MIAMI, FL
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Jeffrey Epstein Part 02 of 08.pdf
This document collection details the FBI's investigation into Jeffrey Epstein for child prostitution between late 2006 and early 2007. It includes internal FBI communications requesting travel to interview witnesses in New York, New Jersey, New Mexico, and the US Virgin Islands, as well as indications of coordination with the Palm Beach Police Department. The file also contains financial request forms for investigative expenses and notes the creation of link analysis charts (i2 Analyst Notebook) to track the case data.
Phone_Messages_(Redacted).pdf
This document contains scanned telephone message books from the Palm Beach State Attorney's Office (likely Barry Krischer's office) spanning from 2005 to 2009. The messages document high-frequency communication between the State Attorney ('BK' or 'Mr. K') and Epstein's defense team (Alan Dershowitz, Jack Goldberger, Bruce Lyons), as well as significant media inquiries regarding Epstein's indictment, prison sentence, and potential charges in the Virgin Islands. A critical handwritten note advises 'No don't give to Feds our case unless they take all,' highlighting the jurisdictional tension between state and federal prosecutors.
Epstein_Part_02.pdf
This document contains a collection of FBI internal memos, electronic communications, and administrative forms related to the investigation of Jeffrey Epstein under Case ID 31E-MM-108062, covering late 2006 to early 2007. The files detail requests for travel concurrence to interview witnesses in various locations, the assignment of agents, the creation of analyst charts, and financial requests for expenses and search fees. A significant portion of the document consists of Deleted Page Information Sheets listing hundreds of pages withheld under FOIA exemptions.
20250728111721067_24-1073ReplyInSupportOfPetitionForWritO...
This document is a legal reply brief filed in the Supreme Court on behalf of Ghislaine Maxwell (Petitioner) against the United States, dated July 28, 2025. The brief argues that the Non-Prosecution Agreement (NPA) signed by Jeffrey Epstein in the Southern District of Florida, which promised not to prosecute 'potential co-conspirators' in 'the United States,' should legally bind other districts like the Southern District of New York. The filing highlights a circuit split on whether US Attorneys can bind other districts and contends that the Second Circuit's decision allowing Maxwell's prosecution violates contract law and the plain text of the agreement.
20250714161447132_Certificate%20-%2024-1073%20-%20Maxwell...
This document is a Certificate of Service filed in the Supreme Court case No. 24-1073, Ghislaine Maxwell v. United States of America, dated July 14, 2025. It certifies that the Solicitor General, D. John Sauer, served the 'Brief for the United States in Opposition' to Maxwell's attorneys, Sara Kropf and David Oscar Markus. The document also includes administrative instructions regarding mail delays at the DOJ and contact information for case management.
20250606115543471_Extension%20Letter%2024-1073%202nd.pdf
This document is a formal request dated June 6, 2025, from Solicitor General D. John Sauer to the Supreme Court Clerk regarding the case Ghislaine Maxwell v. United States (No. 24-1073). The government requests a 30-day extension (until July 14, 2025) to file their response to Maxwell's petition for a writ of certiorari, citing heavy attorney workload. The document notes that Maxwell's counsel (identified in the attached service list as Sara Kropf and David Oscar Markus) does not oppose the extension.
20250509132036202_24-1073%20Affidavit.pdf
This document is an Affidavit of Service filed in the Supreme Court case (No. 24-1073) of Ghislaine Maxwell v. United States. Rina Danielson certifies that on May 9, 2025, she served the 'Brief of Amicus Curiae National Association of Criminal Defense Lawyers in Support of Petitioner' to attorneys for both Maxwell (David Oscar Markus) and the United States (Solicitor General D. John Sauer). The service was performed via Priority Mail and email, with physical copies also sent to the Court via Federal Express.
20250507134103306_Extension%20Letter%2024-1073.pdf
This document is a letter dated May 7, 2025, from U.S. Solicitor General D. John Sauer to the Clerk of the Supreme Court regarding the case Ghislaine Maxwell v. United States of America (No. 24-1073). The Solicitor General requests a 30-day extension, until June 13, 2025, to file the government's response to Maxwell's petition for a writ of certiorari, citing a heavy workload. Attached is a service list identifying Sara Kropf and David Oscar Markus as counsel for the petitioner.
2022.08.02%20Memorandum%20Of%20Law.pdf
This document is a Supplemental Brief filed on August 1, 2022, by the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in the Superior Court of the Virgin Islands. The brief supports a Motion to Dismiss Ghislaine Maxwell's complaint seeking indemnification from the Estate. The Co-Executors argue that because Maxwell was convicted of intentional criminal acts (sex trafficking and conspiracy) in the Southern District of New York on June 29, 2022, public policy prohibits enforcing any contract or equitable doctrine that would indemnify her for the financial consequences of her crimes.
2022.08.01%20Brief.pdf
This document is a legal brief filed by Ghislaine Maxwell in the Superior Court of the Virgin Islands against the Estate of Jeffrey Epstein. Maxwell argues that Virgin Islands public policy does not prevent her from seeking indemnification (reimbursement) for legal fees and security costs incurred due to her employment with Epstein, despite her criminal conviction in New York (SDNY). She asserts claims based on contract promises, common law joint tortfeasor indemnity, and corporate indemnity laws regarding her role at NES, LLC.
2021.04.13%20Reply%20Motion.pdf
This document is a 'Plaintiff's Reply to Co-Executors' Brief' filed on April 13, 2021, in the Superior Court of the Virgin Islands by Ghislaine Maxwell's legal team. Maxwell argues that her indemnification case against the Estate of Jeffrey Epstein should not be transferred to the Complex Litigation Division nor assigned to the same judge handling the 'CICO action' (Government v. Indyke). She asserts that her case does not meet the criteria for complex litigation and shares no common facts or claims with the government's racketeering case against the executors.
2021.03.29%20Response%20to%20Order.pdf
This document is a legal brief filed on March 29, 2021, by the Co-Executors of the Estate of Jeffrey Epstein (Darren K. Indyke and Richard D. Kahn) in the Superior Court of the Virgin Islands. The brief argues against designating Ghislaine Maxwell's lawsuit for legal fee indemnification as 'complex' litigation and opposes consolidating it with a separate government 'CICO action' (Case No. ST-2020-CV-00014). The Executors contend that Maxwell's case is a simple single-issue dispute, whereas the CICO action involves complex allegations of a multi-decade criminal enterprise.
2020.07.30%20Stipulation%20For%20Extension%20of%20Time.pdf
This document is a legal stipulation filed on July 30, 2020, in the Superior Court of the Virgin Islands (Case ST-20-CV-155). It represents an agreement between Ghislaine Maxwell (Plaintiff) and the Government of the U.S. Virgin Islands (Proposed Intervenor) to extend the deadline for Maxwell to respond to the Government's Motion to Intervene until August 17, 2020. The document lists the Estate of Jeffrey Epstein and his executors, Darren K. Indyke and Richard D. Kahn, as defendants.
2020.03.12%20Civil%20Complaint.pdf
This document is a civil complaint filed on March 12, 2020, by Ghislaine Maxwell against the Estate of Jeffrey Epstein and its executors, Darren Indyke and Richard Kahn, as well as NES, LLC. Maxwell seeks indemnification for legal fees, security costs, and safe accommodation expenses she has incurred due to her prior employment with Epstein. The complaint alleges that Epstein repeatedly promised, both verbally and in writing (specifically in a 2004 letter), to support Maxwell financially and indemnify her, a practice he reportedly maintained during previous lawsuits in 2009 and 2017.
016.pdf
This document is a Motion for a Protective Order filed by plaintiff M.J. on November 11, 2010, requesting the court bar Jeffrey Epstein from direct or indirect contact. The motion details a pattern of Epstein using private investigators to harass and intimidate victims and witnesses, specifically citing an incident on July 1, 2010, where a PI named Thaddeus Knowles followed 'Jane Doe' and flashed lights into her home. It also references Epstein's intimidation of other witnesses including Sarah Kellen, Leslie Groff, and Alfredo Rodriguez, and his history of violating no-contact orders.
016-02.pdf
This document is a Motion for No-Contact Order filed by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein in the Southern District of Florida on May 22, 2009. The plaintiffs argue that despite a state plea agreement prohibiting contact, Epstein's counsel refused to confirm he would not contact federal victims. The filing includes exhibits of correspondence between attorneys and a transcript of the 2008 plea conference where Judge Pucillo explicitly defined 'indirect contact' to include Facebook and MySpace.
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.
MOTION-EXT%20OF%20TIME%20(JURIS%20BRIEF).pdf
This is a legal motion filed on December 14, 2015, in the Supreme Court of Florida (Case No. SC15-2286) by Jeffrey Epstein's attorney, Paul Morris. Epstein requests an extension of time until January 19, 2016, to file his initial brief on jurisdiction. The document notes that the Respondent's counsel, Philip M. Burlington, has no objection to the request, and includes a service list of attorneys involved in the related proceedings.
LETTER.pdf
This document is a legal filing dated December 10, 2015, in which Jeffrey Epstein's attorney, Paul Morris, files a 'Notice to Invoke Discretionary Jurisdiction' with the Supreme Court of Florida. Epstein is appealing a decision made on November 12, 2015, by the District Court of Appeal (Fourth District) in the case of 'Bradley J. Edwards v. Jeffrey Epstein'. The attached opinion reveals that the lower court reversed a summary judgment that had favored Epstein, ruling that 'litigation privilege' does not bar Edwards' claim of malicious prosecution against Epstein.
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.
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.
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