Doe II
PersonRelationship Network
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.
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.
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.
044.pdf
This document is a Motion to Compel filed on July 10, 2009, in the Southern District of Florida, requesting the court to force Jeffrey Epstein to answer 23 specific requests for admission in a civil suit brought by Jane Doe No. 2. Epstein had previously asserted his Fifth Amendment privilege against self-incrimination to refuse answering questions regarding his net worth (alleged to be over $1 billion), his financial support of modeling agency MC2, his ownership of foreign property, and specific allegations of sexual assault, battery, and sex trafficking of minors. The plaintiff argues that the Fifth Amendment cannot be used as a blanket refusal in a civil case and demands Epstein answer or provide specific justification for his silence.
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.
006.pdf
This document is a Court Order from the United States District Court Southern District of Florida, dated April 28, 2009, presided over by Judge Kenneth A. Marra. The order grants the Plaintiffs' motion for a protective order against piecemeal depositions, limiting Jeffrey Epstein (Defendant) to a single deposition of each plaintiff across ten related civil cases. It also consolidates four specific cases (08-80119, 08-80232, 08-80380, and 08-80993) for the purposes of discovery and orders parties in the remaining six cases to show cause why they should not also be consolidated.
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.
020.pdf
This document is a 'Notice of Limited Appearance' filed on May 29, 2009, in the United States District Court for the Southern District of Florida. It lists multiple civil cases involving Jane Doe plaintiffs against Jeffrey Epstein. The United States, represented by Assistant U.S. Attorney A. Marie Villafaña (under U.S. Attorney R. Alexander Acosta), files this notice to respond to a court order regarding Epstein's 'Motion to Stay Proceedings,' while explicitly stating the U.S. is not becoming a party to the litigation.
013.pdf
This document is a legal notice filed on May 20, 2009, in the U.S. District Court for the Southern District of Florida, involving multiple consolidated cases against Jeffrey Epstein. Plaintiff C.M.A. formally withdraws her objections to Epstein's motion to identify her by her legal name in the case style and in third-party subpoenas, rendering the motion to dismiss moot, though she continues to object to dismissal on alternative grounds. The document lists numerous 'Jane Doe' plaintiffs and provides a service list of attorneys representing both the plaintiffs (Jack Scarola, Jack P. Hill) and the defendant (Richard Willits, Robert Critton, Jack Goldberger, Bruce Reinhart).
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.
034.pdf
This document is a response filed by the United States Government (as amicus curiae) in May 2009 opposing Jeffrey Epstein's motion to stay various civil lawsuits against him. The government argues that there are no 'special circumstances' justifying a stay because Epstein is not currently under indictment, and the Non-Prosecution Agreement (NPA) was intended to facilitate restitution for victims, not to shield Epstein from civil discovery. The filing lists numerous related civil cases involving Jane Doe plaintiffs and emphasizes that staying the cases would prejudice the victims' rights to speedy proceedings and restitution.
033.pdf
This document is a 'Notice of Limited Appearance' filed by the United States government in the Southern District of Florida on May 29, 2009. The filing, signed by Assistant US Attorney A. Marie Villafaña under US Attorney R. Alexander Acosta, consolidates multiple civil cases against Jeffrey Epstein (Plaintiffs include various Jane Does and C.M.A.). The United States enters as Amicus Curiae solely to respond to a court order regarding Epstein's Motion to Stay Proceedings, explicitly stating it does not become a party to the litigation nor take a position on the outcome of the civil suits.
023.pdf
This document is a 'Notice of Filing Withdrawal of Previously Raised Objections' filed on May 20, 2009, in the US District Court for the Southern District of Florida. Plaintiff C.M.A. withdraws her objections to Jeffrey Epstein's motion to compel her to identify herself by her legal name in the case style and third-party subpoenas, though she maintains her objection to the case being dismissed sua sponte. The document lists numerous related cases involving Jane Doe plaintiffs and provides a service list of attorneys involved.
019.pdf
This document is a consolidated court order from the Southern District of Florida dated May 14, 2009, covering multiple civil lawsuits (Jane Does, C.M.A., etc.) against Jeffrey Epstein. Judge Kenneth A. Marra requests the United States government provide its official position regarding Epstein's motion to stay these civil cases. Epstein argued that defending himself in these civil suits might violate his Non-Prosecution Agreement (NPA) with the USAO and subject him to criminal prosecution.
018.pdf
This document is a court order dated May 14, 2009, from the Southern District of Florida, consolidating eleven separate civil cases against Jeffrey Epstein for the purposes of discovery and procedural motions. Judge Kenneth A. Marra designates 'Jane Doe No. 2 v. Epstein' as the lead case for filings and sets strict limits on depositions to prevent duplication, ruling that defendants and common witnesses may be deposed only once across all cases. The order aims to improve judicial economy and efficiency in handling the multiple lawsuits filed by various Jane Does and other plaintiffs.
006.pdf
This document is a court order from the United States District Court for the Southern District of Florida, signed by Judge Kenneth A. Marra on April 28, 2009. It addresses ten separate civil cases filed against Jeffrey Epstein by various plaintiffs (Jane Does and C.M.A.). The order grants the plaintiffs' motion to consolidate cases for discovery purposes and grants a protective order limiting Epstein to a single deposition per plaintiff to prevent piecemeal depositions, while also ordering parties in remaining cases to show cause why they should not also be consolidated.
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