Palm Beach County, Florida
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020.pdf
This document is the Plaintiff's Memorandum of Law in Opposition to Defendant Epstein's Motion to Dismiss in a civil case. The Plaintiff argues that the federal court has jurisdiction alongside state claims, that the 2006 amendments to 18 U.S.C. §2255 regarding damages should apply retroactively or are procedural, and that interstate commerce requirements were met via phone calls made by co-defendant Sarah Kellen from a New York number. The document details specific dates of solicitation between 2003 and 2005 and alleges a conspiracy involving Epstein, Kellen, and Haley Robson to procure minors for 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.
013-02.pdf
This document is a Clerk's Notice of Reassignment from the Circuit Court of the Fifteenth Judicial Circuit in Palm Beach County, Florida, dated April 10, 2009. It notifies parties in the case of Jane Doe II vs. Jeffrey Epstein (Case ID: 502008CA020614XXXXMB) that the case has been reassigned from Judge Diana Lewis to Judge Donald W. Hafele. The document lists attorneys Robert Critton Jr, Michael Pike, Isidro Garcia, and Jack Goldberger on the distribution list.
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.
005.pdf
This document is a court order from March 30, 2009, in the case of Jane Doe II vs. Jeffrey Epstein and Sara Kellen (Case No. 09-80469-CIV-MARRA) in the Southern District of Florida. Judge Kenneth A. Marra orders counsel to confer and file a joint scheduling and discovery report pursuant to Federal Rules of Civil Procedure. The order outlines specific deadlines for pretrial discovery planning and scheduling conferences.
026.pdf
This document is an October 2008 court order granting a motion to remand the civil case 'Jane Doe v. Jeffrey Epstein, Haley Robson, and Sarah Kellen' back to state court. The federal judge ruled that the plaintiff had valid state-law claims (civil conspiracy, etc.) against defendant Haley Robson, a Florida resident, meaning her inclusion in the lawsuit was not 'fraudulent joinder' intended solely to defeat federal diversity jurisdiction. The order details the plaintiff's allegations that Robson recruited her at age 14 from Loxahatchee, Kellen managed the encounter, and Epstein sexually abused her at his Palm Beach mansion.
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.
012-01.pdf
This document is a 2008 legal motion filed by Jeffrey Epstein's attorney requesting the return of property seized by the Palm Beach Police Department during the October 20, 2005, raid on Epstein's home at 358 El Brillo Way. Attached to the motion are six pages of police property receipts detailing the evidence confiscated, which includes multiple 'massage tables,' phone message books, computers, surveillance-style equipment described as 'Soap on Rope' found in bathrooms, and explicit materials including a 'black framed photo of nude girl' and pornographic videotapes found in the Master Bedroom. The inventory also lists a school transcript for an individual named Alexander Hall found in the Master Bedroom desk.
001.pdf
This document is a Notice of Removal filed by defendants Jeffrey Epstein, Sarah Kellen, and Haley Robson, seeking to move a civil lawsuit filed by Jane Doe from the Circuit Court of the Fifteenth Judicial Circuit in Palm Beach County, Florida, to the United States District Court for the Southern District of Florida. The defendants argue that the non-diverse defendant, Haley Robson, was fraudulently joined solely to defeat diversity jurisdiction and prevent removal. Attached as Exhibit A is a deposition transcript of Jane Doe (whose name is redacted) taken on February 20, 2008, in a related criminal case, where she is questioned about her age, MySpace profiles, inconsistencies in her statements to police regarding sexual contact with Epstein, and her interactions with various attorneys and law enforcement officials.
010.pdf
This is a Final Order of Dismissal from the United States District Court, Southern District of Florida, dated February 28, 2008. The case (08-80069-CIV-MARRA/JOHNSON) involves Jane Doe No. 1 and family members as Plaintiffs against Jeffrey Epstein as Defendant. Judge Kenneth A. Marra dismissed the case without prejudice and denied all pending motions as moot following the Plaintiff's Notice of Voluntary Dismissal.
007-01.pdf
This document is a 'Custodial Parent Modification' agreement and subsequent court order from 2006 between Dawn Lavogue-Sandberg and her former husband (name redacted, but signature matches Jeffrey Epstein). The agreement grants full parental custody of their two minor children to the Former Husband, who resides in Florida, while the Former Wife resides in Georgia. The Former Husband assumes all financial responsibility for the children, including medical care and college tuition.
003.pdf
This document is a court order from the U.S. District Court for the Southern District of Florida in the case of Jane Doe No. 1 vs. Jeffrey Epstein (Case No. 08-80069-CIV-MARRA). Dated January 28, 2008, Judge Kenneth A. Marra orders counsel to confer and file a joint scheduling and discovery report. It outlines procedural deadlines for pretrial discovery and scheduling conferences pursuant to Federal Rules of Civil Procedure.
019.pdf
A court order from the United States District Court for the Southern District of Florida in the case of Jane Doe No. 103 vs. Jeffrey Epstein (Case No. 10-80309-CIV-MARRA). Judge Kenneth A. Marra orders counsel to confer, file a joint scheduling report, and file a joint discovery report, outlining specific deadlines and procedural rules for the pretrial phase.
029-01.pdf
This document is the 'Order of Community Control I' and sentencing disposition for Jeffrey Epstein in the State of Florida (Palm Beach County) for the charge of procuring a person under age 18 for prostitution. Dated June 30, 2008, it sentences Epstein to six months in county jail followed by 12 months of community control, mandating sex offender registration, DNA submission, and no unsupervised contact with minors. It also details financial penalties totaling $473.00 and specific supervision conditions including electronic monitoring and a curfew.
018.pdf
This document is a court order dated May 14, 2009, from the Southern District of Florida, consolidating eleven separate civil cases against Jeffrey Epstein for the purposes of discovery and procedural motions. Judge Kenneth A. Marra designates 'Jane Doe No. 2 v. Epstein' as the lead case for filings and sets strict limits on depositions to prevent duplication, ruling that defendants and common witnesses may be deposed only once across all cases. The order aims to improve judicial economy and efficiency in handling the multiple lawsuits filed by various Jane Does and other plaintiffs.
010.pdf
This document is an unopposed motion filed on October 24, 2019, in the Southern District of New York by attorney Andrew S. Buzin. The motion seeks the admission of Florida attorney Laura J. Starr *pro hac vice* to represent the Plaintiff, Jane Doe 17, in her lawsuit against the Estate of Jeffrey Epstein and associated entities. The filing includes Starr's declaration, a certificate of good standing from the Florida Supreme Court, and a proposed order. Defense counsel Bennet Moskowitz stated that the Defendants do not oppose the motion.
009.pdf
This is an unopposed motion filed in the U.S. District Court for the Southern District of New York by Andrew S. Buzin to admit Laura J. Starr pro hac vice as counsel for the plaintiff, Jane Doe 17. The document includes a declaration by Laura J. Starr confirming her good standing with the Florida Bar and lack of disciplinary history, a certificate of service, and a certificate of good standing from the Florida Bar.
001.pdf
This is a legal complaint filed against Jeffrey Epstein by a plaintiff identified as C.L. The complaint alleges sexual assault and abuse of a minor and details the defendant's ownership of a residence in Palm Beach, Florida, and his current citizenship in the U.S. Virgin Islands.
EFTA00018698.pdf
This document is a printed screenshot from the Palm Beach County School District's Student Information System, dated July 19, 2021. It displays the enrollment history of an unnamed (redacted) student spanning from 1990 to 2002. The record includes codes for entry types such as 'Original Entry of Adult' and 'Re-entry from another school same district,' alongside corresponding drop dates and withdrawal codes.
EFTA00016315.pdf
This document is a formal letter dated September 14, 2020, from the Office of the State Attorney in Palm Beach County (David Aronberg) to an Assistant US Attorney in the Southern District of New York. It confirms the fulfillment of an agency request received on September 3, 2020, for the entire un-redacted investigation and prosecution files concerning Jeffrey Epstein. The transfer includes 4,421 pages of documents, 43 audio files, 6 video files, and 'Case Relationships' data, provided electronically via a CIP portal.
EFTA00014615.pdf
A legal opinion letter from attorney H. Dohn Williams Jr. to the U.S. Attorney's Office explaining the specific legal mechanisms Jeffrey Epstein used to avoid indefinite civil commitment under Florida's Jimmy Ryce Act. The author details how serving time in county jail rather than state prison was a deliberate loophole used to bypass the Act, a loophole that was closed in 2014. The letter asserts that 'money, powerful friends,' and the cooperation of the U.S. Attorney, State Attorney, and Sheriff's Office facilitated this unique arrangement.
EFTA00014077.pdf
This document is the Government's response to a victim's emergency petition under the Crime Victims' Rights Act (CVRA). The Government argues that because no federal charges were filed against Epstein (no 'court proceeding'), the CVRA rights did not fully attach in the way the petitioner claims. The document details the timeline of the 2006-2008 investigation, the negotiations for the Non-Prosecution Agreement (NPA), and the Government's 'best efforts' to notify victims' counsel (Brad Edwards) of the state plea hearing on June 27, 2008. It defends the secrecy of the negotiations as necessary to prevent Epstein from impeaching victim witnesses and to secure a provision allowing victims to sue under 18 U.S.C. § 2255.
EFTA00014046.pdf
This document is the Non-Prosecution Agreement (NPA) between the United States and Jeffrey Epstein, dated September 24, 2007, along with an Addendum dated October 29, 2007. In exchange for pleading guilty to state prostitution charges and serving a recommended 18-month county jail sentence (plus probation), the federal government agreed not to prosecute Epstein for federal crimes. Crucially, the agreement grants immunity to 'potential co-conspirators' (names redacted) and stipulates that the agreement would not be made part of the public record.
EFTA00013989.pdf
This document is a letter from Kenneth Starr to a high-ranking DOJ official arguing against the federal prosecution of Jeffrey Epstein. Starr alleges significant prosecutorial misconduct, including violations of the Non-Prosecution Agreement (NPA), leaks to the New York Times, and conflicts of interest within the US Attorney's Office. He claims the prosecution is politically motivated by Epstein's ties to Bill Clinton and requests a 'de novo' independent review of the case.
EFTA00013976.pdf
This document is a legal petition filed on July 7, 2008, by attorney Brad Edwards on behalf of 'Jane Doe,' a victim of Jeffrey Epstein. The petition seeks to enforce Doe's rights under the Crime Victims' Rights Act (CVRA), specifically asserting that the US Attorney's Office failed to confer with her regarding ongoing plea negotiations with Epstein. The filing details that Epstein had already pleaded guilty to state charges on June 30, 2008, and argues that the federal government was on the verge of finalizing a plea deal without victim input.
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