Theodore Jon Leopold
PersonRelationship Network
016-02.pdf
This document is a Motion for No-Contact Order filed by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein in the Southern District of Florida on May 22, 2009. The plaintiffs argue that despite a state plea agreement prohibiting contact, Epstein's counsel refused to confirm he would not contact federal victims. The filing includes exhibits of correspondence between attorneys and a transcript of the 2008 plea conference where Judge Pucillo explicitly defined 'indirect contact' to include Facebook and MySpace.
032.pdf
This document is a legal reply filed on June 4, 2009, by Plaintiffs Jane Doe No. 101 and 102 in the US District Court for the Southern District of Florida. The plaintiffs are requesting a court order prohibiting Jeffrey Epstein and his agents from contacting them directly or indirectly, citing his status as a convicted sex offender and their fear of intimidation. The document also includes a service list detailing the legal representation for various parties, including Bruce E. Reinhart representing co-defendant Sarah Kellen.
027.pdf
This document is a Motion for Leave to File Under Seal submitted on May 29, 2009, by attorneys for Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida. The plaintiffs request permission to file their response to Epstein's Motion to Stay under seal, or alternatively, request the court to unseal the Non-Prosecution Agreement (NPA) so they can adequately respond. The document includes a comprehensive service list detailing attorneys representing Epstein, co-defendant Sarah Kellen (represented by Bruce Reinhart), and various other Jane Doe plaintiffs.
025.pdf
This document is a legal reply filed on May 29, 2009, by Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida, arguing for the right to proceed anonymously in their lawsuit against Jeffrey Epstein. The plaintiffs contend that Epstein aims to reveal their identities to harass and intimidate them, and they cite various legal precedents and the Non-Prosecution Agreement (NPA) to support their request for privacy due to the sexual nature of the crimes committed against them as minors. The document also includes a service list detailing the attorneys representing various parties in related cases against Epstein.
016-01.pdf
This document contains a Proposed Order and an Unopposed Motion for Enlargement of Time filed by Plaintiff Jane Doe in a civil case against Jeffrey Epstein, Haley Robson, and Sarah Kellen (Case No. 08-80804). Filed on August 13, 2008, the motion requests an extension to file a Civil RICO Case Statement until after the court rules on an upcoming motion to remand the case back to state court. The plaintiff argues the case was improperly removed to federal court and lacks federal jurisdiction. The document includes a service list identifying legal counsel for all parties, including Bruce Reinhart representing Sarah Kellen.
009.pdf
This document is a Notice of Voluntary Dismissal Without Prejudice filed on February 22, 2008, in the U.S. District Court for the Southern District of Florida (Case No. 08-80069). The plaintiffs (Jane Doe No. 1 and her parents) voluntarily dismissed their action against Jeffrey Epstein. The document includes a certificate of service indicating that notice was sent electronically to attorney Theodore Jon Leopold and by mail to Jeffrey Epstein at his New York residence.
008.pdf
This document is a Notice of Non-Opposition filed on February 14, 2008, in the case of Jane Doe No. 1 et al. v. Jeffrey Epstein in the Southern District of Florida. The plaintiffs (Jane Doe No. 1, her father, and stepmother) inform the court that they do not oppose the motion to intervene filed by Jane Doe's mother. The document lists the attorneys representing the plaintiffs from the firm Herman & Mermelstein, P.A.
007.pdf
This document is a legal memorandum filed on February 13, 2008, by the attorneys for Jane Doe No. 1 and her father in the case against Jeffrey Epstein (Case No. 08-80069). The plaintiffs oppose a motion filed by Jane Doe's mother, Dawn LaVogue Sandberg, who sought to stay the proceedings until the minor plaintiff reached the age of majority. The plaintiffs argue that the mother's motion is procedurally defective, was not properly served on the defendant (Epstein), and that the mother lacks standing because the father has full legal custody of the child. The document emphasizes that the lawsuit concerns the sexual assault of Jane Doe No. 1 by Epstein when she was 14 years old.
020.pdf
This document is an agreed motion filed on May 13, 2010, in the Southern District of Florida by Plaintiff Jane Doe No. 103 against Defendant Jeffrey Epstein. The plaintiff requests a one-week extension to file a response to Epstein's motion to dismiss because the parties are in the process of resolving the matter via settlement, which would render the motion moot. The document includes a comprehensive service list detailing legal counsel for Epstein, Co-Defendant Sarah Kellen (represented by Bruce Reinhart), and plaintiffs in several related cases.
016.pdf
This document is an agreed motion for an extension of time filed on April 22, 2010, in the case of Jane Doe No. 103 vs. Jeffrey Epstein (Case No. 10-80309-WJZ). Plaintiff's counsel, Katherine W. Ezell, requests an extension until May 13, 2010, to file a response to Epstein's motion to dismiss because she is leaving for a vacation in Italy the following day. The motion notes that Epstein's counsel, Robert Critton, agrees to the extension, and the document includes a service list of attorneys involved in this and related cases.
012.pdf
This document is a Motion to Transfer filed on April 1, 2010, by Plaintiff Jane Doe No. 103 in the US District Court, Southern District of Florida. The plaintiff seeks to transfer her case against Jeffrey Epstein to Judge Marra's division to consolidate it with other similar pending cases, specifically 'Jane Doe No. 2 vs. Jeffrey Epstein'. The document includes a service list detailing legal counsel for Epstein, co-defendant Sarah Kellen (represented by Bruce Reinhart), and plaintiffs in several related cases.
024.pdf
This document is a legal motion filed on May 29, 2009, in the Southern District of Florida by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein. The plaintiffs request leave to file their response to Epstein's motion to stay under seal because it references the confidential Non-Prosecution Agreement (NPA), or alternatively, to unseal the NPA. The document includes a comprehensive service list detailing the legal representation for Epstein (including Robert Critton and Jack Goldberger), Sarah Kellen (represented by Bruce Reinhart), and numerous other Jane Doe plaintiffs.
022.pdf
This document is a legal reply brief filed on May 29, 2009, by Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida. The plaintiffs seek to proceed anonymously in their lawsuit against Jeffrey Epstein, arguing that revealing their identities would subject them to harassment, shame, and further trauma, particularly given their status as victims of sexual exploitation as minors. The filing also discusses the Non-Prosecution Agreement (NPA), statutory minimum damages under 18 U.S.C. ยง 2255, and accuses Epstein of using the threat of publicity to intimidate victims into settling.
016.pdf
This document is a Motion for an Order for the Preservation of Evidence filed by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein in May 2009. The motion requests the court to order Epstein to preserve evidence related to allegations of sexual abuse, specifically citing evidence seized during a 2005 police search and other electronic/physical records located across his six international properties. The document lists numerous attorneys involved in related cases and references Epstein's previous guilty plea in 2008.
038.pdf
This document is a Motion to Reschedule Hearing filed on May 29, 2009, in the United States District Court for the Southern District of Florida. Attorney Robert C. Josefsberg, representing Plaintiffs Jane Doe 101 and 102, requests to move a hearing scheduled for June 12, 2009, because he will be attending his 50th College Reunion in Hanover, New Hampshire. The document includes a comprehensive service list detailing the legal teams associated with Jeffrey Epstein, Sarah Kellen, and various plaintiffs in related cases.
035.pdf
This document is a legal reply filed on May 29, 2009, in the US District Court for the Southern District of Florida by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein. The plaintiffs argue for the right to proceed anonymously, citing fears of harassment, public humiliation, and Epstein's alleged intent to intimidate victims by exposing their identities. The document lists numerous related cases and provides a service list of attorneys representing various parties, including Bruce Reinhart representing co-defendant Sarah Kellen.
010.pdf
This document is a 'Notice of Striking Docket Entry' filed on May 4, 2009, in the United States District Court for the Southern District of Florida, case Jane Doe No. 101 v. Jeffrey Epstein. The plaintiff's counsel, Katherine W. Ezell of Podhurst Orseck, P.A., notifies the court that a previous docket entry was filed without a signature and has been re-filed correctly. The document includes a Certificate of Service listing numerous attorneys involved in this case and related cases against Epstein, including Bruce Reinhart (defense), Jack Scarola, and Brad Edwards.
008.pdf
This document is a legal response filed by Plaintiff Jane Doe 101 in the United States District Court for the Southern District of Florida on May 1, 2009. The plaintiff agrees to the court's order to consolidate ten separate cases filed by various Jane Does and C.M.A. against Jeffrey Epstein for the purposes of discovery. The document includes a service list detailing the contact information for attorneys representing the various plaintiffs and the defendant.
Notice of Electronic Filing
Service of Notice of Voluntary Dismissal
Plaintiffs' Notice of Non-Opposition to Motion to Intervene
Service of the legal notice via CM/ECF system.
Plaintiffs' Memorandum of Law in Opposition to Motion to ...
Service of court document via CM/ECF.
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