Stuart S. Mermelstein
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Lanna Leigh Belohlavek
|
Legal representative |
7
|
3 | |
|
person
Lanna Leigh Belohlavek
|
Professional |
6
|
2 | |
|
person
JACK A. GOLDBERGER
|
Professional |
6
|
2 | |
|
person
JACK A. GOLDBERGER
|
Legal representative |
6
|
2 | |
|
person
Witness Y. Doe
|
Client |
6
|
2 | |
|
person
Jeffrey Epstein
|
Adversarial |
5
|
1 | |
|
person
SANDRA McSORLEY
|
Professional |
5
|
1 | |
|
person
Jeffrey M. Herman
|
Professional |
5
|
1 | |
|
person
Unnamed witness
|
Client |
5
|
1 | |
|
person
Jeffrey Epstein
|
Legal representative |
5
|
1 | |
|
person
SANDRA McSORLEY
|
Legal representative |
5
|
1 | |
|
person
Jane Doe No. 5
|
Client |
5
|
1 | |
|
person
Jeffrey Epstein
|
Professional |
5
|
1 | |
|
person
Jane Doe No. 8
|
Client |
2
|
2 | |
|
person
Jane Doe No. 4
|
Counsel for jane doe no 4 |
1
|
1 | |
|
person
Plaintiffs
|
Client |
1
|
1 | |
|
person
Adam D. Horowitz
|
Business associate |
1
|
1 | |
|
person
Plaintiffs
|
Counsel for |
1
|
1 | |
|
person
Adam D. Horowitz
|
Professional |
1
|
1 | |
|
person
Jane Does 2-8
|
Client |
1
|
1 | |
|
person
Plaintiffs
|
Counsel for plaintiffs |
1
|
1 | |
|
person
JANE DOE NO. 2
|
Legal representative |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | Legal case | Ongoing legal case State of Florida v. Jeffrey Epstein, Case No. 2006CF009454AXX. | Florida | View |
| N/A | Legal proceeding | A proposed single deposition of Jane Doe No. 5 to be used for both criminal and civil matters in ... | N/A | View |
| N/A | Legal hearing | A request for a fifteen (15) minute or less special set hearing to be scheduled on an enclosed Mo... | Palm Beach County Courthouse | View |
| 2010-05-28 | N/A | Plaintiffs filed Memorandum in Response to Defendant's Rule 4 Appeal. | United States District Cour... | View |
| 2010-05-28 | N/A | Filing of Plaintiffs' Memorandum in Response to Defendant's Rule 4 Appeal regarding the productio... | United States District Cour... | View |
| 2009-07-30 | N/A | Date of filing for this Unopposed Motion for Enlargement of Time. | Southern District of Florida | View |
| 2008-04-21 | Fax transmission | Stuart S. Mermelstein sent a 2-page fax with attached correspondence regarding the case of State ... | From Miami, Florida | 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 | Attorney Stuart S. Mermelstein sent a fax transmitting a 'Notice of Withdrawal of Motion for Prot... | N/A | 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 |
| 2008-03-31 | N/A | Request for Special Set Hearing submitted | West Palm Beach, Florida | View |
| 2008-03-28 | N/A | Transmission of correspondence regarding State of Florida v. Jeffrey Epstein | Miami to 15th Judicial Circ... | View |
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.
073.pdf
This document is a legal response filed on November 28, 2009, by Plaintiff Carolyn M. Andriano (Jane Doe No. 2) in her civil case against Jeffrey Epstein. The filing opposes a motion by third-party witness Igor Zinoview—Epstein's driver, bodyguard, and trainer since November 2005—who sought to avoid being deposed by claiming he had no knowledge of relevant facts. The Plaintiff argues that Zinoview must be deposed because he worked for Epstein during the active Palm Beach Police investigation (2005-2006) and likely possesses knowledge regarding activities at the Epstein residence, especially since Epstein himself invoked the Fifth Amendment.
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.
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.
Plaintiffs Jane Does 2-8' Memorandum in Response to Defen...
Filing of legal memorandum and service to opposing counsel.
Plaintiffs' Memorandum in Response to Defendant's Rule 4 ...
No preview available
State of Florida v. Jeffrey E. Epstein, Case No.: 2006CF0...
Stuart S. Mermelstein informs Jack A. Goldberger that his firm represents 'Jane Doe No. 5' in matters related to Jeffrey Epstein. He requests all future correspondence be directed to his office and proposes conducting a single deposition for both criminal and civil matters, pending agreement and approval from the State Attorney's Office.
State of Florida v. Jeffrey Epstein Case No.: 502006CF009...
Requesting a 15-minute special set hearing regarding a Motion for Protective Order for a witness.
State of Florida v. Jeffrey Epstein, Case No.: 502006CF00...
A letter from attorney Stuart S. Mermelstein, representing a witness, to Judge McSorley requesting a 15-minute hearing for a Motion for Protective Order in the case against Jeffrey Epstein.
State of Florida v. Jeffrey Epstein, Case No. 2006CF00945...
Stuart S. Mermelstein writes to Lanna Leigh Belohlavek of the State Attorney's Office to coordinate depositions for his clients in the Epstein case. He argues for a single deposition for each client to be used in both the criminal and civil cases to protect the victim's well-being and notes a deposition is scheduled for April 2, 2008.
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