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028.pdf
A legal stipulation filed on April 9, 2020, in the Southern District of New York, wherein Plaintiff Maria Farmer and the Executors of Jeffrey Epstein's estate (Indyke and Kahn) agreed to stay the lawsuit. The stay was requested to allow Farmer to participate in the 'Epstein Victims’ Compensation Program,' a non-adversarial alternative for resolving sexual abuse claims against the estate.
007.pdf
A court order from the Southern District of New York dated November 25, 2019, in the case of Maria Farmer v. Darren K. Indyke and Richard D. Kahn (Executors of the Estate of Jeffrey Edward Epstein). The order grants attorney Sigrid S. McCawley of Boies Schiller Flexner LLP admission to practice Pro Hac Vice to represent the plaintiff, Maria Farmer.
006.pdf
This document is a Motion for Admission Pro Hac Vice filed on November 21, 2019, in the U.S. District Court for the Southern District of New York. Attorney Sigrid S. McCawley of Boies Schiller Flexner LLP requests permission to represent the plaintiff, Maria Farmer, in her case against the executors of Jeffrey Epstein's estate, Darren K. Indyke and Richard D. Kahn.
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.
014.pdf
This document is a Court Order and Joint Stipulation filed on January 28, 2020, in the Southern District of New York regarding the case of Anastasia Doe v. The Estate of Jeffrey Epstein. The order, signed by Judge Alison J. Nathan, establishes strict protocols to maintain the plaintiff's anonymity, including requirements for sealing documents and executing non-disclosure agreements for any parties privy to her identity. It also documents the agreement between the Plaintiff's counsel (Bradley J. Edwards) and the Defendants (Executors Indyke and Kahn) to adhere to these anonymity protections.
003.pdf
This document is a Motion for Admission Pro Hac Vice filed on December 27, 2019, in the Southern District of New York. Attorney Bradley J. Edwards seeks permission to represent Plaintiff Anastasia Doe in her lawsuit against Darren K. Indyke and Richard D. Kahan, the co-executors of the Estate of Jeffrey E. Epstein. Edwards attests to his good standing with the Florida and New York bars and lack of disciplinary history.
002.pdf
This document is a Civil Cover Sheet (Form JS 44) filed on December 27, 2019, in the Southern District of New York. The plaintiff, using the pseudonym Anastasia Doe, is suing Darren K. Indyke and Richard D. Kahn in their capacities as Co-Executors of the Estate of Jeffrey E. Epstein. The nature of the suit is listed as 'Other Personal Injury' and jurisdiction is based on diversity.
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.
017.pdf
Legal filing from November 2009 in the case of Jane Doe No. 2 v. Jeffrey Epstein. Epstein's attorneys reply to a response regarding the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), which was undergoing restructuring. The document notes that the Department of Justice had seized approximately 40 boxes of documents from RRA, including 13 boxes related to the Epstein case, and alludes to serious ethical and criminal issues involving the RRA firm that could impact the validity of the cases against Epstein.
020.pdf
This document is an agreed motion filed on May 13, 2010, in the Southern District of Florida by Plaintiff Jane Doe No. 103 against Defendant Jeffrey Epstein. The plaintiff requests a one-week extension to file a response to Epstein's motion to dismiss because the parties are in the process of resolving the matter via settlement, which would render the motion moot. The document includes a comprehensive service list detailing legal counsel for Epstein, Co-Defendant Sarah Kellen (represented by Bruce Reinhart), and plaintiffs in several related cases.
016.pdf
This document is an agreed motion for an extension of time filed on April 22, 2010, in the case of Jane Doe No. 103 vs. Jeffrey Epstein (Case No. 10-80309-WJZ). Plaintiff's counsel, Katherine W. Ezell, requests an extension until May 13, 2010, to file a response to Epstein's motion to dismiss because she is leaving for a vacation in Italy the following day. The motion notes that Epstein's counsel, Robert Critton, agrees to the extension, and the document includes a service list of attorneys involved in this and related cases.
012.pdf
This document is a Motion to Transfer filed on April 1, 2010, by Plaintiff Jane Doe No. 103 in the US District Court, Southern District of Florida. The plaintiff seeks to transfer her case against Jeffrey Epstein to Judge Marra's division to consolidate it with other similar pending cases, specifically 'Jane Doe No. 2 vs. Jeffrey Epstein'. The document includes a service list detailing legal counsel for Epstein, co-defendant Sarah Kellen (represented by Bruce Reinhart), and plaintiffs in several related cases.
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.
055.pdf
This document is a Motion for Protective Order filed on November 9, 2009, by Igor Zinoviev, a third-party witness and Jeffrey Epstein's driver/bodyguard since November 2005. Zinoviev seeks to prevent or limit his deposition, arguing he has no knowledge relevant to the civil cases as his employment with Epstein began after the alleged events, and he has not discussed Epstein's criminal or civil cases with him. The motion cites legal precedents on the scope of discovery and includes a list of attorneys involved in various related cases.
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.
080.pdf
This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, requesting a protective order to prevent his deposition in the case Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, who worked as a driver and bodyguard for Epstein since November 2005, argues he has no relevant information for the civil cases as his employment began after the alleged events and he never discussed the criminal or civil cases with Epstein.
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.
014-01.pdf
This document is a 'Motion to Proceed Anonymously' filed on April 17, 2009, in the Southern District of Florida by Jane Doe No. 101 against Jeffrey Epstein. The plaintiff, represented by Podhurst Orseck, P.A., requests to use a pseudonym because she was sexually abused by Epstein as a minor and wishes to avoid further psychological trauma and public humiliation. The motion notes that Epstein already knows her identity from the related criminal investigation and cites precedents where other victims (Jane Does 1-7, etc.) were granted anonymity.
061.pdf
This is a Joint Stipulation and Proposed Order filed in the US District Court (SDNY) on June 12, 2020, in the case of Jane Doe 1000 v. The Estate of Jeffrey Epstein. The parties agreed to stay (pause) the lawsuit for 60 days to allow the Plaintiff to participate in the Epstein Victims' Compensation Program, a non-adversarial alternative for resolving sexual abuse claims. If the claim is resolved through the program, the Plaintiff agrees to discontinue the legal action with prejudice.
010.pdf
This document is a legal filing dated November 21, 2019, containing a Motion for Admission Pro Hac Vice for attorney Sigrid S. McCawley of Boies Schiller Flexner LLP to represent Plaintiff Jane Doe 1000 in the case against the Estate of Jeffrey Epstein. The document includes McCawley's declaration of good standing, a supporting Certificate of Good Standing from the Supreme Court of Florida, and a proposed order for the judge to sign granting the admission. The defendants listed are Darren K. Indyke and Richard D. Kahn in their capacities as executors of Epstein's estate.
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.
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