FLORIDA
LocationRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Jeffrey Epstein
|
Legal representative |
1
|
1 |
C._Contact_Book_(Redacted).pdf
This document is a heavily redacted version of Jeffrey Epstein's 'Black Book' (contact list) from approximately 2004-2005. It contains an alphabetical listing of high-profile individuals, politicians, celebrities, and business associates, along with sections for specific locations (Palm Beach, NY, Paris, etc.) and services (Massage, Medical, Aviation). The final page contains significant handwritten notes identifying key witnesses, staff members (chefs, drivers), and specific allegations regarding the procurement of women ('Scout for young females') and interactions with underage girls.
Epstein_Part_24_(Redacted).pdf
This document contains a series of miscellaneous notes and a car rental agreement. Key information includes a thank you note related to a car, scheduling details involving individuals named Dr. Beard, Soruch, and Britney, and instructions to re-rent a car from Dollar Rent A Car, with its contract expiring in February. The document also includes a standard car rental notice to renters regarding insurance and responsibilities.
Epstein_Part_06.pdf
This document contains a series of Deleted Page Information Sheets listing pages withheld from a FOIA release under various exemptions, followed by several FBI internal communications (Electronic Communications and Payment Request forms) concerning the case of Jeffrey Epstein (Case ID 31E-MM-108062). The memos track the opening of sub-files for subpoena and forfeiture matters, updates on forfeiture investigations involving properties in Palm Beach, and interactions with the US Attorney's Office, culminating in a request to close the forfeiture sub-file in 2008 due to state prosecution.
025-01.pdf
Official letter from the New Mexico Department of Public Safety to Jeffrey Epstein dated August 19, 2010. The letter informs Epstein that he is not required to register as a sex offender in New Mexico under state law (NMSA 29-11A) for his 2008 Florida conviction, but notes he may still be required to register under the federal Adam Walsh Child Protection and Safety Act while temporarily residing in the state.
024.pdf
Defense counsel Marc Fernich writes to Judge Berman to supplement Jeffrey Epstein's bail request, arguing against the government's stance that Epstein's wealth creates an irrebuttable presumption for detention. The letter proposes a forensic accounting by Joel Podgor, notes that Epstein's brother Mark is willing to secure a bond with his >$100 million net worth, clarifies Epstein's sex offender registration status in New Mexico, defends against claims regarding an expired Austrian passport, and argues that Epstein's return to the US despite media pressure proves he is not a flight risk.
023-01.pdf
A Palm Beach Police Department incident report detailing allegations of aggressive stalking by private investigators hired by Jeffrey Epstein's defense team in May 2006. The report also analyzes phone records from March 2006, linking a specific individual who intimidated a victim directly to phone numbers registered to Epstein's corporations at 457 Madison Ave, including Ghislaine Corporation and El Zorro Ranch Corporation. The investigator notes a pattern where the intimidator would call the victim and immediately communicate with Epstein's office.
022.pdf
Defense counsel Marc Fernich writes to Judge Berman to supplement Jeffrey Epstein's bail request, arguing that the government is incorrectly using Epstein's wealth to create an irrebuttable presumption of detention. The letter highlights that Epstein's brother, Mark, is willing to pledge his >$100 million net worth to secure bond, disputes the government's characterization of an expired Austrian passport, and clarifies Epstein's sex offender registration status in New Mexico. The defense also argues that Epstein did not flee despite intense media pressure in late 2018 and offers a forensic accounting of his finances.
018.pdf
This document is a transcript of a court conference held on July 8, 2019, in the Southern District of New York regarding the case U.S. v. Jeffrey Epstein. The proceedings cover the scheduling of bail hearings, the government's confirmation of its obligation to notify victims, and preliminary arguments regarding the 2007/2008 Florida Non-Prosecution Agreement (NPA). The defense argues the NPA bars this prosecution, while the government asserts the NPA does not bind the Southern District of New York and that the current indictment involves separate conduct and victims.
006.pdf
This document is a letter from Jeffrey Epstein's defense counsel to Judge Richard Berman arguing for pretrial release on bail. The defense proposes strict conditions including home detention, GPS monitoring, and a substantial bond secured by Epstein's $77 million Manhattan home and private jet, with his brother and friend as co-sureties. The letter argues Epstein is not a flight risk (citing his U.S. ties and surrender of passport) and that the current charges are barred by a 2007 Non-Prosecution Agreement.
007.pdf
A court calendar notice for the Circuit Criminal Felony division in Florida regarding case numbers 06CF009454AXX and 08CF009381AXX against Jeffrey Epstein. The document adds an event (likely a status hearing) to the calendar for June 30, 2008, at 8:30 AM, with the note 'Counsel Agreed'. The document was filed on June 27, 2008.
2022.08.01%20Brief.pdf
This document is a legal brief filed by Ghislaine Maxwell in the Superior Court of the Virgin Islands against the Estate of Jeffrey Epstein. Maxwell argues that Virgin Islands public policy does not prevent her from seeking indemnification (reimbursement) for legal fees and security costs incurred due to her employment with Epstein, despite her criminal conviction in New York (SDNY). She asserts claims based on contract promises, common law joint tortfeasor indemnity, and corporate indemnity laws regarding her role at NES, LLC.
2020.03.12%20Civil%20Complaint.pdf
This document is a civil complaint filed on March 12, 2020, by Ghislaine Maxwell against the Estate of Jeffrey Epstein and its executors, Darren Indyke and Richard Kahn, as well as NES, LLC. Maxwell seeks indemnification for legal fees, security costs, and safe accommodation expenses she has incurred due to her prior employment with Epstein. The complaint alleges that Epstein repeatedly promised, both verbally and in writing (specifically in a 2004 letter), to support Maxwell financially and indemnify her, a practice he reportedly maintained during previous lawsuits in 2009 and 2017.
2022.03.04-5%20Exhibit%20(Affidavit%202).pdf
This document is an affidavit filed by Daniel H. Weiner on March 4, 2022, in the Superior Court of the Virgin Islands regarding the Estate of Jeffrey E. Epstein. Weiner, a partner at Hughes Hubbard & Reed representing Co-Executor Darren K. Indyke, attests to his professional qualifications and billing rates ($1,315/hr in 2020, $1,251/hr in 2021, $1,450/hr current). Attached exhibits include his professional biography and a detailed ledger of fees charged between January 2020 and March 2021 related to 'GVI Motions and GVI Appeal,' totaling dozens of billable hours.
2022.03.04%20Motion%20-%20Motion.pdf
This document is a Motion for Award of Attorneys' Fees filed by the Co-Executors of the Estate of Jeffrey Epstein in the Superior Court of the Virgin Islands. The Co-Executors are requesting $112,216.90 in fees incurred while successfully defending against the Government of the Virgin Islands' (GVI) attempts to intervene in the probate action and freeze estate assets. The document details the history of the GVI's failed motions, the complex nature of the estate, the funding of the Victims' Compensation Program ($121 million+), and justifies the legal fees based on the attorneys' experience and standard rates.
014.pdf
This document is a legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party witness Jean Luc Bruhnel (likely Jean-Luc Brunel) in the civil case Jane Doe v. Jeffrey Epstein. Bruhnel opposes the plaintiff's motion to compel his deposition, arguing that he is a French citizen who has left the United States and cannot be legally compelled to return for testimony. The filing claims the plaintiff's motion is frivolous, notes that previous deposition dates were canceled by agreement, and suggests the plaintiff should use the Hague Convention to secure testimony abroad.
008.pdf
This document contains a Motion for Protective Order filed by Igor Zinoview and Jeffrey Epstein to limit the scope of depositions in a civil case. Zinoview asserts via affidavit that he only began working for Epstein in November 2005, after the alleged events, and thus has no relevant knowledge. The filing also includes excerpts from the depositions of Epstein's pilots, Larry Visoski and Larry Eugene Morrison, where they are questioned about their personal beliefs regarding the sexual abuse allegations and whether they would trust Epstein with their own daughters. Flight logs and passenger manifests are referenced in the deposition indexes ('PLAINTIFF'S EX. 1 FLIGHT LOG BOOK' and 'JEGE, Inc., Passenger Manifest') but the actual log content is not present in these specific pages.
026.pdf
This document is the formal Answer and Affirmative Defenses filed by the Co-Executors of the Jeffrey Epstein Estate (Darren K. Indyke and Richard D. Kahn) in response to a civil complaint by Annie Farmer. The executors generally deny knowledge of the specific allegations of abuse but admit to certain procedural facts, such as Epstein's arrest date (July 6, 2019), death date (August 10, 2019), and property ownership in NY, NM, USVI, FL, and France. They assert ten affirmative defenses, including failure to state a claim, contributory negligence, assumption of risk, and statute of limitations arguments challenging the New York Child Victims' Act.
013.pdf
This document is a legal letter dated January 24, 2020, from attorney Bennet J. Moskowitz (representing the Estate of Jeffrey Epstein) to Judge Naomi Reice Buchwald. The letter requests a pre-motion conference to move for the dismissal of a lawsuit filed by Maria Farmer. The defense argues that Farmer's claims of assault occurring in Ohio in 1995/1996 are time-barred under both New York and Ohio statutes of limitations and that her arguments for tolling (based on Epstein's later criminal indictment or equitable estoppel) are legally insufficient. It also argues that punitive damages cannot be awarded against an estate.
ORDER-SHOW%20CAUSE%20(TAG-DECLINE%20JURIS).pdf
A corrected order from the Supreme Court of Florida dated May 3, 2017, in the case of Jeffrey Epstein vs. Bradley J. Edwards. The court orders the Petitioner (Epstein) to show cause by May 18, 2017, why the court should not decline jurisdiction based on the precedent of Debrincat v. Fischer. The document lists service to several attorneys including Marc S. Nurik and Jack Alan Goldberger.
ORDER-FILING%20FEE%20DUE.pdf
A Florida Supreme Court order dated December 11, 2015, notifying Jeffrey Epstein (Petitioner) that he failed to pay the required $300.00 filing fee for his case against Bradley J. Edwards. The court set a deadline of January 11, 2016, to pay the fee or file for insolvency, warning that failure to do so would result in final dismissal of the case.
DISP-REV%20DY%20LACK%20JURIS%20(TAG).pdf
A 2017 Supreme Court of Florida order denying Jeffrey Epstein's petition for discretionary review in his case against Bradley J. Edwards. The court declined jurisdiction following a review of the response to a show cause order. The document lists the concurring justices and the individuals served with the order, including various attorneys and clerks.
010-16.pdf
This document is a transcript of a court hearing on April 21, 2016, in the case of Giuffre v. Maxwell. The hearing addresses motions to admit Brad Edwards and Paul Cassell as counsel for the plaintiff, which the defense opposes citing conflicts with other litigation (Florida cases) and their status as potential witnesses. The judge also rules on various discovery disputes, including the production of Giuffre's medical records (limited to 1999-2002), tax returns (15 years ordered), and statements made to law enforcement (to be reviewed in camera).
005.pdf
This document is a Motion to Appear Pro Hac Vice filed on June 29, 2016, in the Southern District of Florida. Attorney Denise D. Riley requests that attorney Jeffrey S. Pagliuca of the Colorado firm Haddon, Morgan and Foreman be admitted to represent Defendant Ghislaine Maxwell in matters related to a subpoena issued to Bradley J. Edwards. The document includes contact information for the attorneys involved and a certificate of service to opposing counsel Jack Scarola.
005-02.pdf
This document is a proposed court order filed on June 29, 2016, in the Southern District of Florida, granting attorney Jeffrey S. Pagliuca permission to appear Pro Hac Vice on behalf of Ghislaine Maxwell. The order relates to a subpoena issued to Bradley J. Edwards in connection with the underlying case of Virginia L. Giuffre v. Ghislaine Maxwell. It also establishes electronic filing notifications for Pagliuca and his legal assistant, Nicole Simmons, at the firm Haddon, Morgan and Foreman, P.C.
001-05.pdf
This document outlines Ghislaine Maxwell's formal objections and responses to Virginia Giuffre's second request for production of documents in the 2015 civil case. Maxwell's counsel objects to numerous requests on grounds of privilege, relevance, and burden, specifically refusing to produce financial documents (tax returns, bank statements, asset lists) pending a motion for a protective order. The document also addresses requests for Joint Defense Agreements with Jeffrey Epstein and Alan Dershowitz, communications regarding sexual abuse allegations, and funding sources for the TerraMar Project, including any from the Clinton Foundation.
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