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027.pdf
This document is a Motion for Leave to File Under Seal submitted on May 29, 2009, by attorneys for Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida. The plaintiffs request permission to file their response to Epstein's Motion to Stay under seal, or alternatively, request the court to unseal the Non-Prosecution Agreement (NPA) so they can adequately respond. The document includes a comprehensive service list detailing attorneys representing Epstein, co-defendant Sarah Kellen (represented by Bruce Reinhart), and various other Jane Doe plaintiffs.
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.
024.pdf
This document is a legal motion filed on May 29, 2009, in the Southern District of Florida by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein. The plaintiffs request leave to file their response to Epstein's motion to stay under seal because it references the confidential Non-Prosecution Agreement (NPA), or alternatively, to unseal the NPA. The document includes a comprehensive service list detailing the legal representation for Epstein (including Robert Critton and Jack Goldberger), Sarah Kellen (represented by Bruce Reinhart), and numerous other Jane Doe plaintiffs.
008.pdf
This document is a legal response filed by Plaintiff Jane Doe 101 in the United States District Court for the Southern District of Florida on May 1, 2009. The plaintiff agrees to the court's order to consolidate ten separate cases filed by various Jane Does and C.M.A. against Jeffrey Epstein for the purposes of discovery. The document includes a service list detailing the contact information for attorneys representing the various plaintiffs and the defendant.
041.pdf
A letter motion filed on March 6, 2020, by Andrew S. Buzin of Buzin Law P.C. requesting permission to withdraw as local counsel for plaintiff Jane Doe 17 in her case against Indyke and Kahn (executors of the Epstein estate). The client requested the discharge, and she remains represented by attorneys from Weisman, Brodie, Starr & Margolies, P.A. and Alan Goldfarb, P.A. The letter notes that the case is currently stayed pending the plaintiff's potential participation in the Epstein Victims' Compensation Program.
024.pdf
This document is a Notice of Motion filed on November 8, 2019, in the Southern District of New York (Case 1:19-cv-09610-PAE). The plaintiff, identified as Jane Doe 17, is suing the Estate of Jeffrey Epstein and various associated corporate entities (including Nine East 71st Street Corp and Financial Trust Company). The motion requests a court order allowing the plaintiff to proceed anonymously and lists the legal representation for the plaintiff from three different law firms.
024-01.pdf
This document is a legal motion filed on November 8, 2019, in the Southern District of New York, requesting that Plaintiff 'Jane Doe 17' be allowed to proceed anonymously in her lawsuit against the Estate of Jeffrey Epstein and associated entities. The motion argues that the sensitive nature of the sexual assault allegations, the risk of retaliation due to Epstein's wealth and connections, and the lack of public interest in her specific identity outweigh the presumption of open proceedings. Attached as Exhibit A is a September 11, 2019 Order from Judge P. Kevin Castel in a similar case (Katlyn Doe v. Indyke), which granted anonymity under nearly identical circumstances.
019.pdf
This document is an Appearance of Counsel form filed on October 28, 2019, in the United States District Court for the Southern District of New York (Case 1:19-cv-09610-PAE). Attorney David H. Brodie enters his appearance as counsel for 'All plaintiffs' (identified as Jane Doe 17 in the caption) in the lawsuit against Darren K. Indyke and Richard D. Kahn.
007.pdf
This document is a formal Summons in a Civil Action filed on October 22, 2019, in the Southern District of New York (Case 1:19-cv-09610). The plaintiff, identified as Jane Doe 17, is suing the Estate of Jeffrey E. Epstein (represented by Darren K. Indyke and Richard D. Kahn) and numerous associated corporate entities (Nine East 71st Street Corp, Laurel Inc, NES LLC, etc.). The summons instructs the defendants to respond within 21 days to avoid a default judgment and lists the plaintiff's legal representation.
DOJ-OGR-00031399.jpg
This document is a photocopy of a 'Letters to the Editor' page from The Palm Beach Post dated August 25, 2006. It features a highlighted letter by Aileen Josephs criticizing Jeffrey Epstein's legal team (specifically Jack Goldberger and Alan Dershowitz) for attacking victims' reputations and asserting that money and power buy justice in Palm Beach County. Handwritten notes indicate this clipping was processed by staff to be included in the 'Jeffrey Epstein File' with the State Attorney.
DOJ-OGR-00031397.jpg
This document is a scanned page from The Palm Beach Post dated August 25, 2006, containing Letters to the Editor. The primary letter, written by Aileen Josephs, strongly criticizes Jeffrey Epstein and his legal team (specifically naming Jack Goldberger and Alan Dershowitz) for attacking his victims' reputations. The author asserts that 'money and power does buy justice' in Palm Beach County and argues that lack of knowledge regarding a victim's age is no defense for statutory rape. The page also contains unrelated letters regarding a local church and pension legislation.
DOJ-OGR-00031316.jpg
This Palm Beach Police Department incident report, dated November 18, 2005, details case number 1-05-001263. The report lists Benjamin Skyler Bryan as a suspect/arrestee and provides his personal information. It also documents confiscated evidence, a 'PAPER BAG W/MARIJUANA', and details of a searched 1997 Mitsubishi Galant associated with the case.
DOJ-OGR-00031274.jpg
This document is a screenshot of a MySpace profile page from July 2005. It features a flyer for a local music event at a venue called SKATEZONE UNDERGROUND, scheduled for a Friday in August, and lists several performing bands. The page also contains two comments from other MySpace users, 'sam' and 'imCORE', indicating social interactions on the platform.
DOJ-OGR-00032370.jpg
This Palm Beach Police Department incident report, dated April 20, 2006, documents ongoing investigative activities related to a case involving Epstein. It includes details of vehicle surveillance, background checks on associated individuals, and a scheduled interview with Janusz Banasiak. The main part of the document is a narrative from a January 19, 2006 interview with Johanna Sjoberg, who describes being recruited by Ghaline Maxwell to work for Epstein while in college, a job that evolved from running errands to providing massages to Epstein, his assistant Sarah, and Nadia Marcinkova.
DOJ-OGR-00032365.jpg
This Palm Beach Police Department incident report from February 17, 2006, details two interviews related to an investigation into Jeffrey Epstein. The first interview is with a woman who describes being paid to give Epstein a massage approximately a year prior, during which he masturbated. The second interview, conducted on February 13, 2006, is with Epstein's pilot, David Rodgers, who discusses his employment, flight procedures, and limited knowledge of passengers like Dana Burns, Sarah, and Adrianna.
DOJ-OGR-00032364.jpg
This Palm Beach Police Department incident report, dated February 17, 2006, documents an interview with an 18-year-old woman who alleges Jeffrey Epstein sexually assaulted her multiple times during paid massage sessions at his home, beginning in May 2005. The woman claims Epstein touched her breasts, masturbated during the sessions, and digitally penetrated her on one occasion. The report also states the woman admitted to receiving money for bringing other people, including a girl and her friend Tory Bean, to Epstein's house to "work."
DOJ-OGR-00031075.jpg
This is a Palm Beach Police Department Incident Report dated November 18, 2005, for case number 1-05-001263. The report details confiscated property described as a 'PAPER BAG W/MARIJUANA', a searched 1997 Mitsubishi Galant, and provides personal and descriptive information for the suspect/arrestee, Benjamin Skyler Bryan.
DOJ-OGR-00032917.jpg
This Palm Beach Police Department incident report, dated April 20, 2006, details interviews conducted as part of an investigation into Jeffrey Epstein. It includes an interview with Victoria Bean, who described providing a massage to Epstein during which he masturbated, and an interview with Epstein's pilot, David Rodgers, who provided limited information about flight passengers. The report also documents the investigator's unsuccessful attempts to meet with Courtney Wild and initial contact with Britany Beale.
DOJ-OGR-00032916.jpg
This document is an incident report from the Palm Beach Police Department related to the investigation of Jeffrey Epstein. It details the conclusion of an interview with an individual named Venero, a background check on Epstein's pilot David Rodgers, and a detailed interview with Joanna Harrison regarding sexual acts performed during massages for Epstein.
DOJ-OGR-00032912.jpg
Palm Beach Police incident report dated January 23, 2006, detailing an interview with Johanna Sjoberg. Sjoberg identified Ghislaine Maxwell (spelled 'Ghaline') as the person who recruited her from Palm Beach Atlantic College to work at Epstein's home. Sjoberg admitted to providing massages to Epstein, his assistant Sarah, and Nadia Marcinkova before she was a licensed therapist, starting when she was approximately 20 years old.
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This newspaper article discusses the legal complexities facing the prosecution of Jeffrey Epstein following his indictment on a single charge of felony solicitation. Experts like attorney Dekle and former prosecutor Betty Resch explain why child sex abuse cases are difficult to win, citing issues with victim credibility, social status, and the tendency of jurors to believe adults over children. The article notes Epstein's high-powered defense team, including Jack Goldberger and Alan Dershowitz, who attacked the victims' credibility.
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This document contains a Palm Beach Police Department incident report narrative (Narrative #39) dated February 2006. It details an interview with a redacted witness who describes providing massages to Jeffrey Epstein beginning at age 18, during which she alleges sexual acts occurred, including manual penetration. The report also documents a background check on David Rodgers, Epstein's pilot, and notes phone records obtained via T-Mobile.
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Minutes from a July 17, 2008, Code Enforcement Board meeting in Palm Beach regarding a violation by the Nightingale Beach Club Association involving sea grape trimming during turtle nesting season. The Board debated the fairness of enforcement, environmental concerns, and the Town's own compliance history, ultimately voting to grant the violator until November 7, 2008, to comply or face a daily fine of $250.00. The document highlights tensions between Town enforcement, state environmental agencies (DEP, FWC), and property owners.
HOUSE_OVERSIGHT_016567.jpg
This document contains minutes from a Palm Beach Code Enforcement Board meeting on July 17, 2008, primarily discussing environmental regulations regarding sea grape trimming during turtle nesting season at the Nightingale Beach Club Association. The Board debated enforcement timelines, referencing coordination with the DEP and FWC, while the violator's representative, Mr. Maxey, raised concerns about economic hardship and alleged the Town itself had violated similar regulations. The Board ultimately voted to grant an extension for compliance until November 7, 2008, with a potential daily fine of $250.00 thereafter.
HOUSE_OVERSIGHT_013416.jpg
A Palm Beach Post article from September 18, 2009, reporting on the unsealing of Jeffrey Epstein's secret non-prosecution agreement with federal prosecutors. The deal, criticized by legal experts and victims' attorneys as a "sweetheart deal," protected potential co-conspirators from charges and initially included a provision for Epstein to pay for a lawyer to negotiate civil settlements with victims. The article highlights the lack of consultation with victims and the disparity in sentencing.
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