Adam D. Horowitz
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Jeffrey M. Herman
|
Professional |
5
|
1 | |
|
person
Witness Y. Doe
|
Client |
5
|
1 | |
|
person
Jane Doe No. 8
|
Client |
2
|
2 | |
|
person
Plaintiffs
|
Counsel for |
1
|
1 | |
|
person
Jane Does 2-7
|
Legal representative |
1
|
1 | |
|
person
Jane Does 2-7
|
Client |
1
|
1 | |
|
person
Stuart S. Mermelstein
|
Professional |
1
|
1 | |
|
person
Jane Doe 4
|
Client |
1
|
1 | |
|
person
Jane Doe No. 4
|
Client |
1
|
1 | |
|
person
Stuart S. Mermelstein
|
Business associate |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2009-09-17 | N/A | Deposition scheduled but canceled due to an incident involving Jeffrey Epstein and the plaintiff. | Florida Science Foundation ... | View |
| 2009-09-16 | N/A | Scheduled deposition of Jane Doe No. 4. Jeffrey Epstein was stipulated not to attend in person bu... | 350 Australian Ave. South, ... | View |
| 2009-08-11 | N/A | Filing of Plaintiff Jane Doe No. 8's Unopposed Motion to Consolidate for Discovery Purposes. | Southern District of Florida | View |
| 2009-07-29 | N/A | Filing of Plaintiffs Jane Does' 2-7 Motion for Protective Order | United States District Cour... | View |
| 2009-06-08 | N/A | Filing of Notice of Joinder in Motion for No-Contact Order. | US District Court Southern ... | View |
| 2009-05-27 | N/A | Filing of Notice of Filing Proposed Order and Certificate of Service. | United States District Cour... | View |
| 2008-04-02 | N/A | Withdrawal of Motion for Protective Order filed by Witness Y. Doe. | Circuit Court of the 15th J... | View |
| 2008-03-31 | Legal filing | Attorneys for Witness Y. Doe filed a request for a protective order to require that the witness's... | United States District Cour... | View |
Jeffrey Epstein Part 22 of 22.pdf
This document contains court filings from September 2009 regarding a dispute over the deposition of 'Jane Doe No. 4' in the civil case Jane Doe No. 2 v. Jeffrey Epstein. The plaintiff's attorney, Adam Horowitz, cancelled the deposition after an alleged intimidation incident where Epstein and his driver, Igor Zinoviev, crossed paths with the plaintiff in the building lobby. Epstein's legal team (Critton and Luttier) filed for sanctions, arguing the encounter was coincidental as Epstein was leaving his office (Florida Science Foundation, same building) to avoid the deposition. The document includes affidavits from Epstein and Zinoviev denying interaction, invoices for the cancelled deposition costs, and a 2008 plea conference transcript defining 'no contact' orders.
Epstein_Part_22.pdf
This document contains a partial transcript from a plea conference for Jeffrey Epstein in Palm Beach County, Florida, on June 30, 2008, where the court detailed strict no-contact orders with victims. It also includes a declaration from Adam D. Horowitz dated September 16, 2009, describing a stipulation for Jeffrey Epstein not to physically attend Jane Doe No. 4's deposition, but to listen remotely, and an incident where Epstein crossed paths with Jane Doe No. 4 in a lobby.
017-13.pdf
This document is a protective response filed by Plaintiff Jane Doe on May 27, 2010, in the Southern District of Florida case against Jeffrey Epstein. The plaintiff requests the court to promptly order the production of tax returns and other documents that Epstein has withheld on Fifth Amendment grounds, emphasizing that the trial date is set for July 19, 2010. The filing notes that negotiations with Epstein's counsel failed and lists numerous related cases and attorneys involved.
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.
017-01.pdf
This document is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Jane Doe in the United States District Court for the Southern District of Florida against Jeffrey Epstein. The plaintiff argues that Epstein's blanket invocation of Fifth Amendment privileges to refuse producing documents (such as phone records, tax returns, and correspondence) is improper and that he should be compelled to answer or provide a privilege log. The motion details specific discovery requests and Epstein's uniform response asserting his constitutional rights against self-incrimination.
016-13.pdf
This document is a Motion for Sanctions filed by Plaintiff Jane Doe No. 3 against Jeffrey Epstein on January 4, 2010. The motion alleges that Epstein flagrantly violated multiple court orders, including a No-Contact Order, by deliberately appearing at the location of the Plaintiff's Independent Medical Examination (IME) on November 24, 2009. The Plaintiff requests sanctions, attorney's fees, and a protective order moving the remainder of her IME to a different city, citing the trauma caused by the encounter.
016-12.pdf
This document is a Motion for Sanctions filed by Plaintiff Jane Doe No. 4 against Jeffrey Epstein for violating a no-contact order and a written stipulation. On September 16, 2009, Epstein appeared in the lobby of the building where Jane Doe No. 4's deposition was scheduled, staring her down and causing her to flee in distress, despite an agreement that he would not attend. The document includes a declaration from attorney Adam Horowitz, a transcript of the cancelled deposition where defense counsel Robert Critton argues Epstein was simply leaving his office in the same building, and an email confirming the prior stipulation.
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.
015.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) opposing Jeffrey Epstein's appeal of a Magistrate Judge's order compelling him to produce income tax returns for the years 2003-2008. The Plaintiffs argue that tax returns are 'required records' not protected by the Fifth Amendment privilege against self-incrimination and are critical for determining punitive damages. The document notes that Epstein attempted to avoid producing these records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs rejected as insufficient.
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.
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.
076.pdf
This document is a legal memorandum filed by the Plaintiffs (Jane Does 2-8) in response to Jeffrey Epstein's appeal of a Magistrate Judge's order compelling him to produce his income tax returns for the years 2003-2008. The Plaintiffs argue that the tax returns are relevant for determining punitive damages and are not protected by the Fifth Amendment privilege against self-incrimination, citing the 'required records' exception. The document also notes Epstein's attempt to avoid producing records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs reject as insufficient.
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.
052.pdf
This document is a Motion for Protective Order filed on July 29, 2009, in the Southern District of Florida by Plaintiffs 'Jane Does 2-7' against Jeffrey Epstein. The plaintiffs allege that Epstein hired private investigators to harass and intimidate them by contacting their former employers, ex-boyfriends, and friends to ask intrusive personal questions and potentially 'out' them as sexual abuse victims. The motion seeks a court order to stop Epstein's investigators from making ex parte contacts with nonparties associated with the plaintiffs.
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.
045.pdf
This document is a Motion to Compel filed by Plaintiff Jane Doe against Jeffrey Epstein on July 10, 2009, in the Southern District of Florida. The plaintiff lists 23 specific interrogatories regarding Epstein's finances, properties, travel, and alleged sexual abuse of minors, all of which Epstein refused to answer by invoking his Fifth and Sixth Amendment rights. The motion argues that Epstein's blanket refusals are improper and requests the court force him to answer or provide a privilege log.
043.pdf
This document is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the United States District Court, Southern District of Florida (Case No. 08-CV-80119-MARRA/JOHNSON). The motion argues that Epstein has improperly asserted blanket Fifth Amendment privileges in response to sixteen specific requests for production of documents, including telephone records, appointment books, financial records, and correspondence. The Plaintiff requests the Court to order Epstein to answer the requests, provide a particularized justification for his Fifth Amendment invocations, and produce a privilege log.
021.pdf
This document is a Notice of Filing Proposed Order submitted to the U.S. District Court for the Southern District of Florida on May 27, 2009. It lists eleven separate civil cases filed against Jeffrey Epstein by various plaintiffs, including Jane Does 2-7, 101, 102, C.M.A., and Doe II. The filing serves to submit a proposed order related to case no. 08-80119 and includes a service list of attorneys involved in the litigation.
009.pdf
This document is a Notice of Voluntary Dismissal Without Prejudice filed on February 22, 2008, in the U.S. District Court for the Southern District of Florida (Case No. 08-80069). The plaintiffs (Jane Doe No. 1 and her parents) voluntarily dismissed their action against Jeffrey Epstein. The document includes a certificate of service indicating that notice was sent electronically to attorney Theodore Jon Leopold and by mail to Jeffrey Epstein at his New York residence.
008.pdf
This document is a Notice of Non-Opposition filed on February 14, 2008, in the case of Jane Doe No. 1 et al. v. Jeffrey Epstein in the Southern District of Florida. The plaintiffs (Jane Doe No. 1, her father, and stepmother) inform the court that they do not oppose the motion to intervene filed by Jane Doe's mother. The document lists the attorneys representing the plaintiffs from the firm Herman & Mermelstein, P.A.
007.pdf
This document is a legal memorandum filed on February 13, 2008, by the attorneys for Jane Doe No. 1 and her father in the case against Jeffrey Epstein (Case No. 08-80069). The plaintiffs oppose a motion filed by Jane Doe's mother, Dawn LaVogue Sandberg, who sought to stay the proceedings until the minor plaintiff reached the age of majority. The plaintiffs argue that the mother's motion is procedurally defective, was not properly served on the defendant (Epstein), and that the mother lacks standing because the father has full legal custody of the child. The document emphasizes that the lawsuit concerns the sexual assault of Jane Doe No. 1 by Epstein when she was 14 years old.
005.pdf
This document is a 'Motion to Intervene and Supporting Memorandum of Law' filed on January 29, 2008, in the US District Court for the Southern District of Florida (Case No. 08-80069). Jane Doe's Mother seeks to intervene as a plaintiff in the lawsuit against Jeffrey Epstein, asserting she has claims sharing common questions of law and fact with the existing action. The document notes that Jane Doe's Father (a current plaintiff) does not agree to her intervention.
004.pdf
This is a Motion to Stay Proceedings filed on January 29, 2008, in the US District Court for the Southern District of Florida. Jane Doe's Mother (Intervenor-Plaintiff) requests the court pause the lawsuit against Jeffrey Epstein until Jane Doe No. 1 turns 18 on May 13, 2008. The motion reveals that Jane Doe No. 1 is estranged from her father (who filed the suit) and that the father filed the suit without her knowledge or consent.
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.
Filing of Motion
Electronic filing via CM/ECF and service to parties on the service list.
Notice of Filing Proposed Order
Filing of a proposed order in reference to document no. 111 filed in case no. 08-80119.
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