Southern District of Florida
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066.pdf
This document is a Government Memorandum filed on July 29, 2025, in the Southern District of New York, responding to Court Orders regarding the unsealing of grand jury transcripts in the Jeffrey Epstein and Ghislaine Maxwell cases. The Government supports the disclosure of these transcripts due to significant public interest, noting that Epstein is deceased and Maxwell is incarcerated, but requests redactions to protect victim identities. The memo analyzes the 'In re Craig' factors for unsealing grand jury records and confirms that the key law enforcement witnesses are still active.
061.pdf
This document is a motion filed on July 18, 2025, by U.S. Attorney General Pamela Bondi and Deputy AG Todd Blanche, requesting the U.S. District Court for the Southern District of New York to unseal grand jury transcripts related to Jeffrey Epstein. The motion follows a July 6, 2025, DOJ/FBI memorandum that concluded a review of Epstein's case found no evidence to predicate investigations into uncharged third parties. Citing significant public interest and historical importance, the government argues for transparency while ensuring victim identities remain redacted.
018.pdf
This document is a transcript of a court conference held on July 8, 2019, in the Southern District of New York regarding the case U.S. v. Jeffrey Epstein. The proceedings cover the scheduling of bail hearings, the government's confirmation of its obligation to notify victims, and preliminary arguments regarding the 2007/2008 Florida Non-Prosecution Agreement (NPA). The defense argues the NPA bars this prosecution, while the government asserts the NPA does not bind the Southern District of New York and that the current indictment involves separate conduct and victims.
061.pdf
This document is a Supplemental Appendix filed by Palm Beach Newspapers, Inc. in a Florida state court case involving Jeffrey Epstein. It contains a transcript of a June 2009 hearing regarding the unsealing of court records, administrative orders, case law, and federal court filings including a declaration by AUSA A. Marie Villafana regarding the federal Non-Prosecution Agreement (NPA). The appendix documents the legal arguments surrounding the transparency of the Epstein proceedings and the government's interaction with victims under the Crime Victims' Rights Act.
20250728111721067_24-1073ReplyInSupportOfPetitionForWritO...
This document is a legal reply brief filed in the Supreme Court on behalf of Ghislaine Maxwell (Petitioner) against the United States, dated July 28, 2025. The brief argues that the Non-Prosecution Agreement (NPA) signed by Jeffrey Epstein in the Southern District of Florida, which promised not to prosecute 'potential co-conspirators' in 'the United States,' should legally bind other districts like the Southern District of New York. The filing highlights a circuit split on whether US Attorneys can bind other districts and contends that the Second Circuit's decision allowing Maxwell's prosecution violates contract law and the plain text of the agreement.
20250714161434468_24-1073_Maxwell_Opp.pdf
This document is a legal brief filed by the United States Solicitor General in July 2025 opposing Ghislaine Maxwell's petition for a writ of certiorari to the Supreme Court. The government argues that the 2007 Non-Prosecution Agreement (NPA) signed by Jeffrey Epstein in Florida does not bar the Southern District of New York from prosecuting Maxwell, as the agreement was contractually limited to the Florida district and Maxwell was not a party to it. The brief details the history of the Epstein investigation, the terms of the NPA, and relevant legal precedents regarding the scope of plea agreements binding different US Attorney's Offices.
20250117133905126_22-1426.pdf
This document is a formal legal opinion from the United States Court of Appeals for the Second Circuit affirming the conviction and 240-month prison sentence of Ghislaine Maxwell for sex trafficking and related offenses. The court rejected Maxwell's appeal on five grounds, including arguments regarding a non-prosecution agreement, statute of limitations, juror misconduct, jury instructions, and sentencing reasonableness. The document also includes a subsequent order from November 2024 denying Maxwell's petition for panel rehearing or rehearing en banc.
022.pdf
This document is a legal motion filed on November 23, 2010, in the United States District Court for the Southern District of Florida (Case 9:10-CV-81111-WPD). Attorney Bradley J. Edwards requests the court to admit Paul G. Cassell (a member of the Utah Bar) to appear pro hac vice as co-counsel for the plaintiff, identified as M.J., in a civil suit against Jeffrey Epstein and Sarah Kellen. The document documents the payment of a $75 admission fee and lists the defense counsel for Jeffrey Epstein from the firm Fowler White Burnett PA.
020.pdf
This document is a Reply in Support of a Motion to Quash Service of Process filed by Jeffrey Epstein's legal team in November 2010. The defense argues that the plaintiff failed to properly serve Epstein because the papers were left with an individual named 'Mark' at Epstein's New York home (9 East 71st St), but the plaintiff failed to prove 'Mark' resided there or was of suitable discretion. The filing also seeks to strike allegations regarding obstruction of justice in prior litigation and opposes sanctions against Epstein.
017-20.pdf
This affidavit by attorney Bradley Edwards details difficulties in discovery for a civil case against Jeffrey Epstein (Case 10-81111). It alleges that key witnesses Ghislaine Maxwell and Jean Luc Brunel evaded depositions by falsely claiming to be out of the country. Crucially, it lists specific individuals for whom Epstein paid legal fees to prevent them from testifying against him, explicitly labeling Sarah Kellen as a 'procurer of girls' and Nadia Marcinkova as a 'live-in sex slave', while also identifying his personal pilots and household staff.
017-19.pdf
Plaintiff Jane Doe filed an emergency motion to hold Jeffrey Epstein in contempt for failing to comply with discovery orders in a civil case (08-CV-80893). The motion alleges that Epstein failed to produce state criminal discovery materials and provided only heavily redacted correspondence with the U.S. Attorney's Office, obscuring the defense counsel's side of the communications. Doe seeks immediate production of unredacted documents, sanctions of $5,000 against Epstein's counsel, and a ruling that withheld materials be deemed admissible at trial.
017-18.pdf
This document is a page from a court docket covering filings on June 29 and 30, 2010, in the case of Jane Doe vs. Jeffrey Epstein (Case 9:10-cv-81111-WPD). Key entries include orders by Judge Kenneth A. Marra granting an open trial and identifying Jane Doe, as well as denying Epstein's request to redact tax records. It also lists motions by Epstein's defense regarding jury selection, sequestration, and a request to continue the trial, alongside Plaintiff's motion for a writ regarding witness Alfredo Rodriguez.
017-17.pdf
This document is a Motion for Protective Order filed on June 30, 2010, by Jeffrey Epstein's defense team in the civil case Jane Doe v. Jeffrey Epstein. Epstein seeks permission to redact specific portions of his tax returns regarding investment vehicles, claiming they contain trade secrets and confidential business information. The motion argues that Plaintiff's counsel, Brad Edwards, has a history of sharing discovery material with media and investigators, specifically citing an instance involving Alfredo Rodriguez's journal.
017-14.pdf
Order from the U.S. District Court (S.D. Florida) dated June 25, 2010, denying Jeffrey Epstein's appeal of Magistrate Judge Johnson's discovery orders. Epstein is ordered to produce documents within three days, with specific instructions to redact names of minor sexual assault victims. The order also restricts the Plaintiff from disclosing Epstein's tax returns or passport to third parties, except for expert witnesses bound by confidentiality.
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.
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.
016.pdf
This document is a Motion for a Protective Order filed by plaintiff M.J. on November 11, 2010, requesting the court bar Jeffrey Epstein from direct or indirect contact. The motion details a pattern of Epstein using private investigators to harass and intimidate victims and witnesses, specifically citing an incident on July 1, 2010, where a PI named Thaddeus Knowles followed 'Jane Doe' and flashed lights into her home. It also references Epstein's intimidation of other witnesses including Sarah Kellen, Leslie Groff, and Alfredo Rodriguez, and his history of violating no-contact orders.
016-05.pdf
This document is a motion filed on June 30, 2010, by Plaintiff Jane Doe requesting the modification of a court order regarding an upcoming settlement conference with Jeffrey Epstein. Doe requests that Epstein be kept in a secure, separate room to prevent any contact or intimidation, citing his status as a convicted sex offender and previous incidents where he intimidated victims, specifically Jane Doe No. 4, during court proceedings. The motion references Epstein's 2008 guilty plea and strict no-contact orders issued by both state and federal courts.
015-01.pdf
Affidavit by attorney Bradley Edwards in Case 10-81111 detailing obstruction tactics by Jeffrey Epstein and his associates. The document asserts that Jean Luc Brunel visited Epstein 67 times in jail and that both Brunel and Ghislaine Maxwell evaded depositions by falsely claiming to be out of the country. It explicitly lists Epstein's inner circle (including pilots and household staff like Sarah Kellen and Nadia Marcinkova) and notes that Epstein paid for their legal counsel to control their testimony.
013.pdf
A court order from the U.S. District Court for the Southern District of Florida dated November 8, 2010, in the case of M.J. vs. Jeffrey Epstein and Sarah Kellen. Judge William P. Dimitrouleas denied Jeffrey Epstein's motion to quash service of process without prejudice because the motion failed to comply with local rules requiring a certification of good faith effort to confer with opposing parties.
007-01.pdf
This document is an affidavit by Richard Barnett filed on October 29, 2010, in the case of M.J. v. Jeffrey Epstein and Sarah Kellen in the Southern District of Florida. Barnett testifies that on October 13, 2010, he discovered an unmarked envelope containing legal documents (Summons, Complaint, Civil Rico Statement) in the mailbox of Epstein's home at 9 East 71st Street, NYC. He asserts that service was never personally delivered to anyone at the residence.
001-04.pdf
This document is a 'Summons in a Civil Action' filed in the United States District Court for the Southern District of Florida on September 17, 2010. The case (No. 9:10-cv-81111-WPD) involves plaintiff 'M.J.' suing defendants Jeffrey Epstein and Sarah Kellen. The summons is addressed to Sarah Kellen at an apartment in Palm Beach, FL, instructing her to respond to the complaint within 21 days via plaintiff's attorney Bradley J. Edwards.
001-03.pdf
This document is a Summons in a Civil Action filed in the US District Court for the Southern District of Florida on September 17, 2010. The plaintiff, identified as M.J., is suing Jeffrey Epstein and Sarah Kellen. The document commands Epstein to respond within 21 days and lists Bradley J. Edwards as the plaintiff's attorney. The second page is an unfilled Proof of Service form.
020.pdf
This document is a Motion to Dismiss filed by Jeffrey Epstein's legal team on June 16, 2010, in the case of L.M. v. Epstein. Epstein's lawyers argue the case should be dismissed because the plaintiff failed to serve the complaint within the required 120 days (Rule 4(m)). Furthermore, the motion alleges that the complaint filed by L.M. (represented by Bradley Edwards) was used as a prop in Scott Rothstein's massive $1.2 billion Ponzi scheme to lure investors with fabricated settlement agreements. The document cites depositions where L.M. contradicts allegations made in her complaint regarding sexual acts and travel.
020-01.pdf
This document contains a series of court orders and motions from the case *Morse v. Jan Jones International, Inc.* (Case 9:09-cv-81092-KAM) in the Southern District of Florida. The Plaintiffs, represented by Scott Rothstein, successfully argued that Jan Jones committed fraud and illegally moved funds to the Cayman Islands, resulting in an order for over $23 million in damages and the seizure of assets. The document includes a Stipulated Confidentiality Order and a subsequent Order on Emergency Writ of Mandamus from the 11th Circuit Court of Appeals, which reinstated the District Court's orders and mandated review by the Department of Treasury and FBI due to the sensitive nature of the government's investigation.
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