Richard H. Willits
PersonRelationship Network
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.
013.pdf
This document is a legal notice filed on May 20, 2009, in the U.S. District Court for the Southern District of Florida, involving multiple consolidated cases against Jeffrey Epstein. Plaintiff C.M.A. formally withdraws her objections to Epstein's motion to identify her by her legal name in the case style and in third-party subpoenas, rendering the motion to dismiss moot, though she continues to object to dismissal on alternative grounds. The document lists numerous 'Jane Doe' plaintiffs and provides a service list of attorneys representing both the plaintiffs (Jack Scarola, Jack P. Hill) and the defendant (Richard Willits, Robert Critton, Jack Goldberger, Bruce Reinhart).
080.pdf
This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, requesting a protective order to prevent his deposition in the case Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, who worked as a driver and bodyguard for Epstein since November 2005, argues he has no relevant information for the civil cases as his employment began after the alleged events and he never discussed the criminal or civil cases with Epstein.
023.pdf
This document is a 'Notice of Filing Withdrawal of Previously Raised Objections' filed on May 20, 2009, in the US District Court for the Southern District of Florida. Plaintiff C.M.A. withdraws her objections to Jeffrey Epstein's motion to compel her to identify herself by her legal name in the case style and third-party subpoenas, though she maintains her objection to the case being dismissed sua sponte. The document lists numerous related cases involving Jane Doe plaintiffs and provides a service list of attorneys involved.
EFTA00023624.pdf
This document is a Plaintiff's Notice of Serving Second Amended Answers to Interrogatories in a 2009 civil case against Jeffrey Epstein in the Southern District of Florida. The plaintiff, whose name is redacted, details her residence history and her interactions with Epstein between 2002 and 2003, stating she visited his Florida home roughly twice a week to provide massages after being introduced by a friend. The document reveals she recruited other females for Epstein in exchange for payment, used drugs (Morning Glory, Angel Trumpets, cocaine, marijuana) during the relevant period, and lists various legal counsel and law enforcement entities involved in the investigation.
DOJ-OGR-00015189.tif
This document is a legal pleading detailing accusations against Sarah Kellen for aiding and abetting Jeffrey Epstein's sexual abuse of a minor Plaintiff. It describes Kellen's actions including arranging for the Plaintiff to provide 'massages' to Epstein, escorting her, paying her, arranging gifts, and taking nude photographs of the Plaintiff at Epstein's request. The Plaintiff seeks damages in excess of fifteen thousand dollars and demands a jury trial for the severe mental and emotional trauma suffered.
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