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080.pdf
This document is a Stipulation of Dismissal with Prejudice filed on June 30, 2010, in the case of Jane Doe II v. Jeffrey Epstein and Sarah Kellen in the Southern District of Florida. The parties agreed to dismiss the lawsuit with prejudice, meaning it cannot be refiled, with each party bearing their own legal costs. The document notes that a settlement was reached, and the court retains jurisdiction to enforce its terms.
078.pdf
This document is a legal notice filed on June 14, 2010, in the case of Jane Doe No. 2 v. Jeffrey Epstein. The notice, filed by attorney Spencer T. Kuvin on behalf of Plaintiff C.L., withdraws a subpoena and cancels the deposition of Maritza Milagros Vasquez, which was scheduled for the following day, June 15, 2010. The document also includes a certificate of service listing legal counsel for various parties involved in related cases.
075.pdf
A legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party Jean Luc Bruhnel (spelled 'Bruhnel' in document) in the case of Jane Doe v. Jeffrey Epstein. The filing opposes a motion to compel Bruhnel's deposition, arguing that he is a French citizen who has left the U.S. with no plans to return and cannot be compelled to appear under Federal Rules. The document alleges misrepresentation and nonfeasance by the Plaintiff's counsel and suggests using the Hague Convention to secure testimony abroad.
071.pdf
A 2009 legal motion filed in the Southern District of Florida on behalf of Jeffrey Epstein requesting permission to attend mediation in a case involving Carolyn Andriano (C.M.A.). The motion notes that a prior 'no contact order' exists regarding Andriano, but states that neither she nor her counsel object to Epstein's presence at depositions, mediation, or trial. The document includes a comprehensive service list of attorneys involved in multiple related cases against Epstein.
069.pdf
This document is a legal motion filed on November 9, 2009, by Igor Zinoviev, a third-party witness and employee of Jeffrey Epstein, seeking a protective order to prevent or limit his deposition in the civil case 'Jane Doe No. 2 v. Jeffrey Epstein'. Zinoviev claims he has no relevant information for the civil cases as his employment with Epstein began in November 2005, after the period of the alleged misconduct, and he has not discussed Epstein's criminal or civil cases with him.
061.pdf
This document is Jeffrey Epstein's Answer and Affirmative Defenses to a civil complaint filed by Jane Doe II in the Southern District of Florida in October 2009. Epstein pleads the Fifth Amendment against self-incrimination in response to most factual allegations. He asserts multiple affirmative defenses, claiming the plaintiff consented to the acts, that he believed she was 18 years or older, and that the claims are barred by the statute of limitations and various constitutional challenges to the retroactivity and application of 18 U.S.C. §2255.
050.pdf
This document is a Notice of Compliance filed by Jeffrey Epstein's legal team (Burman, Critton, Luttier & Coleman) on July 28, 2009, in the US District Court for the Southern District of Florida. It addresses a court order regarding the preservation of evidence and a protective order, noting that while the parties agreed on many sections, they could not finalize a joint order, leading Epstein to submit his own proposed order separately. The document lists numerous related civil cases involving Jane Doe plaintiffs and provides a comprehensive service list of attorneys involved in the various Epstein-related litigations at that time, including Bruce Reinhart representing Sarah Kellen.
047.pdf
This document is a Plaintiff's Memorandum of Law filed on July 14, 2009, in the case of Jane Doe II v. Jeffrey Epstein and Sarah Kellen. The Plaintiff opposes Sarah Kellen's motion to set aside a default judgment, arguing that Kellen was properly served via 'nail and mail' in New York on April 23, 2009, after six attempts, and deliberately ignored the lawsuit. The filing asserts Kellen has provided no evidence she didn't receive service and has failed to present a meritorious defense as required by law.
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.
037.pdf
This document is a Plaintiff's Motion for Default filed on June 12, 2009, in the Southern District of Florida against Sarah Kellen in the case of Jane Doe II vs. Jeffrey Epstein and Sarah Kellen. The motion asserts that Kellen has been avoiding service but was successfully served according to New York law and failed to respond. Notably, it alleges that Kellen is aware of the legal action and has visited Jeffrey Epstein at the Palm Beach County Jail on several occasions.
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.
031.pdf
This document is a Reply by Defendant Jeffrey Epstein to Plaintiff Jane Doe II's opposition to his motion to dismiss a civil suit (Case 09-CIV-80469). Epstein's defense argues that a concurrent state action requires dismissal of the federal case, that the 2006 amendment to 18 U.S.C. §2255 ('Masha's Law') cannot be applied retroactively to conduct from 2003-2005 to increase damages, and that the Plaintiff misrepresents the terms of Epstein's non-prosecution agreement with the US Attorney's Office. The document details specific dates in 2003 and 2004 where the Plaintiff alleges she received payments for acts of prostitution.
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.
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.
016.pdf
This document is a legal motion filed on May 15, 2009, in the Southern District of Florida, case number 09-80469-CIV-MARRA. Plaintiff Jane Doe II requests an extension until May 22, 2009, to file a reply to Defendant Jeffrey Epstein's Motion to Dismiss, citing complex issues and other business. Epstein's counsel, Robert Critton, was consulted and did not oppose the extension.
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.
009.pdf
This document is a legal response filed by Jeffrey Epstein's attorneys on May 4, 2009, in the Southern District of Florida. Epstein opposes the court's potential order to consolidate multiple civil lawsuits (filed by various 'Jane Doe' plaintiffs) for all discovery purposes, arguing that while consolidating depositions is acceptable, full consolidation would confuse distinct facts and defenses unique to each case. The filing lists numerous related case numbers and requests clarification on how consolidation would operate regarding motion practice.
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.
024.pdf
This document is an unopposed motion filed on September 18, 2008, by Plaintiff Jane Doe in the Southern District of Florida (Case 08-80804) against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The plaintiff requests an extension of time to respond to Epstein's Motion to Dismiss until 15 days after the court rules on a pending motion to remand the case to state court due to alleged lack of federal jurisdiction. The document lists legal counsel for all parties, including Bruce Reinhart representing Sarah Kellen.
016-01.pdf
This document contains a Proposed Order and an Unopposed Motion for Enlargement of Time filed by Plaintiff Jane Doe in a civil case against Jeffrey Epstein, Haley Robson, and Sarah Kellen (Case No. 08-80804). Filed on August 13, 2008, the motion requests an extension to file a Civil RICO Case Statement until after the court rules on an upcoming motion to remand the case back to state court. The plaintiff argues the case was improperly removed to federal court and lacks federal jurisdiction. The document includes a service list identifying legal counsel for all parties, including Bruce Reinhart representing Sarah Kellen.
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.
001-02.pdf
This document is a summons and affidavit of service related to a lawsuit filed in the 15th Judicial Circuit Court in Palm Beach County, Florida. Jane Doe, represented by her mother, is the plaintiff against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The document details the service of the summons on Sarah Kellen in New York City on April 19, 2008, and includes important legal notices in English, Spanish, and French regarding the lawsuit and the defendant's responsibilities.
030.pdf
This document is a Notice of Withdrawing Subpoena filed on June 14, 2010, in the United States District Court for the Southern District of Florida. Plaintiff C.L., represented by attorney Spencer T. Kuvin, withdrew a subpoena and cancelled the deposition of Maritza Milagros Vasquez, which had been scheduled for June 15, 2010. The document includes a certificate of service listing legal counsel for various parties involved in the primary case (Jane Doe No. 2 v. Jeffrey Epstein) and related cases.
027.pdf
Legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party witness Jean Luc Bruhnel (spelled Bruhnel in document). The filing opposes Plaintiff Jane Doe's motion to compel Bruhnel to appear for a deposition, arguing that Bruhnel is a French citizen who has left the US with no plans to return and cannot be compelled by the Court to return. The document asserts that the Plaintiff should use the Hague Convention or other international mechanisms to secure testimony abroad and accuses Plaintiff's counsel of misrepresentation and failure to follow proper procedure.
017.pdf
Legal filing from November 2009 in the case of Jane Doe No. 2 v. Jeffrey Epstein. Epstein's attorneys reply to a response regarding the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), which was undergoing restructuring. The document notes that the Department of Justice had seized approximately 40 boxes of documents from RRA, including 13 boxes related to the Epstein case, and alludes to serious ethical and criminal issues involving the RRA firm that could impact the validity of the cases against Epstein.
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