Legal document filed on May 11, 2009, in the US District Court for the Southern District of Florida (Case 09-80656). Attorneys Robert D. Critton, Jr. and Michael J. Pike of the firm Burman, Critton, Luttier & Coleman formally entered their appearance as counsel for the defendant, Jeffrey Epstein, in a civil suit brought by Jane Doe No. 102. The document includes a certificate of service listing other counsel involved, including Jack Alan Goldberger for the defense and attorneys from Podhurst Orseck, P.A. for the plaintiff.
This document is a Motion for Extension of Time filed on December 2, 2009, by Jeffrey Epstein's legal team in the case of Jane Doe No. 101 v. Jeffrey Epstein. The defense requested an extension until December 15, 2009, to file a reply, citing ongoing settlement negotiations and the need to investigate the implications of the 'Rothstein Rosenfeldt & Adler, PA' firm implosion on the Plaintiff's counsel. The document notes that Plaintiff's counsel opposed this extension request.
This document is an 'Unopposed Motion for Extension of Time' filed on August 7, 2009, in the case of Jane Doe No. 101 v. Jeffrey Epstein in the Southern District of Florida. Epstein's legal team requests an extension until October 15, 2009, to reply to the Plaintiff's response to the motion to dismiss, citing that the parties are working together to find a resolution. The motion lists legal counsel for both sides, including attorneys from Burman, Critton, Luttier & Coleman, Atterbury Goldberger & Weiss, and Podhurst Orseck.
Legal filing from June 12, 2009, in the case of Jane Doe No. 101 v. Jeffrey Epstein in the Southern District of Florida. Epstein's legal team withdraws seven specific arguments previously made in a Motion to Dismiss regarding the Plaintiff's First Amended Complaint, including arguments about the plaintiff's minority status and predicate offenses. The defense states it will now rely solely on arguments regarding count merger and subparagraph D.
This document is a formal legal letter dated May 15, 2009, from Robert C. Josefsberg of Podhurst Orseck to Jeffrey Epstein's attorneys (Robert Critton and Jack Goldberger). The letter demands the immediate preservation of all evidence, particularly electronically stored information (ESI), relevant to pending civil actions by victims of Epstein's sexual exploitation. It specifically references the Non-Prosecution Agreement, the 2005 FBI raid, and warns that failure to preserve data could result in sanctions for spoliation.
This document is a Motion for Limited Appearance filed on May 21, 2009, in the US District Court for the Southern District of Florida (Case 9:09-CV-80591-KAM). Robert D. Critton, Jr. requests the court to admit Michael D. Shumsky of Kirkland & Ellis LLP as co-counsel for the defendant, Jeffrey Epstein. The document lists legal counsel for both the plaintiff (Jane Doe 101) and the defendant, along with their contact information.
This document is an unopposed motion filed on May 18, 2009, by Jeffrey Epstein's legal counsel in the case of Jane Doe No. 101 v. Jeffrey Epstein in the Southern District of Florida. Epstein's lawyers requested permission to exceed the standard 20-page limit for their upcoming motion to dismiss, citing complex legal issues regarding the interpretation of 18 U.S.C. §2255 and its applicability to the alleged conduct. Plaintiff's counsel agreed to this request via telephone.
This document is a Notice of Appearance filed on May 7, 2009, in the United States District Court for the Southern District of Florida (Case No. 09-80591-MARRA/JOHNSON). Attorneys Robert D. Critton, Jr. and Michael J. Pike of the law firm Burman, Critton, Luttier & Coleman formally enter their appearance as counsel for the Defendant, Jeffrey Epstein. The document includes a Certificate of Service listing counsel for the Plaintiff (Jane Doe No. 101) and co-counsel for the Defendant.
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 an unopposed motion filed on May 11, 2010, in the Southern District of Florida (Case 10-80447) by Plaintiff C.L. requesting a 10-day extension to respond to Defendant Jeffrey Epstein's Motion to Dismiss. The extension was requested because Plaintiff's counsel, Spencer T. Kuvin, had a conflicting trial starting the same day in Palm Beach Civil Circuit Court. The document includes a Certificate of Service listing Epstein's legal team (Critton, Pike, Goldberger) and a proposed order for Judge Kenneth A. Marra to sign.
This document contains an email chain from December 2020 between the SDNY US Attorney's Office and defense counsel regarding plea negotiations for a former personal assistant of Jeffrey Epstein. It includes a draft 'Statement of Facts' detailing the assistant's role from 2001-2013 in scheduling massages for minors, paying victims, and allegedly participating in witness tampering in 2005, while also acknowledging the assistant was a victim of Epstein's abuse.
This document is a 13-page New York Sex Offender Registry report for Jeffrey Epstein dated June 27, 2019. It lists his risk level as 3, details his primary residence in the Virgin Islands and secondary residences in Florida, New York, New Mexico, and Paris. The report cites a 2008 conviction for a sex offense involving females aged 14 and 16. It also contains an extensive list of vehicles owned by Epstein, including multiple Chevrolet Suburbans, a Bentley, a Hummer, and notably a 'Gulf Stream Unknown' listed under vehicles.
This document is a partial transcript from a court proceeding on September 17, 2009, detailing the cancellation of a deposition involving Jeffrey Epstein. The deposition was called off because Jeffrey Epstein made face-to-face contact with the plaintiff, Jane Doe 4, which her counsel, Adam Horowitz, stated intimidated her and violated a prior stipulation that Epstein would not be present. Defense counsel, Robert Critton, argued that Epstein was instructed to leave the building and planned to appear via Skype, and that the encounter would not have happened if the plaintiff and her counsel had arrived on time.
This is a court filing from the United States District Court for the Southern District of Florida, dated October 28, 2009. Attorneys Jack Scarola and Jack P. Hill, representing an unnamed (redacted) Plaintiff, filed a notice confirming they served 'Second Amended Answers to Interrogatories' to the defendants, Jeffrey Epstein and Sarah Kellen. The document notes that the original interrogatories were propounded by Epstein on January 16, 2009. It is marked as Defendant's Exhibit C-9 in a later criminal case (20 Cr. 330).
This legal document is a 'Notice of Serving Answers to Interrogatories' filed in the Southern District of Florida on February 18, 2009. It certifies that the Plaintiff (whose name is redacted) has provided answers to questions (interrogatories) previously asked by Defendant Jeffrey Epstein on January 16, 2009. The document lists Sarah Kellen as a co-defendant and was prepared by attorney Jack Scarola of the firm Searcy Denney Scarola Barnhart & Shipley, P.A. The document was later used as Defendant's Exhibit C-8 in the criminal trial S2 20 Cr. 330 (US v. Ghislaine Maxwell).
This document is a letter dated January 8, 2008, from attorney Aileen Josephs to attorney Lanna Belohlavek concerning the Jeffrey Epstein case (2005CF009454A). Josephs expresses concern that hearing dates are being changed 'orally' and without public record, despite the case being an 'active investigation,' which undermines transparency. She references a pending Freedom of Information request from 2006 and formally requests to be notified of all future hearing dates related to the case.
This document is a State Attorney Subpoena issued on September 28, 2005, by the Fifteenth Judicial Circuit in Palm Beach County, Florida. It commands Cingular Cellular Service, specifically its Custodian of Records, to provide subscriber information and call details for telephone number 561-308-0282, covering the period from February 2005 to the present, for a criminal investigation (PBPD Case #05-368). The subpoena was received and executed on the same date.
This is a Palm Beach Police Department incident report for case number 1-05-001263, detailing a drug law violation that occurred on September 11, 2005, at 200 Bahama Ln, Palm Beach, FL. The case was cleared by arrest, and several items were confiscated as evidence, including a marijuana cigarette, two glass pipes with residue, and a plastic bag with marijuana. The report was filed by Officer Nicholas Caristo and supervised by Kurt Burfield.
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).
This document is a 'Notice of Filing' submitted to the Circuit Court of Palm Beach County on May 17, 2011, in the case of Jeffrey Epstein vs. Scott Rothstein, Bradley Edwards, and L.M. Attorney Jack Scarola, representing Bradley Edwards, filed a transcript of a telephone interview with Virginia Roberts to support a motion for punitive damages against Epstein. The document includes a certificate of service indicating it was mailed to opposing counsel.
This document is a legal appeal letter dated July 3, 2008, from Trump Properties LLC to the Town Clerk of Palm Beach regarding a property at 515 North County Road. The letter contests a decision by the Architectural Review Commission (ARCOM) requiring tree plantings, arguing that a prior 1990 agreement only required the maintenance of a hedge, which had been damaged by hurricanes and salt spray. The document details the history of the dispute, including meetings with ARCOM and the Code Enforcement Board in May and June of 2008.
This is a 'Notice of Filing' from May 17, 2011, in a civil case where Jeffrey Epstein is suing Scott Rothstein, Bradley Edwards, and L.M. Attorney Jack Scarola, representing Bradley Edwards, is filing a transcript of a telephone interview with Virginia Roberts. This evidence is intended to support a motion to amend the counter-claim to assert punitive damages.
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