This document is a 'Summons in a Civil Action' filed in the United States District Court for the Southern District of Florida on September 17, 2010. The case (No. 9:10-cv-81111-WPD) involves plaintiff 'M.J.' suing defendants Jeffrey Epstein and Sarah Kellen. The summons is addressed to Sarah Kellen at an apartment in Palm Beach, FL, instructing her to respond to the complaint within 21 days via plaintiff's attorney Bradley J. Edwards.
This document is a Summons in a Civil Action filed in the US District Court for the Southern District of Florida on September 17, 2010. The plaintiff, identified as M.J., is suing Jeffrey Epstein and Sarah Kellen. The document commands Epstein to respond within 21 days and lists Bradley J. Edwards as the plaintiff's attorney. The second page is an unfilled Proof of Service form.
This document is a reply filed by Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell in the case of Giuffre v. Maxwell. Edwards argues that the subpoena imposes an undue burden on him as a non-party and opposing counsel, seeking information that is already in Maxwell's possession, privileged, irrelevant, or available from other sources. The brief details the history of related litigation, including the CVRA case and a defamation suit against Alan Dershowitz, to support the argument that the subpoena is harassing and unnecessary.
Legal declaration by attorney Bradley J. Edwards filed on June 13, 2016, in support of a motion to quash a subpoena from Ghislaine Maxwell. Edwards details his representation of Virginia Giuffre and the undue burden of reviewing over 200,000 emails for communications with journalists. He explicitly states that Ghislaine Maxwell and Jeffrey Epstein share a joint defense agreement and mentions Giuffre's association with the organization 'Victims Refuse Silence, Inc.'
This document is a Civil Summons from the United States District Court, Southern District of Florida, dated March 24, 2009. It notifies defendants Jeffrey Epstein and Sarah Kellen (a.k.a. Sarah Bonk) that they are being sued by Jane Doe II and must respond within 20 days. Notably, the summons lists Sarah Kellen's address in New York City and Jeffrey Epstein's address as the Palm Beach County Stockade, including his inmate jacket number.
This document is a legal motion filed on June 9, 2009, by Plaintiff Jane Doe No. 101 requesting an extension of time and page limits to respond to Jeffrey Epstein's Motion to Dismiss. The request is based on an upcoming court hearing scheduled for June 12, 2009, in a related case (Jane Doe No. 2 vs. Jeffrey Epstein) which addresses potential breaches of Epstein's Non-Prosecution Agreement. The document includes certificates of conference and service, listing legal counsel for both parties, including Bruce Reinhart as counsel for a co-defendant named Sarah.
A proposed court order from the Southern District of Florida in the case of Jane Doe No. 101 vs. Jeffrey Epstein (Case No. 09-80591). The document grants the Plaintiff's motion for an enlargement of time and page limits to respond to the Defendant's Motion to Dismiss. The order allows for a response of up to 36 pages. Note: The body of the text contains a likely typographical error dating it to 'June, 2008' while the header indicates it was entered on the docket in June 2009.
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.
This document is a civil complaint filed on April 17, 2009, by Jane Doe No. 101 against Jeffrey Epstein in the Southern District of Florida. The plaintiff alleges that in 2003, when she was a 17-year-old high school student, she was recruited and transported to Epstein's Palm Beach mansion where she was sexually assaulted under the guise of giving massages. The complaint asserts causes of action under 18 U.S.C. § 2255 regarding coercion, travel with intent to engage in illicit sexual conduct, sex trafficking, and transport of child pornography.
This document is an unopposed motion filed on May 11, 2010, in the Southern District of Florida (Case 10-80447) by Plaintiff C.L. requesting a 10-day extension to respond to Defendant Jeffrey Epstein's Motion to Dismiss. The extension was requested because Plaintiff's counsel, Spencer T. Kuvin, had a conflicting trial starting the same day in Palm Beach Civil Circuit Court. The document includes a Certificate of Service listing Epstein's legal team (Critton, Pike, Goldberger) and a proposed order for Judge Kenneth A. Marra to sign.
This document is a civil summons issued on March 31, 2010, by the U.S. District Court for the Southern District of Florida in the case of Plaintiff C.L. v. Defendant Jeffrey Epstein (Case 9:10-cv-80447-KAM). It commands Epstein to respond to the lawsuit within 21 days and lists Spencer T. Kuvin as the plaintiff's attorney. The second page contains a blank Proof of Service form.
This document is a 'Government's Notice of Proposed Procedures for the Determination of a Remedy' filed by the United States in the case of Jane Doe 1 & 2 v. United States. The government proposes a schedule where Petitioners must first submit their proposed remedies, followed by a 60-day period for the government to consult with victims before responding. The government argues this consultation is essential because potential remedies, such as rescinding Epstein's non-prosecution agreement, could negatively impact other victims who have already received compensation or wish to avoid further trauma.
This document is the controversial Non-Prosecution Agreement (NPA) between Jeffrey Epstein and the United States Government (represented by U.S. Attorney R. Alexander Acosta). The agreement stipulates that federal prosecution will be deferred and eventually dismissed if Epstein pleads guilty to specific state charges (lewd battery, solicitation, sexual activity with minors) and serves a recommended 30-month sentence (minimum 18-20 months in prison). It also notably limits the identification of victims to a list not exceeding forty people and requires Epstein to register as a sex offender.
This is the 2007 Non-Prosecution Agreement (NPA) between the United States (represented by U.S. Attorney R. Alexander Acosta) and Jeffrey Epstein. In exchange for Epstein pleading guilty to state charges of solicitation of prostitution and serving a 30-month sentence (including jail and community control), the federal government agreed not to prosecute him for federal sex trafficking crimes. Crucially, the agreement also granted immunity to any potential co-conspirators (names redacted) and stipulated that the agreement would not be made part of the public record.
This document is a letter from U.S. Attorney R. Alexander Acosta to retired Judge Edward B. Davis, confirming Davis's appointment as a Special Master. The letter outlines the terms of Jeffrey Epstein's Non-Prosecution Agreement (NPA), specifically identifying that the U.S. government has identified 34 victims. It details Epstein's agreement to pay for an attorney representative for these victims and waive liability contests in specific civil suits, provided the victims proceed under 18 U.S.C. § 2255.
This document is the 2007 Non-Prosecution Agreement (NPA) and subsequent Addendum between the United States (represented by US Attorney R. Alexander Acosta) and Jeffrey Epstein. In the agreement, Epstein agrees to plead guilty to state solicitation charges and serve a recommended 30-month sentence (18 months in jail plus probation) in exchange for federal non-prosecution. Crucially, the agreement also grants immunity from federal prosecution to any potential co-conspirators of Epstein, with specific names redacted in the text.
This document is the United States Government's legal response to proposed remedies by victims (Petitioners) of Jeffrey Epstein following a court finding that the government violated the Crime Victims' Rights Act (CVRA) by failing to confer with them before entering a Non-Prosecution Agreement (NPA). The government admits its communication with victims was insufficient but argues against the Petitioners' request to partially rescind the NPA, citing contract law, potential harm to other victims relying on the agreement, and separation of powers. Instead, the government proposes holding a public hearing for victim impact statements, arranging meetings between victims and DOJ representatives, and mandating additional training for prosecutors.
This document outlines terms of an agreement involving Jeffrey Epstein, detailing his obligations to waive challenges and appeal rights, provide agreements to the U.S. Attorney's Office, and cooperate regarding victims. It states that the United States will provide victim lists, facilitate the appointment of an attorney representative paid by Epstein, and Epstein will not contest jurisdiction for victim lawsuits in the Southern District of Florida. This appears to be part of a plea agreement or similar legal settlement.
This page contains sections 7 through 11 of a legal agreement (likely the 2008 Non-Prosecution Agreement) between the United States and Jeffrey Epstein. It outlines the protocol for identifying victims, appointing a representative for them (paid by Epstein), and handling civil liability claims under 18 U.S.C. § 2255. Crucially, the text states that Epstein's agreement to pay damages or waive liability contests in specific federal contexts does not constitute a general admission of civil or criminal liability.
This legal document, dated March 31, 2008, is a motion for a protective order filed by the law firm Herman & Mermelstein, P.A. on behalf of 'Witness Y. Doe'. The motion requests that the court order the witness's deposition for an unspecified criminal case and the civil case 'Jane Doe No. 3 v. Jeffrey Epstein' to be conducted simultaneously. The stated purpose is to prevent potential harassment of the witness by the defendant, Jeffrey Epstein.
This document is a 'Motion for Protective Order' filed in the Circuit Court of Palm Beach County, Florida, in the case of State of Florida v. Jeffrey Epstein. The motion is filed by a witness/victim identified anonymously as 'Y. Doe' (also 'Jane Doe No. 3' in a federal civil case), requesting that her deposition scheduled for April 2, 2008, in the criminal case be conducted simultaneously with her deposition for the civil case. The document explicitly states that Y. Doe alleges she was sexually assaulted by Epstein when she was 16 years old.
This legal document, part of a larger agreement, outlines the terms under which Jeffrey Epstein will address civil claims from victims identified by the United States government. Epstein agrees that after he is sentenced, the U.S. will provide a list of victims to his attorneys, and he will pay for an attorney representative for them. For any victims who file suit under 18 U.S.C. § 2255, Epstein agrees not to contest the jurisdiction of the U.S. District Court for the Southern District of Florida and waives his right to contest liability and damages up to an agreed-upon amount, with the stipulation that this agreement is not an admission of liability for any other purpose.
This legal document, dated March 31, 2008, is a request for a protective order filed by the law firm Herman & Mermelstein on behalf of 'Witness Y. Doe'. The motion asks the court to require that depositions for a criminal case and a civil case, 'Jane Doe No. 3 v. Jeffrey Epstein', be conducted at the same time to prevent harassment of the witness by Defendant Epstein. The filing states that counsel for the State and for Epstein were contacted about this request but have not responded.
A Motion for Protective Order filed on March 31, 2008, in the Circuit Court of Palm Beach County. Witness 'Y. Doe,' an alleged victim claiming sexual assault by Epstein at age 16, requests that her deposition for the criminal case be consolidated with her deposition for her federal civil suit (Jane Doe No. 3 v. Jeffrey Epstein) scheduled for April 2, 2008.
This legal document, a page from a court filing, argues that the defendant was never subjected to double jeopardy in the Southern District of Florida. It asserts that jeopardy never attached because she was never indicted, convicted, or faced adjudication of facts for the offenses in question. The document cites several legal precedents to support the claim that the Non-Prosecution Agreement (NPA) involving the defendant and Epstein did not trigger jeopardy protections as no indictment was ever filed.
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