Southern District of Florida
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017.pdf
This document is a legal notice filed on June 14, 2010, in the United States District Court for the Southern District of Florida, regarding the case of Jane Doe No. 2 v. Jeffrey Epstein. The filing, submitted by attorney Spencer T. Kuvin on behalf of Plaintiff 'C.L.', serves to withdraw a subpoena and cancel the scheduled deposition of Maritza Milagros Vasquez, which was set for the following day, June 15, 2010. The document also includes a certificate of service listing various attorneys representing different parties in related cases against Epstein.
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.
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.
010-01.pdf
This is an Agreed Order from the US District Court for the Southern District of Florida, dated 2009, in the case of Jane Doe No. 2 vs. Jeffrey Epstein. The order grants Epstein permission to attend the deposition, mediation, or trial of Plaintiff Carolyn Andriano (in the related case CMA v. Epstein and Kellen, 08-CIV-80811), explicitly overriding a previous no-contact order [DE 238] for these specific legal proceedings.
004.pdf
A court order from the U.S. District Court for the Southern District of Florida transferring civil case 09-81092 (L.M. v. Jeffrey Epstein) from Judge James I. Cohn to Judge Kenneth A. Marra. The order was signed by Judge Cohn on July 28, 2009, and accepted by Judge Marra on July 29, 2009, citing Internal Operating Procedure 2.15.C.
011.pdf
This document is a legal reply letter dated December 16, 2019, from attorneys representing Alan Dershowitz to Judge Naomi Reice Buchwald. Dershowitz seeks to intervene in the civil case *Maria Farmer v. Estate of Jeffrey Epstein* to strike specific allegations in the complaint he deems scandalous and irrelevant, and to request sanctions against Farmer and her legal team (Boies Schiller Flexner LLP). The letter argues that the allegations against Dershowitz have no bearing on Farmer's claims of battery and emotional distress against the Epstein Estate and are part of a 'campaign of personal animus'.
009.pdf
This document is a letter from Alan Dershowitz's legal counsel to Judge Naomi Reice Buchwald requesting a pre-motion conference to intervene in the civil case 'Maria Farmer v. Estate of Jeffrey Epstein'. Dershowitz seeks to strike paragraph 39 of Farmer's complaint, which alleges she saw him at Epstein's New York mansion going upstairs with young girls brought by Ghislaine Maxwell. Dershowitz argues this allegation is demonstrably false based on chronology (claiming he didn't meet Epstein until after Farmer left) and is legally irrelevant to the estate case, serving only to defame him.
033.pdf
This document is a Reply Memorandum filed by attorney Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell. Edwards argues that Maxwell's requests for his communications with 'prospective witnesses' are overbroad, unduly burdensome, and seek protected attorney work-product. The filing notably alleges that Maxwell has failed to explain her presence on 23 flights with a teenaged Virginia Giuffre or the message pads documenting underage girls calling Epstein's mansion for 'massages'.
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.
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.
010-10.pdf
This document is a Court Order from the Southern District of Florida, dated April 15, 2015, denying Jeffrey Epstein's motion for a supplemental protective order. Epstein sought to keep correspondence between his lawyers and the US Government regarding his non-prosecution agreement sealed from the public. Judge Kenneth Marra ruled that the public interest in determining if the Crime Victims' Rights Act (CVRA) was violated outweighs Epstein's desire for confidentiality, stating that plea negotiations are not privileged.
010-06.pdf
This document is Plaintiff Virginia Giuffre's second amended supplemental response to discovery requests from Defendant Ghislaine Maxwell, dated April 29, 2016. It details Giuffre's legal representation history from 2009 to 2016, listing specific attorneys and cases including actions against Jeffrey Epstein, the US Government, and Alan Dershowitz. The document also contains objections to requests for financial records regarding payments from Epstein or media organizations, asserting attorney-client privilege and irrelevance.
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.
005-02.pdf
This document is a proposed court order filed on June 29, 2016, in the Southern District of Florida, granting attorney Jeffrey S. Pagliuca permission to appear Pro Hac Vice on behalf of Ghislaine Maxwell. The order relates to a subpoena issued to Bradley J. Edwards in connection with the underlying case of Virginia L. Giuffre v. Ghislaine Maxwell. It also establishes electronic filing notifications for Pagliuca and his legal assistant, Nicole Simmons, at the firm Haddon, Morgan and Foreman, P.C.
005-01.pdf
This document is a formal certification filed by attorney Jeffrey S. Pagliuca in the United States District Court for the Southern District of Florida on June 29, 2016. It pertains to a subpoena issued to Bradley J. Edwards in relation to the underlying case of Virginia L. Giuffre v. Ghislaine Maxwell. Pagliuca certifies his compliance with local rules and his good standing with the Colorado bar.
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.
071-01.pdf
This is a United States District Court Agreed Order from November 2009 in the Southern District of Florida. It grants Jeffrey Epstein's motion to attend mediation and explicitly states that a previous no-contact order does not prevent him from attending the deposition, mediation, or trial of Plaintiff Carolyn Andriano. The order references multiple related case numbers.
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.
044.pdf
This document is a Motion to Compel filed on July 10, 2009, in the Southern District of Florida, requesting the court to force Jeffrey Epstein to answer 23 specific requests for admission in a civil suit brought by Jane Doe No. 2. Epstein had previously asserted his Fifth Amendment privilege against self-incrimination to refuse answering questions regarding his net worth (alleged to be over $1 billion), his financial support of modeling agency MC2, his ownership of foreign property, and specific allegations of sexual assault, battery, and sex trafficking of minors. The plaintiff argues that the Fifth Amendment cannot be used as a blanket refusal in a civil case and demands Epstein answer or provide specific justification for his silence.
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.
042.pdf
This document is a Motion to Set Aside Order of Default filed by attorney Bruce E. Reinhart on behalf of defendant Sarah Kellen in the case Jane Doe No. 2 v. Sarah Kellen. Kellen argues that the default judgment entered on June 17, 2009, is invalid because the plaintiff failed to properly serve the summons under New York law (specifically regarding timing of filing the affidavit of service) and because the time for a responsive pleading had not yet expired when the default was entered.
040.pdf
This document is a 'Notice of Reliance' filed on June 19, 2009, in the case of Jane Doe II v. Jeffrey Epstein (Case No. 09-CIV-80469) in the Southern District of Florida. Epstein's legal team informs the court that despite the Plaintiff filing an Amended Memorandum of Law on June 12, 2009, Epstein will not file a new supplemental reply but will instead rely on his previous arguments filed on June 1, 2009. The document outlines the procedural history of the motion to dismiss and includes a certificate of service listing attorneys for both parties.
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.
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