Searcy Denney Scarola Barnhart & Shipley, P.A.
OrganizationRelationship Network
017-02.pdf
This document is a legal response filed by Jeffrey Epstein's legal team on October 6, 2009, opposing a Motion to Compel discovery filed by Plaintiff Jane Doe No. 2. Epstein asserts his Fifth Amendment privilege against self-incrimination to refuse the production of photographs of his Palm Beach home (specifically massage rooms), financial records, tax returns, passport/travel records, and medical records from Dr. Stephan Alexander. The defense argues that despite the Non-Prosecution Agreement (NPA), the threat of federal prosecution remains real and substantial, particularly in districts outside the Southern District of Florida, and that the act of producing these documents would be testimonial and incriminating.
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.
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.
036.pdf
A legal filing (Sur-Reply) by Ghislaine Maxwell's attorneys arguing that Plaintiff Bradley Edwards must produce solicitation letters sent to former Epstein employees and their responses. The defense argues Edwards waived work-product privilege by failing to produce a privilege log and that the letters sent to third parties do not constitute work product.
030.pdf
This document is a Civil Docket Report for Case No. 0:16-mc-61262-JG, filed in the U.S. District Court for the Southern District of Florida on June 13, 2016. The case involves Plaintiff Bradley J. Edwards filing a motion to quash a subpoena against Defendant Ghislaine Maxwell. The docket records various motions, including requests to seal exhibits and appear Pro Hac Vice, culminating in an order on December 22, 2016, to transfer the motion to the Southern District of New York to be handled as part of the case Giuffre v. Maxwell (1:15-cv-07433-RWS). The case was terminated in the Florida court on December 23, 2016.
024.pdf
This document is a legal notice filed by Ghislaine Maxwell's attorneys on December 16, 2016, in the Southern District of Florida regarding a subpoena served on Bradley J. Edwards. Maxwell argues that rulings made by the Southern District of New York on a similar subpoena served on Paul Cassell (another attorney for Virginia Giuffre) should be binding (res judicata) on the Edwards subpoena. The filing includes a table comparing the requests in both subpoenas and the corresponding rulings from the SDNY court, asking the Florida court to issue a consistent order requiring production of certain documents and granting the motion to quash for others.
023.pdf
This document is a formal notice filed on December 16, 2016, in the Southern District of Florida, by attorneys for Ghislaine Maxwell. It informs the court and opposing counsel (specifically Bradley J. Edwards' attorney Jack Scarola) that 'Exhibit B' related to a subpoena status notice has been filed under seal. The underlying case referenced is Virginia L. Giuffre v. Ghislaine Maxwell in the Southern District of New York.
022.pdf
This document is a motion filed on December 16, 2016, by Ghislaine Maxwell's attorneys in the Southern District of Florida. The motion requests permission to file 'Exhibit B' under seal, noting that the exhibit is a sealed order from the Southern District of New York in the underlying 'Giuffre v. Maxwell' case. The document lists legal counsel for Maxwell and for Bradley J. Edwards, who is the subject of a subpoena in this miscellaneous action.
015.pdf
This document is a Motion to Seal filed on July 7, 2016, by attorney Jack Scarola on behalf of Bradley J. Edwards in the U.S. District Court for the Southern District of Florida. Edwards seeks to seal exhibits attached to his Motion to Quash a subpoena, specifically referencing confidential depositions of Ghislaine Maxwell and Rinaldo Rizzo, as well as documents related to Alan Dershowitz, which are already under seal in the Southern District of New York. The motion argues that sealing is necessary to comply with protective orders from the underlying case.
013.pdf
This document is a reply filed by Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell in the case of Giuffre v. Maxwell. Edwards argues that the subpoena imposes an undue burden on him as a non-party and opposing counsel, seeking information that is already in Maxwell's possession, privileged, irrelevant, or available from other sources. The brief details the history of related litigation, including the CVRA case and a defamation suit against Alan Dershowitz, to support the argument that the subpoena is harassing and unnecessary.
013-02.pdf
This document is a Notice of Withdrawal of Motion for Partial Summary Judgment filed on April 8, 2016, in a Florida Circuit Court case between Bradley J. Edwards/Paul G. Cassell and Alan M. Dershowitz. The plaintiffs withdraw their motion pursuant to a confidential settlement agreement but explicitly state that their client, Virginia Giuffre, reaffirms her allegations and that the withdrawal is not an admission that her allegations were mistaken. They concede that filing certain allegations in a separate Crime Victims' Rights Act case was a 'tactical mistake' that caused distractions.
012.pdf
This document is a motion filed on July 7, 2016, in the Southern District of Florida by attorney Jack Scarola on behalf of Bradley J. Edwards. Edwards requests permission to file a reply exceeding the standard page limit (up to 25 pages) in support of his motion to quash a subpoena served by Ghislaine Maxwell. The motion explains that the extra length is necessary to address allegations made by Maxwell regarding Edwards' prior filings and alleged discovery withholding by his client, Virginia Giuffre.
010.pdf
Declaration by Jeffrey S. Pagliuca, attorney for Ghislaine Maxwell, filed on June 30, 2016, in the Southern District of Florida. The document lists 18 exhibits (A-R) supporting Maxwell's opposition to Bradley J. Edwards' motion to quash a subpoena. Several exhibits are filed under seal, while others include procedural documents from related cases (Cassell v. Dershowitz, Epstein v. Rothstein, Jane Doe v. US) and communications regarding discovery and subpoenas.
010-05.pdf
This document is a civil complaint filed on January 6, 2015, in Broward County, Florida, by attorneys Bradley J. Edwards and Paul G. Cassell against Alan M. Dershowitz. The plaintiffs allege that Dershowitz defamed them in media interviews (specifically on CNN) by accusing them of misconduct and lying after they filed court pleadings alleging Dershowitz participated in Jeffrey Epstein's criminal conduct. The complaint asserts that Dershowitz's statements were false, malicious, and intended to distract from his own alleged involvement in Epstein's crimes and the negotiation of Epstein's non-prosecution agreement.
007.pdf
This document is a 'Notice of Filing' submitted to the U.S. District Court for the Southern District of Florida on June 29, 2016. It serves to notify the court and opposing counsel that Defendant Ghislaine Maxwell has filed Exhibits A, G, H, I, and N under seal. These exhibits are attached to a declaration by her attorney, Jeffrey S. Pagliuca, in support of her opposition to Bradley J. Edwards' motion to quash a subpoena.
006.pdf
This document is a motion filed on June 29, 2016, by attorneys for Ghislaine Maxwell in the Southern District of Florida. The motion requests permission to file specific exhibits (A, G, H, I, and N) under seal because they were designated as confidential in the underlying case (Giuffre v. Maxwell) in the Southern District of New York. The document includes a certificate of service indicating the motion was served electronically to attorney Jack Scarola representing Bradley J. Edwards.
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.
001-01.pdf
Legal declaration by attorney Bradley J. Edwards filed on June 13, 2016, in support of a motion to quash a subpoena from Ghislaine Maxwell. Edwards details his representation of Virginia Giuffre and the undue burden of reviewing over 200,000 emails for communications with journalists. He explicitly states that Ghislaine Maxwell and Jeffrey Epstein share a joint defense agreement and mentions Giuffre's association with the organization 'Victims Refuse Silence, Inc.'
073.pdf
This document is a legal response filed on November 28, 2009, by Plaintiff Carolyn M. Andriano (Jane Doe No. 2) in her civil case against Jeffrey Epstein. The filing opposes a motion by third-party witness Igor Zinoview—Epstein's driver, bodyguard, and trainer since November 2005—who sought to avoid being deposed by claiming he had no knowledge of relevant facts. The Plaintiff argues that Zinoview must be deposed because he worked for Epstein during the active Palm Beach Police investigation (2005-2006) and likely possesses knowledge regarding activities at the Epstein residence, especially since Epstein himself invoked the Fifth Amendment.
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.
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.
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