THEODORE J. LEOPOLD
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Jane Doe
|
Client |
7
|
3 | |
|
person
JACK A. GOLDBERGER
|
Professional |
6
|
2 | |
|
person
JACK A. GOLDBERGER
|
Opposing counsel |
6
|
2 | |
|
person
JANE DOE NO. 1
|
Legal representative |
6
|
2 | |
|
person
Unnamed Co-counsel
|
Adversarial professional |
5
|
1 | |
|
person
Jane Doe
|
Professional |
5
|
1 | |
|
person
the witness
|
Legal representative |
5
|
1 | |
|
person
Plaintiff (C.M.A.)
|
Client |
1
|
1 | |
|
person
plaintiff
|
Counsel for plaintiff |
1
|
1 | |
|
person
plaintiff
|
Client |
1
|
1 | |
|
person
Jane Doe
|
Legal representative |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Legal deposition or hearing requiring court reporting | West Palm Beach, FL (Implie... | View |
| 2008-03-01 | Legal filing | A complaint was filed demanding a jury trial and damages against Jeffrey Epstein, Haley Robson, a... | N/A | View |
| 2008-02-20 | N/A | Scheduled deposition of Jane Doe No. 1. | Florida | View |
| 2008-02-20 | Legal proceeding | A direct examination took place where Jack Goldberger's co-counsel refused to provide copies of d... | N/A | View |
| 2008-02-05 | N/A | Filing of Motion for Protective Order | Palm Beach Gardens, FL | View |
| 2008-02-05 | Legal filing | Filing of Jane Doe's Motion For Protective Order with the court. | Palm Beach County Courthouse | View |
| 2008-02-05 | Legal service | Jack A. Goldberger certified that a copy of the Notice of Taking Deposition was furnished via fax... | N/A | View |
| 2008-01-29 | N/A | Filing of Motion to Stay Proceedings. | United States District Cour... | View |
| 2008-01-29 | N/A | Motion to Intervene filed with the US District Court Southern District of Florida | Southern District of Florida | View |
010.pdf
This is a motion filed by Defendant Jeffrey Epstein's attorneys requesting a court order to allow him to attend mediation, deposition, and trial in the case of Jane Doe No. 2 v. Jeffrey Epstein. The motion notes that a prior no-contact order involving Carolyn Andriano might technically preclude this, but states that Plaintiff's counsel and Ms. Andriano have no objection. The document includes a certificate of service listing numerous attorneys involved in related cases.
009.pdf
Legal filing from November 2009 in the case of Jane Doe No. 2 v. Jeffrey Epstein. Epstein's attorneys argue for the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), noting that the DOJ has seized boxes of documents from RRA, including 13 boxes related to Epstein. The document also disputes delays in the deposition of RRA's Chief Restructuring Officer, Herbert Stettin, citing upcoming trial deadlines.
071.pdf
A 2009 legal motion filed in the Southern District of Florida on behalf of Jeffrey Epstein requesting permission to attend mediation in a case involving Carolyn Andriano (C.M.A.). The motion notes that a prior 'no contact order' exists regarding Andriano, but states that neither she nor her counsel object to Epstein's presence at depositions, mediation, or trial. The document includes a comprehensive service list of attorneys involved in multiple related cases against Epstein.
069.pdf
This document is a legal motion filed on November 9, 2009, by Igor Zinoviev, a third-party witness and employee of Jeffrey Epstein, seeking a protective order to prevent or limit his deposition in the civil case 'Jane Doe No. 2 v. Jeffrey Epstein'. Zinoviev claims he has no relevant information for the civil cases as his employment with Epstein began in November 2005, after the period of the alleged misconduct, and he has not discussed Epstein's criminal or civil cases with him.
050.pdf
This document is a Notice of Compliance filed by Jeffrey Epstein's legal team (Burman, Critton, Luttier & Coleman) on July 28, 2009, in the US District Court for the Southern District of Florida. It addresses a court order regarding the preservation of evidence and a protective order, noting that while the parties agreed on many sections, they could not finalize a joint order, leading Epstein to submit his own proposed order separately. The document lists numerous related civil cases involving Jane Doe plaintiffs and provides a comprehensive service list of attorneys involved in the various Epstein-related litigations at that time, including Bruce Reinhart representing Sarah Kellen.
021.pdf
This document is an 'Opposition to Remand Motion' filed by defendants Jeffrey Epstein and Sarah Kellen in September 2008 in the Southern District of Florida. The defendants argue that the case should remain in federal court because the plaintiff fraudulently joined co-defendant Haley Robson (a Florida resident) solely to destroy diversity jurisdiction. The filing contends that the plaintiff has no valid cause of action against Robson for civil conspiracy, intentional infliction of emotional distress (IIED), or civil RICO under Florida law, arguing that Robson's alleged actions do not meet the legal standards for these torts.
019.pdf
Defendant Jeffrey Epstein moves to dismiss Counts I (sexual assault), II (civil conspiracy), and IV (civil RICO) of Jane Doe's amended complaint. The motion argues that the sexual assault claim improperly relies on a criminal statute with no private right of action, the conspiracy claim lacks an actionable underlying tort, and the RICO claim fails to allege a direct injury resulting from a predicate act. The document outlines relevant Florida case law and statutes to support the dismissal of these claims.
017.pdf
This document is a Motion to File Under Seal submitted by defendants Jeffrey Epstein and Sarah Kellen on July 25, 2008, in the case of Jane Doe v. Epstein et al. The defendants request to seal their 'motion for stay' to protect a confidential agreement between Epstein and the U.S. Attorney's Office for the Southern District of Florida. The document includes certificates of compliance and service, noting that the plaintiff opposes the motion, and lists the legal counsel representing all parties involved.
014.pdf
This document is a legal response filed on August 22, 2008, by Jeffrey Epstein's legal team in the case of Jane Doe vs. Jeffrey Epstein, Haley Robson, and Sarah Kellen. Epstein's lawyers state they have no opposition to the plaintiff's Motion to Preserve Evidence (DE 12). However, they dispute the plaintiff's certification of compliance, arguing that plaintiff's counsel filed the motion prematurely without properly conferring with the defense or waiting for a return call regarding Epstein's position.
008.pdf
This document is a motion filed by Jeffrey Epstein's legal team on August 8, 2008, requesting an extension to file a response to the complaint in the case of Jane Doe #1. Epstein's lawyers argue that the deadline should be aligned with parallel cases (Jane Doe Nos. 2-5) to September 4, 2008, to promote judicial economy. The document notes that co-defendants Haley Robson and Sarah Kellen had not yet been served at the time of filing.
008-01.pdf
A court order from the United States District Court for the Southern District of Florida in the case of Jane Doe #1 vs. Jeffrey Epstein, Haley Robson, and Sarah Kellen. Judge Kenneth A. Marra grants the Defendant's Motion to Align Response Date. Copies were furnished to several attorneys including Bruce Reinhart and Jack Goldberger.
003.pdf
This document is a Motion for Enlargement of Time filed on July 25, 2008, in the Southern District of Florida civil case Jane Doe v. Jeffrey Epstein, et al. Defendants Epstein and Sarah Kellen request an extension to answer the complaint until 10 days after a decision is made on their contemporaneous motion to stay the case, citing 18 U.S.C. § 3509 regarding civil stays during parallel criminal proceedings involving child victims. The document includes a service list detailing legal representation for all parties, including Bruce Reinhart as counsel for Sarah Kellen.
002.pdf
Defendants Jeffrey Epstein and Sarah Kellen filed a request for oral argument on July 25, 2008, in the Southern District of Florida regarding a motion to stay civil proceedings pending the resolution of a criminal action. The document lists legal representation for all parties, including Jane Doe (Plaintiff) and Haley Robson (Co-Defendant). Attorneys Michael R. Tein and Guy A. Lewis are the primary signatories for Epstein.
001.pdf
This document is a Notice of Removal filed by defendants Jeffrey Epstein, Sarah Kellen, and Haley Robson, seeking to move a civil lawsuit filed by Jane Doe from the Circuit Court of the Fifteenth Judicial Circuit in Palm Beach County, Florida, to the United States District Court for the Southern District of Florida. The defendants argue that the non-diverse defendant, Haley Robson, was fraudulently joined solely to defeat diversity jurisdiction and prevent removal. Attached as Exhibit A is a deposition transcript of Jane Doe (whose name is redacted) taken on February 20, 2008, in a related criminal case, where she is questioned about her age, MySpace profiles, inconsistencies in her statements to police regarding sexual contact with Epstein, and her interactions with various attorneys and law enforcement officials.
001-02.pdf
This document is a summons and affidavit of service related to a lawsuit filed in the 15th Judicial Circuit Court in Palm Beach County, Florida. Jane Doe, represented by her mother, is the plaintiff against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The document details the service of the summons on Sarah Kellen in New York City on April 19, 2008, and includes important legal notices in English, Spanish, and French regarding the lawsuit and the defendant's responsibilities.
001-01.pdf
This document contains the deposition transcript of 'Jane Doe' (a minor victim) dated February 20, 2008, and a Civil Complaint filed by her mother against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The deposition covers Jane Doe's family issues, credibility, drug use allegations, and interactions with law enforcement, while the Complaint details the 'scheme' wherein Robson recruited underage girls for Epstein to sexually abuse under the guise of massages. The document also includes procedural filings regarding service of process on Haley Robson.
005.pdf
This document is a 'Motion to Intervene and Supporting Memorandum of Law' filed on January 29, 2008, in the US District Court for the Southern District of Florida (Case No. 08-80069). Jane Doe's Mother seeks to intervene as a plaintiff in the lawsuit against Jeffrey Epstein, asserting she has claims sharing common questions of law and fact with the existing action. The document notes that Jane Doe's Father (a current plaintiff) does not agree to her intervention.
004.pdf
This is a Motion to Stay Proceedings filed on January 29, 2008, in the US District Court for the Southern District of Florida. Jane Doe's Mother (Intervenor-Plaintiff) requests the court pause the lawsuit against Jeffrey Epstein until Jane Doe No. 1 turns 18 on May 13, 2008. The motion reveals that Jane Doe No. 1 is estranged from her father (who filed the suit) and that the father filed the suit without her knowledge or consent.
016.pdf
This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, seeking a protective order to prevent or limit his deposition in the case of Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, a driver and bodyguard for Epstein since November 2005, claims he has no relevant information regarding Epstein's criminal or civil cases, particularly concerning events prior to September 2005. The motion cites legal precedents regarding the scope of discovery and Federal Rules of Civil Procedure Rule 26(c) to argue against the deposition.
059.pdf
This document is a motion filed on November 20, 2009, in the US District Court for the Southern District of Florida, requesting permission for Jeffrey Epstein to attend mediation in the case involving Carolyn Andriano (C.M.A.). The motion notes that a previous no-contact order exists regarding Andriano, but her counsel has no objection to Epstein attending the deposition, mediation, or trial. The document includes a service list detailing the attorneys involved in this and related cases, including Bruce Reinhart representing Sarah Kellen.
057.pdf
This document is a legal reply filed by Jeffrey Epstein's legal team on November 16, 2009, regarding the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA). The filing notes that the Department of Justice seized approximately 40 boxes of documents from RRA, including 13 boxes specifically related to Epstein cases. The document highlights scheduling conflicts involving the deposition of Herbert Stettin (RRA's Chief Restructuring Officer) and alludes to potential ethical or criminal issues within RRA that could impact the validity of the cases against Epstein.
055.pdf
This document is a Motion for Protective Order filed on November 9, 2009, by Igor Zinoviev, a third-party witness and Jeffrey Epstein's driver/bodyguard since November 2005. Zinoviev seeks to prevent or limit his deposition, arguing he has no knowledge relevant to the civil cases as his employment with Epstein began after the alleged events, and he has not discussed Epstein's criminal or civil cases with him. The motion cites legal precedents on the scope of discovery and includes a list of attorneys involved in various related cases.
082.pdf
This document is a Reply filed by Jeffrey Epstein's legal team in November 2009 requesting a permanent order for the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), which was undergoing restructuring. The filing highlights that the Department of Justice had seized approximately 40 boxes of documents from RRA, including about 13 boxes related to Epstein cases, amidst concerns of 'serious ethical and potentially criminal issues' at the firm. The document also argues against delaying the deposition of RRA's Chief Restructuring Officer, Herbert Stettin, citing upcoming trial deadlines.
080.pdf
This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, requesting a protective order to prevent his deposition in the case Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, who worked as a driver and bodyguard for Epstein since November 2005, argues he has no relevant information for the civil cases as his employment began after the alleged events and he never discussed the criminal or civil cases with Epstein.
064.pdf
This document is a 'Notice of Compliance' filed on July 28, 2009, by Jeffrey Epstein's legal team in the U.S. District Court for the Southern District of Florida. It pertains to multiple civil cases filed by 'Jane Doe' plaintiffs against Epstein. The filing states that while the court ordered the parties to agree on a preservation of evidence order, they were unable to reach a full agreement, leading Epstein to submit his own proposed order. The document includes a comprehensive service list detailing the attorneys representing the various plaintiffs and defendants, including Sarah Kellen.
Jane Doe v. Epstein
Theodore J. Leopold writes to Jack A. Goldberger to express concern over the unethical behavior of Goldberger's co-counsel, who refused to provide copies of exhibits used in a direct examination. Leopold is writing to confirm their agreement that Goldberger will provide the exhibits to him and the State Attorney.
Jane Doe v. Epstein
Theodore Leopold writes to Jack Goldberger to express concern about Goldberger's co-counsel's refusal to provide copies of exhibits to him and the State Attorney during a direct examination. Leopold is writing to confirm Goldberger's agreement to provide the exhibits.
Deposition scheduling
Agreement to schedule deposition for Feb 20, 2008 and accept service
State of Florida v. Jeffrey Epstein, Case No. 2006 CF 009...
Copies of the letter and the enclosed Motion for Protective Order were sent to Lanna Belohlavek and Jack A. Goldberger.
State of Florida v. Jeffrey Epstein, Case No. 2006 CF 009...
A letter enclosing Jane Doe's Motion for Protective Order and requesting ten minutes of the Court's time to present the motion.
Motion for Protective Order
Service of legal documents via Facsimile and U.S. Mail
Notice of Deposition in Case No. 2006CF009454AXX, State o...
A formal legal notice scheduling the telephonic deposition of a redacted individual for February 20, 2008, at the Palm Beach County Courthouse. The notice was sent to the State Attorney's office and another attorney.
Service of Motion
Electronic notice of filing sent via ECF system.
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