Southern District of Florida
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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.
021.pdf
This document is a Notice of Filing Proposed Order submitted to the U.S. District Court for the Southern District of Florida on May 27, 2009. It lists eleven separate civil cases filed against Jeffrey Epstein by various plaintiffs, including Jane Does 2-7, 101, 102, C.M.A., and Doe II. The filing serves to submit a proposed order related to case no. 08-80119 and includes a service list of attorneys involved in the litigation.
015-01.pdf
This document is a Motion to Stay proceedings filed by Jeffrey Epstein's legal team in a civil case brought by a plaintiff identified as C.M.A. Epstein argues that the civil case should be paused until late 2010, when his Non-Prosecution Agreement (NPA) with federal prosecutors expires, to avoid forcing him to waive his 5th Amendment rights against self-incrimination while facing potential ongoing criminal liability. The filing includes an affidavit from his criminal defense attorney, Jack Goldberger, and an Indictment from 2006 for Felony Solicitation of Prostitution.
013.pdf
This document is a Motion to Dismiss filed by Jeffrey Epstein's defense team in the U.S. District Court for the Southern District of Florida on May 6, 2009, against Plaintiff Jane Doe II. The defense argues that the federal case should be dismissed because a nearly identical state case was filed 10 months prior, and because the plaintiff is improperly applying a 2006 amendment to 18 U.S.C. §2255 retroactively to conduct alleged to have occurred between 2003 and 2005, thereby violating the Ex Post Facto clause. Additionally, the motion argues that the statute does not allow for multiplying damages per incident and that the plaintiff failed to allege the necessary interstate commerce elements required for federal jurisdiction.
007.pdf
This document is an unopposed motion filed on May 1, 2009, in the Southern District of Florida (Case 09-CIV-80469) by Jeffrey Epstein's attorneys requesting a five-day extension to file a response to Jane Doe II's complaint. The extension (until May 6, 2009) was requested because Epstein's counsel, Robert D. Critton, Jr., was preparing for an unrelated state court trial. The document confirms that Plaintiff's counsel, Isidro M. Garcia, agreed to this extension.
006.pdf
This document is a Court Order from the United States District Court Southern District of Florida, dated April 28, 2009, presided over by Judge Kenneth A. Marra. The order grants the Plaintiffs' motion for a protective order against piecemeal depositions, limiting Jeffrey Epstein (Defendant) to a single deposition of each plaintiff across ten related civil cases. It also consolidates four specific cases (08-80119, 08-80232, 08-80380, and 08-80993) for the purposes of discovery and orders parties in the remaining six cases to show cause why they should not also be consolidated.
004.pdf
This document is an Order of Transfer from the United States District Court for the Southern District of Florida, dated March 2009. Judge Kenneth L. Ryskamp transfers the case of Jane Doe II v. Jeffrey Epstein and Sarah Kellen (Case No. 09-80469) to Judge Kenneth A. Marra. The transfer is ordered because the case is related to several lower-numbered cases already assigned to Judge Marra (including 08-80069, 08-80119, etc.).
024-01.pdf
A Proposed Order from the U.S. District Court for the Southern District of Florida in the case of Jane Doe vs. Jeffrey Epstein, Haley Robson, and Sarah Kellen. The document grants the Plaintiff's unopposed motion to extend the deadline for responding to Epstein's Motion to Dismiss until 15 days after a pending motion to remand is decided. The document was entered on the docket on September 18, 2008.
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.
018.pdf
This document is a Motion for Stay filed by defendants Jeffrey Epstein and Sarah Kellen in a civil lawsuit brought by Jane Doe. They argue that a stay is mandatory under federal law because of a pending federal criminal investigation/action (the deferred prosecution agreement). Attached is a declaration from AUSA A. Marie Villafana detailing the government's interaction with victims (T.M., C.W., S.R.) and providing copies of notification letters sent to them and their attorneys regarding their rights and the non-prosecution agreement.
012.pdf
This document is a motion filed on August 21, 2008, by Plaintiff Jane Doe in a civil case against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The plaintiff requests the court to preserve evidence seized by the Palm Beach Police Department from Epstein's home, citing concerns that Epstein (who had recently pleaded guilty and was in jail) was attempting to retrieve the evidence through State Court and might destroy it. The document includes a service list identifying legal counsel for all parties, including Bruce E. Reinhart representing Sarah Kellen.
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.
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.
028.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) in the case Jane Doe No. 2 vs. Jeffrey Epstein (Case No. 08-CV-80119-MARRA/JOHNSON). The memorandum opposes 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 not protected by the Fifth Amendment (citing the 'required records' exception and 'foregone conclusion' doctrine) and are critical for determining punitive damages given the allegations of sexual molestation and Epstein's refusal to provide net worth discovery beyond a stipulation of 'nine figures.'
022-01.pdf
A court order from the Southern District of Florida in the case of Jane Doe No. 8 v. Jeffrey Epstein (Case No. 09-CV-80802). The order grants the Plaintiff's unopposed motion for an extension of time, setting a new deadline of December 14, 2009, to file an Amended Complaint.
006-01.pdf
This document is a Court Order from the United States District Court for the Southern District of Florida, dated July 2009, in the case of Jane Doe No. 8 v. Jeffrey Epstein. Judge Kenneth A. Marra granted Jeffrey Epstein's unopposed motion for an extension of time, setting a deadline of July 14, 2009, for the defendant to file a responsive pleading to the complaint.
007-01.pdf
A court order from the Southern District of Florida in the case of Jane Doe No. 103 vs. Jeffery Epstein (Case No. 10-80309-CIV), entered on March 25, 2010. Judge Kenneth A. Marra granted the Defendant's unopposed motion to exceed the page limitation on his responsive pleading by no more than eight pages.
005-01.pdf
This document is a Civil Docket Report for a case filed on February 23, 2010, in the U.S. District Court for the Southern District of Florida (Case #: 9:10-cv-80309-WJZ). The case involves a 'Sealed Plaintiff' versus a 'Sealed Defandant' regarding personal injury. On March 9, 2010, Judge William J. Zloch signed an order granting the plaintiff's motion to proceed anonymously while unsealing the complaint and other documents.
062.pdf
This document is a motion filed by Jeffrey Epstein's attorneys requesting an extension until December 15, 2009, to respond to a complaint filed by Jane Doe No. 102. The reasons cited for the extension include ongoing resolution negotiations and questions arising from the 'implosion' of the Rothstein Rosenfeldt & Adler, PA firm.
062-01.pdf
A court order from the Southern District of Florida in the case of Jane Doe No. 102 v. Jeffrey Epstein. Judge Kenneth A. Marra grants the defendant's unopposed motion for an extension of time, setting a deadline of December 15, 2009, for Epstein to file a responsive pleading to the complaint.
059-01.pdf
This is an Agreed Order from the US District Court for the Southern District of Florida, dated November 20, 2009. The order grants Jeffrey Epstein permission to attend the deposition, mediation, and trial involving Plaintiff Carolyn Andriano (referred to as CMA in the related case title), explicitly stating that a previous 'no contact order' does not preclude his attendance at these legal proceedings.
053-01.pdf
This document is a Court Order from the Southern District of Florida dated October 29, 2009, in the case of Jane Doe No. 102 v. Jeffrey Epstein. Judge Kenneth A. Marra granted Epstein's unopposed motion for an extension of time, setting a new deadline of November 16, 2009, for the defendant to file a responsive pleading to the complaint.
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