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 |
028.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) in the case Jane Doe No. 2 vs. Jeffrey Epstein (Case No. 08-CV-80119-MARRA/JOHNSON). The memorandum opposes 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 not protected by the Fifth Amendment (citing the 'required records' exception and 'foregone conclusion' doctrine) and are critical for determining punitive damages given the allegations of sexual molestation and Epstein's refusal to provide net worth discovery beyond a stipulation of 'nine figures.'
022.pdf
This document is an unopposed motion filed on December 3, 2009, by Plaintiff Jane Doe No. 8 in the Southern District of Florida, requesting an extension of time until December 14, 2009, to file an Amended Complaint against Jeffrey Epstein. The request cites obligations of the plaintiff's counsel, Stuart Mermelstein and Adam Horowitz, in other matters, including other Epstein cases. The defendant's counsel, identified in the service list as Jack Alan Goldberger and Robert D. Critton, did not object to the extension.
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.
015.pdf
This document is a Reply Memorandum filed by Jeffrey Epstein's legal team on August 20, 2009, in the case of Jane Doe No. 8 v. Jeffrey Epstein. The defense argues that the plaintiff's claims of 'Sexual Assault and Battery' (Count I) and 'Coercion and Enticement' (Count III) should be dismissed because they are barred by the statute of limitations. Epstein's lawyers contend that because the plaintiff was aware of the injury at the time of the alleged incident in 2001 (when she was 16) and turned 18 in 2003, the time limits for filing suit (4 years and 6 years respectively) had expired by the time the complaint was filed in 2009.
011.pdf
Legal motion filed on August 11, 2009, in the Southern District of Florida, requesting to consolidate the case of Jane Doe No. 8 v. Jeffrey Epstein with the lead case Jane Doe No. 2 v. Jeffrey Epstein for discovery purposes. The document states that the case involves alleged sexual abuse in Palm Beach, Florida, in 2001. The motion was unopposed by the Defendant's counsel.
009.pdf
This document is an Unopposed Motion for Enlargement of Time filed on July 30, 2009, in the case of Jane Doe No. 8 vs. Jeffrey Epstein in the Southern District of Florida. The plaintiff's counsel, Stuart S. Mermelstein, requests an extension until August 12, 2009, to respond to Epstein's Motion to Dismiss, citing obligations in other matters including related cases against Epstein. The document confirms that Epstein's counsel does not oppose this request.
008.pdf
This document is a Motion to Dismiss filed by Jeffrey Epstein's defense team on July 14, 2009, in the case of Jane Doe No. 8 v. Jeffrey Epstein. The defense argues that the plaintiff's claims of Sexual Assault and Battery (Count I) and Coercion (Count III) are barred by the applicable 4-year (state) and 6-year (federal) statutes of limitations, as the alleged incident occurred in 2001 when the plaintiff was 16. Footnotes in the document provide graphic details of the allegations, describing how Jane Doe was recruited by another girl, brought to Epstein's Palm Beach mansion, and sexually assaulted during a massage.
006.pdf
This document is an unopposed motion filed on July 7, 2009, in the US District Court for the Southern District of Florida by Jeffrey Epstein's legal team. Epstein's attorneys requested a one-week extension (until July 14, 2009) to respond to a complaint filed by 'Jane Doe No. 8' on May 28, 2009, citing workload from other cases involving Epstein. The motion notes that opposing counsel agreed to this extension.
004.pdf
Legal document filed on June 5, 2009, in the Southern District of Florida court case 'Jane Doe No. 8 v. Jeffrey Epstein'. The document is a Notice of Appearance indicating that attorneys Robert D. Critton, Jr. and Michael J. Pike of the law firm Burman, Critton, Luttier & Coleman, LLP are entering the case to represent the defendant, Jeffrey Epstein. The service list includes contact information for other attorneys involved, including Jack Alan Goldberger (also for Epstein) and Adam D. Horowitz (for the Plaintiff).
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.
040.pdf
This document is a Motion to Compel filed on July 10, 2009, in the US District Court for the Southern District of Florida by Plaintiff Jane Doe (represented by Bradley Edwards). The motion requests the court to force Jeffrey Epstein to answer a set of interrogatories regarding his financial assets, net worth, foreign travel, property ownership, and alleged interactions with the plaintiff and other minor females. Epstein refused to answer nearly all questions (except for providing the name/address of the person answering), invoking his Fifth and Sixth Amendment rights against self-incrimination and right to counsel.
039.pdf
This legal filing is a Motion to Compel submitted by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the United States District Court for the Southern District of Florida. The motion requests the court to order Epstein to answer 23 specific requests for admission regarding his net worth, asset transfers, and allegations of sexual abuse and trafficking of minors, which he had previously refused to answer by asserting Fifth Amendment privileges. The plaintiff argues that Epstein's blanket assertion of the privilege is improper and that he must provide a particularized justification for each refusal or face an adverse inference.
030.pdf
This document is a 'Notice of Joinder' filed on June 8, 2009, in the US District Court for the Southern District of Florida, where Plaintiffs Jane Does 2-7 join a motion for a no-contact order against Jeffrey Epstein. The filing alleges that Epstein's associate and recruiter, Hayley Robson, has been harassing victims Jane Does 4 and 7 through text messages and in-person threats while claiming to be financially supported by and cooperating with Epstein. The plaintiffs request a court order prohibiting Epstein from any direct or indirect contact with the victims.
086.pdf
This document is a response filed by Plaintiff Carolyn M. Andriano on November 28, 2009, opposing a motion by third-party witness Igor Zinoview to prevent his deposition. Zinoview, who worked as Epstein's driver, bodyguard, and trainer starting in November 2005, claims he has no relevant knowledge of legal matters involving Epstein. The Plaintiff argues that because Zinoview worked for Epstein during the active police investigation (2005-2006), he likely possesses relevant information regarding activities at the Epstein residence, and that a complete bar on his deposition is legally unjustified.
082.pdf
This document is a Reply filed by Jeffrey Epstein's legal team in November 2009 requesting a permanent order for the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), which was undergoing restructuring. The filing highlights that the Department of Justice had seized approximately 40 boxes of documents from RRA, including about 13 boxes related to Epstein cases, amidst concerns of 'serious ethical and potentially criminal issues' at the firm. The document also argues against delaying the deposition of RRA's Chief Restructuring Officer, Herbert Stettin, citing upcoming trial deadlines.
064.pdf
This document is a 'Notice of Compliance' filed on July 28, 2009, by Jeffrey Epstein's legal team in the U.S. District Court for the Southern District of Florida. It pertains to multiple civil cases filed by 'Jane Doe' plaintiffs against Epstein. The filing states that while the court ordered the parties to agree on a preservation of evidence order, they were unable to reach a full agreement, leading Epstein to submit his own proposed order. The document includes a comprehensive service list detailing the attorneys representing the various plaintiffs and defendants, including Sarah Kellen.
061.pdf
This document is a Motion to Compel filed on July 10, 2009, in the Southern District of Florida by Plaintiff Jane Doe against Defendant Jeffrey Epstein. The motion seeks to force Epstein to answer 23 specific Requests for Admission regarding his net worth (specifically if it exceeds $1 billion), his financial support of modeling agency MC2, his ownership of Caribbean property, and specific allegations of sexual battery, assault, and sex trafficking of minors. Epstein had previously refused to answer these questions by invoking his Fifth Amendment privilege against self-incrimination.
060.pdf
This is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the Southern District of Florida. The motion seeks a court order requiring Epstein to answer 16 specific requests for production of documents (including telephone records, photos, tax returns, and passport copies) or to provide a privilege log, as Epstein has refused to produce documents by asserting a blanket Fifth Amendment privilege against self-incrimination. The plaintiff argues that Epstein's boilerplate objections are invalid, violate local rules requiring a privilege log, and that he must provide a particularized justification for his Fifth Amendment invocation for each request.
045.pdf
This document is a 'Notice of Joinder' filed on June 8, 2009, in the US District Court for the Southern District of Florida, where Plaintiffs Jane Does 2-7 join a motion for a 'No-Contact Order' against Jeffrey Epstein. The filing alleges that Epstein's associate, Hayley Robson (who originally recruited the victims), has been harassing Jane Does 4 and 7 via text messages and in-person threats while claiming to be financially supported by Epstein. The plaintiffs argue that a court order is necessary to prevent Epstein from contacting or harassing victims through third parties like Robson.
012.pdf
This document is an Emergency Motion filed on June 14, 2010, by Jeffrey Epstein's legal team to quash a subpoena and prevent the deposition of Maritza Milagros Vasquez, scheduled for the following day. Epstein's lawyers argue that the subpoena issued by C.L.'s counsel (Spencer Kuvin) is premature under Rule 26(d) and that the cross-notice by Jane Doe's counsel (Brad Edwards) is invalid because discovery in the Jane Doe case had already concluded on May 31, 2010. The document includes the motion, a subpoena exhibit, and a cross-notice exhibit.
DOJ-OGR-00030305.tif
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.
DOJ-OGR-00030279.tif
This document is a page from a court filing, Case 9:08-cv-80119-KAM, dated September 17, 2009, listing multiple attorneys and their respective law firms, contact information, and the specific related cases they represent plaintiffs in. It details legal counsel for various plaintiffs, including 'Jane Doe' and 'C.M.A.', across several related case numbers, providing contact details for each attorney and their firm.
DOJ-OGR-00030272.tif
This document is an excerpt from a declaration dated September 17, 2009, signed by Adam D. Horowitz. It describes an incident where Jeffrey Epstein intimidated Jane Doe No. 4 by staring at her, causing her to become terrified, cry uncontrollably, and flee the building, thereby preventing her deposition. The declarant affirms the truthfulness of these statements under penalty of perjury.
DOJ-OGR-00030392.jpg
This legal document, dated March 31, 2008, is a motion for a protective order filed by the law firm Herman & Mermelstein, P.A. on behalf of 'Witness Y. Doe'. The motion requests that the court order the witness's deposition for an unspecified criminal case and the civil case 'Jane Doe No. 3 v. Jeffrey Epstein' to be conducted simultaneously. The stated purpose is to prevent potential harassment of the witness by the defendant, Jeffrey Epstein.
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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