Katherine Warthen Ezell
PersonRelationship Network
017-13.pdf
This document is a protective response filed by Plaintiff Jane Doe on May 27, 2010, in the Southern District of Florida case against Jeffrey Epstein. The plaintiff requests the court to promptly order the production of tax returns and other documents that Epstein has withheld on Fifth Amendment grounds, emphasizing that the trial date is set for July 19, 2010. The filing notes that negotiations with Epstein's counsel failed and lists numerous related cases and attorneys involved.
017-01.pdf
This document is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Jane Doe in the United States District Court for the Southern District of Florida against Jeffrey Epstein. The plaintiff argues that Epstein's blanket invocation of Fifth Amendment privileges to refuse producing documents (such as phone records, tax returns, and correspondence) is improper and that he should be compelled to answer or provide a privilege log. The motion details specific discovery requests and Epstein's uniform response asserting his constitutional rights against self-incrimination.
015.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) opposing Jeffrey Epstein's appeal of a Magistrate Judge's order compelling him to produce income tax returns for the years 2003-2008. The Plaintiffs argue that tax returns are 'required records' not protected by the Fifth Amendment privilege against self-incrimination and are critical for determining punitive damages. The document notes that Epstein attempted to avoid producing these records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs rejected as insufficient.
076.pdf
This document is a legal memorandum filed by the Plaintiffs (Jane Does 2-8) in response to Jeffrey Epstein's appeal of a Magistrate Judge's order compelling him to produce his income tax returns for the years 2003-2008. The Plaintiffs argue that the tax returns are relevant for determining punitive damages and are not protected by the Fifth Amendment privilege against self-incrimination, citing the 'required records' exception. The document also notes Epstein's attempt to avoid producing records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs reject as insufficient.
052.pdf
This document is a Motion for Protective Order filed on July 29, 2009, in the Southern District of Florida by Plaintiffs 'Jane Does 2-7' against Jeffrey Epstein. The plaintiffs allege that Epstein hired private investigators to harass and intimidate them by contacting their former employers, ex-boyfriends, and friends to ask intrusive personal questions and potentially 'out' them as sexual abuse victims. The motion seeks a court order to stop Epstein's investigators from making ex parte contacts with nonparties associated with the plaintiffs.
045.pdf
This document is a Motion to Compel filed by Plaintiff Jane Doe against Jeffrey Epstein on July 10, 2009, in the Southern District of Florida. The plaintiff lists 23 specific interrogatories regarding Epstein's finances, properties, travel, and alleged sexual abuse of minors, all of which Epstein refused to answer by invoking his Fifth and Sixth Amendment rights. The motion argues that Epstein's blanket refusals are improper and requests the court force him to answer or provide a privilege log.
043.pdf
This document is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the United States District Court, Southern District of Florida (Case No. 08-CV-80119-MARRA/JOHNSON). The motion argues that Epstein has improperly asserted blanket Fifth Amendment privileges in response to sixteen specific requests for production of documents, including telephone records, appointment books, financial records, and correspondence. The Plaintiff requests the Court to order Epstein to answer the requests, provide a particularized justification for his Fifth Amendment invocations, and produce a privilege log.
021.pdf
This document is a Notice of Filing Proposed Order submitted to the U.S. District Court for the Southern District of Florida on May 27, 2009. It lists eleven separate civil cases filed against Jeffrey Epstein by various plaintiffs, including Jane Does 2-7, 101, 102, C.M.A., and Doe II. The filing serves to submit a proposed order related to case no. 08-80119 and includes a service list of attorneys involved in the litigation.
028.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) in the case Jane Doe No. 2 vs. Jeffrey Epstein (Case No. 08-CV-80119-MARRA/JOHNSON). The memorandum opposes Epstein's appeal of a Magistrate Judge's order compelling him to produce his income tax returns for the years 2003-2008. The Plaintiffs argue that the tax returns are not protected by the Fifth Amendment (citing the 'required records' exception and 'foregone conclusion' doctrine) and are critical for determining punitive damages given the allegations of sexual molestation and Epstein's refusal to provide net worth discovery beyond a stipulation of 'nine figures.'
040.pdf
This document is a Motion to Compel filed on July 10, 2009, in the US District Court for the Southern District of Florida by Plaintiff Jane Doe (represented by Bradley Edwards). The motion requests the court to force Jeffrey Epstein to answer a set of interrogatories regarding his financial assets, net worth, foreign travel, property ownership, and alleged interactions with the plaintiff and other minor females. Epstein refused to answer nearly all questions (except for providing the name/address of the person answering), invoking his Fifth and Sixth Amendment rights against self-incrimination and right to counsel.
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.
030.pdf
This document is a 'Notice of Joinder' filed on June 8, 2009, in the US District Court for the Southern District of Florida, where Plaintiffs Jane Does 2-7 join a motion for a no-contact order against Jeffrey Epstein. The filing alleges that Epstein's associate and recruiter, Hayley Robson, has been harassing victims Jane Does 4 and 7 through text messages and in-person threats while claiming to be financially supported by and cooperating with Epstein. The plaintiffs request a court order prohibiting Epstein from any direct or indirect contact with the victims.
061.pdf
This document is a Motion to Compel filed on July 10, 2009, in the Southern District of Florida by Plaintiff Jane Doe against Defendant Jeffrey Epstein. The motion seeks to force Epstein to answer 23 specific Requests for Admission regarding his net worth (specifically if it exceeds $1 billion), his financial support of modeling agency MC2, his ownership of Caribbean property, and specific allegations of sexual battery, assault, and sex trafficking of minors. Epstein had previously refused to answer these questions by invoking his Fifth Amendment privilege against self-incrimination.
060.pdf
This is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the Southern District of Florida. The motion seeks a court order requiring Epstein to answer 16 specific requests for production of documents (including telephone records, photos, tax returns, and passport copies) or to provide a privilege log, as Epstein has refused to produce documents by asserting a blanket Fifth Amendment privilege against self-incrimination. The plaintiff argues that Epstein's boilerplate objections are invalid, violate local rules requiring a privilege log, and that he must provide a particularized justification for his Fifth Amendment invocation for each request.
012.pdf
This document is an Emergency Motion filed on June 14, 2010, by Jeffrey Epstein's legal team to quash a subpoena and prevent the deposition of Maritza Milagros Vasquez, scheduled for the following day. Epstein's lawyers argue that the subpoena issued by C.L.'s counsel (Spencer Kuvin) is premature under Rule 26(d) and that the cross-notice by Jane Doe's counsel (Brad Edwards) is invalid because discovery in the Jane Doe case had already concluded on May 31, 2010. The document includes the motion, a subpoena exhibit, and a cross-notice exhibit.
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