution agreement.
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.
016-01.pdf
This document contains a Proposed Order and an Unopposed Motion for Enlargement of Time filed by Plaintiff Jane Doe in a civil case against Jeffrey Epstein, Haley Robson, and Sarah Kellen (Case No. 08-80804). Filed on August 13, 2008, the motion requests an extension to file a Civil RICO Case Statement until after the court rules on an upcoming motion to remand the case back to state court. The plaintiff argues the case was improperly removed to federal court and lacks federal jurisdiction. The document includes a service list identifying legal counsel for all parties, including Bruce Reinhart representing Sarah Kellen.
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.
012.pdf
This document is a motion filed on August 21, 2008, by Plaintiff Jane Doe in a civil case against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The plaintiff requests the court to preserve evidence seized by the Palm Beach Police Department from Epstein's home, citing concerns that Epstein (who had recently pleaded guilty and was in jail) was attempting to retrieve the evidence through State Court and might destroy it. The document includes a service list identifying legal counsel for all parties, including Bruce E. Reinhart representing Sarah Kellen.
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.
003.pdf
This document is a Motion for Enlargement of Time filed on July 25, 2008, in the Southern District of Florida civil case Jane Doe v. Jeffrey Epstein, et al. Defendants Epstein and Sarah Kellen request an extension to answer the complaint until 10 days after a decision is made on their contemporaneous motion to stay the case, citing 18 U.S.C. § 3509 regarding civil stays during parallel criminal proceedings involving child victims. The document includes a service list detailing legal representation for all parties, including Bruce Reinhart as counsel for Sarah Kellen.
002.pdf
Defendants Jeffrey Epstein and Sarah Kellen filed a request for oral argument on July 25, 2008, in the Southern District of Florida regarding a motion to stay civil proceedings pending the resolution of a criminal action. The document lists legal representation for all parties, including Jane Doe (Plaintiff) and Haley Robson (Co-Defendant). Attorneys Michael R. Tein and Guy A. Lewis are the primary signatories for Epstein.
001.pdf
This document is a Notice of Removal filed by defendants Jeffrey Epstein, Sarah Kellen, and Haley Robson, seeking to move a civil lawsuit filed by Jane Doe from the Circuit Court of the Fifteenth Judicial Circuit in Palm Beach County, Florida, to the United States District Court for the Southern District of Florida. The defendants argue that the non-diverse defendant, Haley Robson, was fraudulently joined solely to defeat diversity jurisdiction and prevent removal. Attached as Exhibit A is a deposition transcript of Jane Doe (whose name is redacted) taken on February 20, 2008, in a related criminal case, where she is questioned about her age, MySpace profiles, inconsistencies in her statements to police regarding sexual contact with Epstein, and her interactions with various attorneys and law enforcement officials.
030.pdf
This document is a Notice of Withdrawing Subpoena filed on June 14, 2010, in the United States District Court for the Southern District of Florida. Plaintiff C.L., represented by attorney Spencer T. Kuvin, withdrew a subpoena and cancelled the deposition of Maritza Milagros Vasquez, which had been scheduled for June 15, 2010. The document includes a certificate of service listing legal counsel for various parties involved in the primary case (Jane Doe No. 2 v. Jeffrey Epstein) and related cases.
017.pdf
Legal filing from November 2009 in the case of Jane Doe No. 2 v. Jeffrey Epstein. Epstein's attorneys reply to a response regarding the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), which was undergoing restructuring. The document notes that the Department of Justice had seized approximately 40 boxes of documents from RRA, including 13 boxes related to the Epstein case, and alludes to serious ethical and criminal issues involving the RRA firm that could impact the validity of the cases against Epstein.
015.pdf
This document is a Reply Memorandum filed by Jeffrey Epstein's legal team on August 20, 2009, in the case of Jane Doe No. 8 v. Jeffrey Epstein. The defense argues that the plaintiff's claims of 'Sexual Assault and Battery' (Count I) and 'Coercion and Enticement' (Count III) should be dismissed because they are barred by the statute of limitations. Epstein's lawyers contend that because the plaintiff was aware of the injury at the time of the alleged incident in 2001 (when she was 16) and turned 18 in 2003, the time limits for filing suit (4 years and 6 years respectively) had expired by the time the complaint was filed in 2009.
008.pdf
This document is a Motion to Dismiss filed by Jeffrey Epstein's defense team on July 14, 2009, in the case of Jane Doe No. 8 v. Jeffrey Epstein. The defense argues that the plaintiff's claims of Sexual Assault and Battery (Count I) and Coercion (Count III) are barred by the applicable 4-year (state) and 6-year (federal) statutes of limitations, as the alleged incident occurred in 2001 when the plaintiff was 16. Footnotes in the document provide graphic details of the allegations, describing how Jane Doe was recruited by another girl, brought to Epstein's Palm Beach mansion, and sexually assaulted during a massage.
006.pdf
This document is an unopposed motion filed on July 7, 2009, in the US District Court for the Southern District of Florida by Jeffrey Epstein's legal team. Epstein's attorneys requested a one-week extension (until July 14, 2009) to respond to a complaint filed by 'Jane Doe No. 8' on May 28, 2009, citing workload from other cases involving Epstein. The motion notes that opposing counsel agreed to this extension.
004.pdf
Legal document filed on June 5, 2009, in the Southern District of Florida court case 'Jane Doe No. 8 v. Jeffrey Epstein'. The document is a Notice of Appearance indicating that attorneys Robert D. Critton, Jr. and Michael J. Pike of the law firm Burman, Critton, Luttier & Coleman, LLP are entering the case to represent the defendant, Jeffrey Epstein. The service list includes contact information for other attorneys involved, including Jack Alan Goldberger (also for Epstein) and Adam D. Horowitz (for the Plaintiff).
015.pdf
This document is a motion filed on April 12, 2010, by Jeffrey Epstein's legal counsel in the case 'Jane Doe No. 103 vs. Jeffery Epstein'. The defense seeks to amend their previous Motion to Dismiss to clarify an argument regarding retroactivity, specifically stating that the criminal statute (18 U.S.C. § 2252A(g)) relied upon by the plaintiff did not exist during the time of the alleged abuse (Jan 2004 - May 2005). The plaintiff's counsel reportedly did not oppose this amendment.
006.pdf
This document is an unopposed motion filed on March 23, 2010, in the United States District Court for the Southern District of Florida, requesting an extension of time for Jeffrey Epstein to respond to a complaint filed by Jane Doe No. 103. Epstein's legal team requests the deadline be moved from March 26 to April 5, 2010, citing workload from 'several other cases' filed in the same court in which Epstein is a defendant. The plaintiff's counsel agreed to this extension.
004.pdf
This is a Summons in a Civil Case issued by the United States District Court for the Southern District of Florida on February 23, 2010. The case (No. 10-80309) involves plaintiff Jane Doe 103 suing defendant Jeffrey Epstein. The summons directs Epstein to serve an answer to the complaint within 21 days via his counsel, Robert D. Critton, to the plaintiff's attorneys at Podhurst Orseck, P.A.
059.pdf
This document is a motion filed on November 20, 2009, in the US District Court for the Southern District of Florida, requesting permission for Jeffrey Epstein to attend mediation in the case involving Carolyn Andriano (C.M.A.). The motion notes that a previous no-contact order exists regarding Andriano, but her counsel has no objection to Epstein attending the deposition, mediation, or trial. The document includes a service list detailing the attorneys involved in this and related cases, including Bruce Reinhart representing Sarah Kellen.
057.pdf
This document is a legal reply filed by Jeffrey Epstein's legal team on November 16, 2009, regarding the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA). The filing notes that the Department of Justice seized approximately 40 boxes of documents from RRA, including 13 boxes specifically related to Epstein cases. The document highlights scheduling conflicts involving the deposition of Herbert Stettin (RRA's Chief Restructuring Officer) and alludes to potential ethical or criminal issues within RRA that could impact the validity of the cases against Epstein.
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