Isidro M. Garcia
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Jane Doe
|
Client |
5
|
5 | |
|
person
plaintiff
|
Counsel for plaintiff |
1
|
1 | |
|
person
plaintiff
|
Client |
1
|
1 | |
|
person
plaintiff
|
Counsel for |
1
|
1 | |
|
person
Jane Doe
|
Legal representative |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2010-07-02 | N/A | Filing of Plaintiff's Counsel's Response to Court's Order to Show Cause | United States District Cour... | View |
| 2009-07-14 | N/A | Plaintiff filed Memorandum in Opposition to Defendant Kellen's Motion. | United States District Cour... | View |
| 2008-09-18 | N/A | Filing of Plaintiff's Unopposed Motion for Enlargement of Time | Southern District of Florida | View |
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.
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.
081.pdf
Legal filing from July 2, 2010, in the case of Jane Doe II vs. Jeffrey Epstein and Sarah Kellen. Plaintiff's counsel Isidro Garcia responds to a court order, apologizing for delays in filing a scheduling report, partly attributing the delay to difficulty serving Sarah Kellen who was 'believed to have been avoiding service.' The document announces that a settlement has been reached resolving all claims in this federal case and a companion state court case.
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.
069.pdf
This document is a legal motion filed on November 9, 2009, by Igor Zinoviev, a third-party witness and employee of Jeffrey Epstein, seeking a protective order to prevent or limit his deposition in the civil case 'Jane Doe No. 2 v. Jeffrey Epstein'. Zinoviev claims he has no relevant information for the civil cases as his employment with Epstein began in November 2005, after the period of the alleged misconduct, and he has not discussed Epstein's criminal or civil cases with him.
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.
047.pdf
This document is a Plaintiff's Memorandum of Law filed on July 14, 2009, in the case of Jane Doe II v. Jeffrey Epstein and Sarah Kellen. The Plaintiff opposes Sarah Kellen's motion to set aside a default judgment, arguing that Kellen was properly served via 'nail and mail' in New York on April 23, 2009, after six attempts, and deliberately ignored the lawsuit. The filing asserts Kellen has provided no evidence she didn't receive service and has failed to present a meritorious defense as required by law.
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.
037.pdf
This document is a Plaintiff's Motion for Default filed on June 12, 2009, in the Southern District of Florida against Sarah Kellen in the case of Jane Doe II vs. Jeffrey Epstein and Sarah Kellen. The motion asserts that Kellen has been avoiding service but was successfully served according to New York law and failed to respond. Notably, it alleges that Kellen is aware of the legal action and has visited Jeffrey Epstein at the Palm Beach County Jail on several occasions.
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.
020.pdf
This document is the Plaintiff's Memorandum of Law in Opposition to Defendant Epstein's Motion to Dismiss in a civil case. The Plaintiff argues that the federal court has jurisdiction alongside state claims, that the 2006 amendments to 18 U.S.C. §2255 regarding damages should apply retroactively or are procedural, and that interstate commerce requirements were met via phone calls made by co-defendant Sarah Kellen from a New York number. The document details specific dates of solicitation between 2003 and 2005 and alleges a conspiracy involving Epstein, Kellen, and Haley Robson to procure minors for prostitution.
016.pdf
This document is a legal motion filed on May 15, 2009, in the Southern District of Florida, case number 09-80469-CIV-MARRA. Plaintiff Jane Doe II requests an extension until May 22, 2009, to file a reply to Defendant Jeffrey Epstein's Motion to Dismiss, citing complex issues and other business. Epstein's counsel, Robert Critton, was consulted and did not oppose the extension.
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.
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.
002.pdf
This document is a Civil Summons from the United States District Court, Southern District of Florida, dated March 24, 2009. It notifies defendants Jeffrey Epstein and Sarah Kellen (a.k.a. Sarah Bonk) that they are being sued by Jane Doe II and must respond within 20 days. Notably, the summons lists Sarah Kellen's address in New York City and Jeffrey Epstein's address as the Palm Beach County Stockade, including his inmate jacket number.
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.
016.pdf
This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, seeking a protective order to prevent or limit his deposition in the case of Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, a driver and bodyguard for Epstein since November 2005, claims he has no relevant information regarding Epstein's criminal or civil cases, particularly concerning events prior to September 2005. The motion cites legal precedents regarding the scope of discovery and Federal Rules of Civil Procedure Rule 26(c) to argue against the deposition.
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.
Service of Response to Order to Show Cause
Service of legal filing via electronic transmission
Plaintiff's Memorandum of Law in Opposition to Defendant ...
Service of legal memorandum via electronic case management system.
Service of Motion for Default
Certificate of service for the motion
Enlargement of time
Counsel consulted regarding extension of time to file reply; Critton did not oppose.
Service of Motion
Service of the Unopposed Motion for Enlargement of Time
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