FLORIDA
LocationRelationship Network
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Jeffrey Epstein
|
Legal representative |
1
|
1 |
075.pdf
A legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party Jean Luc Bruhnel (spelled 'Bruhnel' in document) in the case of Jane Doe v. Jeffrey Epstein. The filing opposes a motion to compel Bruhnel's deposition, arguing that he is a French citizen who has left the U.S. with no plans to return and cannot be compelled to appear under Federal Rules. The document alleges misrepresentation and nonfeasance by the Plaintiff's counsel and suggests using the Hague Convention to secure testimony abroad.
011.pdf
This document is a Motion to Remand filed on August 18, 2008, by Plaintiff Jane Doe against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The plaintiff seeks to move the case back to Florida state court, arguing that federal diversity jurisdiction is invalid because both the Plaintiff and Defendant Haley Robson are Florida citizens. The motion details allegations that Robson recruited the plaintiff (a minor at the time) for Epstein's sexual abuse scheme and argues that Robson is a legitimate defendant, not 'fraudulently joined' solely to prevent federal jurisdiction.
027.pdf
Legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party witness Jean Luc Bruhnel (spelled Bruhnel in document). The filing opposes Plaintiff Jane Doe's motion to compel Bruhnel to appear for a deposition, arguing that Bruhnel is a French citizen who has left the US with no plans to return and cannot be compelled by the Court to return. The document asserts that the Plaintiff should use the Hague Convention or other international mechanisms to secure testimony abroad and accuses Plaintiff's counsel of misrepresentation and failure to follow proper procedure.
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.
005.pdf
This document is a Civil Cover Sheet (Form JS 44) filed on October 18, 2019, in the Southern District of New York for a lawsuit initiated by 'Jane Doe 17' against the Estate of Jeffrey Epstein and various associated corporate entities. The cause of action is listed as Battery under 18 U.S.C. sections 1591-1595 (statutes relating to sex trafficking and forced labor). The document identifies Darren K. Indyke and Richard D. Kahn as the personal representatives of the estate and lists several shell companies (like JEGE, Inc. and NES, LLC) as defendants whose addresses were unknown at the time of filing.
034.pdf
This document is a Memorandum of Law in Support of Defendants' Motion to Dismiss Plaintiff's Complaint, filed by the executors of the Estate of Jeffrey E. Epstein. The defendants argue that the plaintiff's claims for battery and intentional infliction of emotional distress, stemming from alleged sexual assaults in 1999, are time-barred by the applicable statutes of limitations in New York and Florida. They further argue that recent New York legislation extending the statute of limitations does not apply retroactively to already expired claims, and that the plaintiff cannot claim equitable tolling or estoppel. Additionally, the defendants assert that punitive damages cannot be recovered from a decedent's estate under New York or Florida law.
024.pdf
This document is a letter from Bennet J. Moskowitz, attorney for the Co-Executors of Jeffrey Epstein's Estate, to Judge Lorna G. Schofield, dated January 24, 2020. The letter requests a pre-motion conference to move for the dismissal of a lawsuit filed by Jane Doe 1000. The defense argues that the plaintiff's claims regarding alleged abuse in 1999 are time-barred by the statutes of limitations in New York and Florida, do not qualify for tolling under the Child Victims Act or criminal proceeding statutes, and that punitive damages cannot be legally awarded against a decedent's estate.
007.pdf
This document is a legal memorandum filed on November 20, 2019, in the Southern District of New York, supporting a motion for 'Jane Doe 1000' to proceed anonymously in her civil suit against the Estate of Jeffrey Epstein. The plaintiff alleges she was sexually trafficked and abused by Epstein and Ghislaine Maxwell, detailing forced sexual acts and the use of sex toys. The motion argues that anonymity is necessary to protect the plaintiff from severe emotional distress, public scrutiny, and potential retaliation from Maxwell, who was described as being 'at large' at the time of the filing.
016.pdf
This document is a letter from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Gregory H. Woods, dated January 21, 2020. It outlines the grounds for an anticipated motion to dismiss claims brought by plaintiff Teala Davies against the Estate of Jeffrey Epstein. The defense argues that Davies' claims of sexual assault (alleged to have occurred between 2002 and 2004 in FL, NM, NY, USVI, and France) are time-barred by applicable statutes of limitations and that punitive damages cannot be recovered from a deceased tortfeasor's estate.
024.pdf
This is a Memorandum of Law filed by the defendants (Executors of the Estate of Jeffrey Epstein) in support of their motion to dismiss the plaintiff's complaint. The defendants argue that the plaintiff's claims of sexual assault and battery are time-barred by the applicable statutes of limitations in multiple jurisdictions (USVI, NY, NM, FL, France) and that exceptions like CPLR 215(8)(a) or equitable tolling do not apply. Additionally, the defendants argue that punitive damages are not recoverable against a deceased tortfeasor's estate under the laws of any relevant jurisdiction.
012.pdf
This document is a letter from Bennet J. Moskowitz of Troutman Sanders LLP to Judge Andrew L. Carter Jr., dated January 24, 2020. It serves as a pre-motion letter outlining the Estate of Jeffrey Epstein's intent to move for dismissal of a lawsuit filed by Juliette Bryant. The Estate argues that Bryant's claims regarding alleged sexual abuse between 2002 and 2004 are time-barred by the statutes of limitations in New York, USVI, Florida, and New Mexico, and that she cannot rely on the Child Victims Act or tolling because she was an adult (age 20-22) at the time of the alleged incidents. Additionally, the letter argues that punitive damages cannot be recovered from a decedent's estate under the relevant laws.
EFTA00038941.pdf
This document is a 'Relativity Searches' report dated November 18, 2021, listing document control numbers relevant to four redacted search targets. The results include references to Epstein's 'black book', lists of girls' names, masseuses, phone records, bill logs, and interview transcripts from 2007 and 2018. It serves as an index of evidence rather than a primary source of the evidence itself.
EFTA00038681.pdf
This document is an email chain from May and June 2021 between FBI agents and potentially legal counsel regarding the transfer of evidence ('Florida Materials') related to the '72 case' (likely referring to an FBI classification code, potentially with case ID 72-MM-113327 as seen in the attachment filename). The correspondence confirms that evidence from Florida has arrived in New York and discusses creating an index of these items to be produced to the defense. The emails involve the FBI New York Field Office's Child Exploitation/Human Trafficking unit.
EFTA00038462.pdf
An email chain from October 1, 2020, in which Maria Kelljchian, a paralegal at Edwards Pottinger LLC, contacts federal authorities regarding a client identified as a 'Florida victim' of Epstein currently living in Ohio. The email requests FBI assistance for the victim's therapy expenses and offers to coordinate a statement. The internal discussion among the recipients (likely law enforcement or prosecutors) involves coordinating interviews with victims represented by Brittany and Brad, and mentions an upcoming trip to Pennsylvania.
EFTA00038415.pdf
An email from an FBI Victim Specialist in the New York Office dated May 4, 2020. The email informs the recipient that because Florida Crime Victims Compensation is unavailable, the FBI Victim Services Division has approved payment for up to 12 counseling sessions for Florida victims of Jeffrey Epstein. It outlines the protocol requiring pre-approval by the Case Agent to confirm victim status before payments can be made.
EFTA00038412.pdf
This document is an email thread from May 13, 2020, regarding therapy resources for victims of Jeffrey Epstein. An attorney ('Of Counsel') writes to an unidentified recipient (likely within the FBI or DOJ) seeking counseling options for clients located in the West Palm Beach area, referencing similar assistance previously provided by the FBI in New York. The email is forwarded internally with a query about the sender's identity.
EFTA00038408.pdf
An email chain from April 2020 involving an FBI agent, attorney Robert Josefsberg, and Brittany Henderson. The correspondence clarifies FBI Victim Assistance policies, specifically stating that while standard coverage is six counseling sessions, victims residing in Florida may be approved for up to 12 sessions by a case agent. The thread also references a previous meeting in Miami regarding these matters.
EFTA00038394.pdf
This document is an email dated December 9, 2019, sent by a Detective from the NYPD/FBI Child Exploitation and Human Trafficking Task Force (Squad C20). The email transmits an attachment containing an image of Ghislaine Maxwell's Florida Driver's License (FL DL). The sender and recipient names are redacted.
EFTA00038175.pdf
An email chain from October 2020 between legal/prosecution teams regarding outstanding discovery issues in the Ghislaine Maxwell case. Key topics include handling 'six images of child pornography' found in 'Florida boxes', converting grand jury audio, and processing unreadable GPS data from Maxwell's phone. The emails coordinate logistics for defense counsel to review evidence, specifically nude images, at the FBI.
EFTA00037984.pdf
This document is an FBI Operations Order Form dated July 2, 2019, outlining the plan to arrest Jeffrey Epstein for child sex trafficking. It details that Epstein was out of the country at the time, and a 'silent hit' was placed with CBP to detain him upon his return to the US, after which FBI and NYPD would effect the arrest. The plan also includes the subsequent execution of a search warrant at his residence at 9 East 71st Street in New York.
EFTA00037915.pdf
This document is an inventory list of electronic evidence seized in relation to the Jeffrey Epstein case, specifically labeled as 'New York Evidence' and 'Island Evidence'. It lists various hardware including Seagate hard drives (linked to the original Florida case), Apple Mac desktops, Windows PCs (Dell, HP, MSI), loose media (SD cards, USBs), and a Nikon camera. It also lists inventory numbers for cell phone extractions and notes comments from a redacted individual regarding further processing needs.
EFTA00037904.pdf
This document is a page from a victim questionnaire containing questions 13 through 23 regarding human trafficking experiences. While most answers are heavily redacted (blacked out), the document explicitly identifies the locations of the trafficking as Kentucky, Tennessee, Texas, and Florida. Crucially, question 23 identifies the trafficker as 'Jeffery Epstein' and notes he is 'in his 60's'.
EFTA00037900.pdf
This document is an Interim Report of Investigation from Ben Nivens of Hope for Justice, dated August 1, 2019. It details allegations from a victim who claims she was trafficked at age 5 in Florida and at age 17 in the U.S. Virgin Islands, describing severe abuse including being kept in a crawl space and abused in a room resembling a horse stall. The investigator concludes that the allegations should be forwarded to the FBI's New York Field Office for inclusion in their investigative file on a redacted individual (contextually likely Jeffrey Epstein).
EFTA00037877.pdf
This document is an email chain from August 15, 2019, involving the United States Attorney's Office for the Southern District of New York (SDNY). The correspondence coordinates mental health counseling and support for victims in the Epstein case, specifically mentioning a victim in Palm Beach, Florida. The emails identify 'Safe Horizon' (specifically Victoria Dexter and Sherri Papamihalis) as a resource willing to provide counseling slots for these victims.
EFTA00037655.pdf
An email chain dated December 10, 2019, between the MAGLOCLEN Intelligence Services Unit and members of the NYPD/FBI Child Exploitation Task Force. The correspondence shares intelligence regarding Ghislaine Maxwell, specifically attaching a PDF of her Florida driver's license and information about Florida vehicles, referencing a password previously used for 'MA vehicles'.
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