Palm Beach Gardens, Florida
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Epstein_Part_12_(Redacted).pdf
This document is an excerpt from a federal indictment (Case No. 00-8124CR - HURLEY) from the Southern District of Florida, detailing charges of mail fraud and bank fraud against an individual named HURLEY. The defendant, a mortgage broker at Mortgage Express, Inc., is accused of submitting false and fraudulent information, including fictitious leases and false verifications of employment/deposit, to financial institutions like Bank of America, Republic Consumer Lending Group, and Ohio Savings Bank to obtain mortgage financing for himself and customers.
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.
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.
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.
DOJ-OGR-00031550.jpg
This is a legal document filed by attorney Jack A. Goldberger regarding a Motion for Protective Order concerning 'Jane Doe No. 1'. The filing states that the motion is moot because the attorneys (Goldberger and Leopold) agreed to schedule Jane Doe No. 1's deposition for February 20, 2008, with Leopold accepting service on her behalf. The document is dated February 7, 2008, and includes a certificate of service to attorneys Belohlavek, Leopold, and Herman.
DOJ-OGR-00031544.jpg
This document is a legal certification and request signed by attorney Jack A. Goldberger on February 7, 2008. It requests the court deny a Motion for Protective Order as moot because the parties (Goldberger and Theodore Leopold) agreed to reschedule Jane Doe No. 1's deposition to February 20, 2008. The document certifies service to attorneys Lanna Belohlavek, Theodore Leopold, and Jeffrey Herman.
DOJ-OGR-00031538.jpg
This is a letter dated February 21, 2008, from attorney Theodore J. Leopold to attorney Jack A. Goldberger regarding the case of 'Jane Doe v. Epstein'. Leopold expresses serious ethical concerns about Goldberger's co-counsel, who refused to share copies of exhibits after a direct examination the previous day. Leopold writes to confirm a prior agreement that Goldberger will provide copies of all exhibits to him and the State Attorney, highlighting a potential conflict or lack of cooperation among the legal team.
DOJ-OGR-00031537.jpg
This is a letter dated February 21, 2008, from attorney Theodore J. Leopold to attorney Jack A. Goldberger regarding the case of 'Jane Doe v. Epstein'. Leopold expresses serious ethical concerns about Goldberger's co-counsel, who refused to provide copies of exhibits to Leopold and the State Attorney during a direct examination the previous day. Leopold writes to confirm an agreement that Goldberger will now provide copies of all exhibits used.
DOJ-OGR-00032338.jpg
This Palm Beach Police Department incident report, dated February 17, 2006, details a search of Jeffrey Epstein's residence and vehicles conducted on November 17, 2005. Officers seized photographs, DVDs, and VCR tapes from the home. A key finding was a Thrifty car rental agreement in the name of Johanna Sjoberg inside Epstein's Chevy Suburban, suggesting a connection between the two.
HOUSE_OVERSIGHT_010528.jpg
The document contains an excerpt from a book (Chapter 49) titled 'Jeffrey Epstein: September 2007' alongside a partial 2006 letter from Palm Beach Police Chief Michael Reiter regarding the Epstein investigation. The book text contrasts the harsh 2013 sentencing of school principal Scott Blake for soliciting a minor with the 'extraordinary' plea deal Jeffrey Epstein received in 2007 for similar offenses. It highlights Epstein's high-powered defense team and political connections.
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