Mr. Willits

Person
Mentions
12
Relationships
3
Events
3
Documents
6
Also known as:
Willits

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3 total relationships
Connected Entity Relationship Type
Strength (mentions)
Documents Actions
person CAROLYN
Legal representative
6
2
View
person CAROLYN
Client
5
1
View
person THE WITNESS
Filer of complaint on behalf of
1
1
View
Date Event Type Description Location Actions
N/A N/A Filing of a legal complaint State Court View
2008-01-01 Legal filing A complaint was filed in state court by Mr. Willits on behalf of Carolyn against Jeffrey Epstein ... state court View
2008-01-01 N/A Filing of a complaint in state court against Jeffrey Epstein and Sarah Kellen. State Court View

EFTA00014028.pdf

This document contains an email thread from December 29, 2008, between the FBI and the US Attorney's Office (USAFLS), and a forwarded email from an Assistant U.S. Attorney to several lawyers representing victims (Josefsberg, Edwards, Ezell, etc.). The primary subject is the confidentiality of victim locations regarding Jeffrey Epstein's GPS monitoring 'exclusionary zones.' The Assistant U.S. Attorney confirms, via Captain Sleeth of the Palm Beach Sheriff's Office, that victim addresses added to the GPS system will remain confidential and will not be shared with Epstein.

Email correspondence
2025-12-25

EFTA00014026.pdf

This document is an email chain from December 2008 involving an Assistant U.S. Attorney and several defense attorneys (Josefsberg, Ezell, Edwards, etc.) regarding Jeffrey Epstein's work release conditions. The discussion focuses on the 'exclusionary zones' programmed into Epstein's GPS monitoring system to protect victims. The AUSA confirms, via Captain Sleeth of the Palm Beach Sheriff's Office, that while Epstein's GPS will alert if he nears a prohibited location, the specific addresses and identities of the victims will remain confidential and unknown to Epstein.

Email correspondence
2025-12-25

DOJ-OGR-00018782.jpg

This document is page 184 of a court transcript from Case 1:20-cr-00330-PAE (Ghislaine Maxwell trial), filed on August 10, 2022. Defense attorney Mr. Pagliuca is cross-examining a witness named Carolyn regarding a complaint filed on her behalf by attorney Mr. Willits in 2008 against Jeffrey Epstein and Sarah Kellen. The prosecution (Ms. Comey) successfully objects to the admission of defense exhibit C4 on the grounds that it is 'not inconsistent,' leading the defense to request a sidebar.

Court transcript (cross-examination)
2025-11-20

DOJ-OGR-00018780.jpg

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) dated August 10, 2022. It features the cross-examination of a witness named Carolyn by defense attorney Mr. Pagliuca. The questioning focuses on a previous legal complaint filed on Carolyn's behalf by an attorney named Mr. Willits in state court; specifically, Pagliuca establishes that this 91-page, 209-paragraph complaint did not contain a single mention of Ms. Maxwell's name.

Court transcript (cross-examination)
2025-11-20

DOJ-OGR-00013197.jpg

This document is a court transcript from August 10, 2022, detailing the cross-examination of a witness named Carolyn by an attorney, Mr. Pagliuca. The questioning focuses on a complaint filed on Carolyn's behalf in 2008 against Jeffrey Epstein and Sarah Kellen. The proceedings are interrupted when another attorney, Ms. Comey, makes an objection that is subsequently sustained by the judge.

Legal document
2025-11-20

DOJ-OGR-00013195.jpg

This document is a page from a court transcript dated August 10, 2022, detailing a cross-examination. Mr. Pagliuca is questioning a witness, possibly named Carolyn, about a complaint that was 91 pages long with 209 paragraphs and did not mention Ms. Maxwell's name. They also discuss an Exhibit C4 and the filing of the complaint by Mr. Willits in state court.

Court transcript / hearing record
2025-11-20
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