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016.pdf
This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, seeking a protective order to prevent or limit his deposition in the case of Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, a driver and bodyguard for Epstein since November 2005, claims he has no relevant information regarding Epstein's criminal or civil cases, particularly concerning events prior to September 2005. The motion cites legal precedents regarding the scope of discovery and Federal Rules of Civil Procedure Rule 26(c) to argue against the deposition.
015.pdf
This document is a Reply Memorandum filed by Jeffrey Epstein's legal team on August 20, 2009, in the case of Jane Doe No. 8 v. Jeffrey Epstein. The defense argues that the plaintiff's claims of 'Sexual Assault and Battery' (Count I) and 'Coercion and Enticement' (Count III) should be dismissed because they are barred by the statute of limitations. Epstein's lawyers contend that because the plaintiff was aware of the injury at the time of the alleged incident in 2001 (when she was 16) and turned 18 in 2003, the time limits for filing suit (4 years and 6 years respectively) had expired by the time the complaint was filed in 2009.
008.pdf
This document is a Motion to Dismiss filed by Jeffrey Epstein's defense team on July 14, 2009, in the case of Jane Doe No. 8 v. Jeffrey Epstein. The defense argues that the plaintiff's claims of Sexual Assault and Battery (Count I) and Coercion (Count III) are barred by the applicable 4-year (state) and 6-year (federal) statutes of limitations, as the alleged incident occurred in 2001 when the plaintiff was 16. Footnotes in the document provide graphic details of the allegations, describing how Jane Doe was recruited by another girl, brought to Epstein's Palm Beach mansion, and sexually assaulted during a massage.
020.pdf
This document is an agreed motion filed on May 13, 2010, in the Southern District of Florida by Plaintiff Jane Doe No. 103 against Defendant Jeffrey Epstein. The plaintiff requests a one-week extension to file a response to Epstein's motion to dismiss because the parties are in the process of resolving the matter via settlement, which would render the motion moot. The document includes a comprehensive service list detailing legal counsel for Epstein, Co-Defendant Sarah Kellen (represented by Bruce Reinhart), and plaintiffs in several related cases.
016.pdf
This document is an agreed motion for an extension of time filed on April 22, 2010, in the case of Jane Doe No. 103 vs. Jeffrey Epstein (Case No. 10-80309-WJZ). Plaintiff's counsel, Katherine W. Ezell, requests an extension until May 13, 2010, to file a response to Epstein's motion to dismiss because she is leaving for a vacation in Italy the following day. The motion notes that Epstein's counsel, Robert Critton, agrees to the extension, and the document includes a service list of attorneys involved in this and related cases.
015.pdf
This document is a motion filed on April 12, 2010, by Jeffrey Epstein's legal counsel in the case 'Jane Doe No. 103 vs. Jeffery Epstein'. The defense seeks to amend their previous Motion to Dismiss to clarify an argument regarding retroactivity, specifically stating that the criminal statute (18 U.S.C. § 2252A(g)) relied upon by the plaintiff did not exist during the time of the alleged abuse (Jan 2004 - May 2005). The plaintiff's counsel reportedly did not oppose this amendment.
012.pdf
This document is a Motion to Transfer filed on April 1, 2010, by Plaintiff Jane Doe No. 103 in the US District Court, Southern District of Florida. The plaintiff seeks to transfer her case against Jeffrey Epstein to Judge Marra's division to consolidate it with other similar pending cases, specifically 'Jane Doe No. 2 vs. Jeffrey Epstein'. The document includes a service list detailing legal counsel for Epstein, co-defendant Sarah Kellen (represented by Bruce Reinhart), and plaintiffs in several related cases.
006.pdf
This document is an unopposed motion filed on March 23, 2010, in the United States District Court for the Southern District of Florida, requesting an extension of time for Jeffrey Epstein to respond to a complaint filed by Jane Doe No. 103. Epstein's legal team requests the deadline be moved from March 26 to April 5, 2010, citing workload from 'several other cases' filed in the same court in which Epstein is a defendant. The plaintiff's counsel agreed to this extension.
064.pdf
A Stipulation of Dismissal with Prejudice filed on December 7, 2009, in the US District Court for the Southern District of Florida (Case No. 09-CV-80656). Plaintiff Jane Doe No. 102 and Defendant Jeffrey Epstein agreed to dismiss the action following a settlement, with the court retaining jurisdiction to enforce its terms. The document is signed by Robert Critton (representing Epstein) and Katherine W. Ezell (representing Jane Doe No. 102).
059.pdf
This document is a motion filed on November 20, 2009, in the US District Court for the Southern District of Florida, requesting permission for Jeffrey Epstein to attend mediation in the case involving Carolyn Andriano (C.M.A.). The motion notes that a previous no-contact order exists regarding Andriano, but her counsel has no objection to Epstein attending the deposition, mediation, or trial. The document includes a service list detailing the attorneys involved in this and related cases, including Bruce Reinhart representing Sarah Kellen.
057.pdf
This document is a legal reply filed by Jeffrey Epstein's legal team on November 16, 2009, regarding the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA). The filing notes that the Department of Justice seized approximately 40 boxes of documents from RRA, including 13 boxes specifically related to Epstein cases. The document highlights scheduling conflicts involving the deposition of Herbert Stettin (RRA's Chief Restructuring Officer) and alludes to potential ethical or criminal issues within RRA that could impact the validity of the cases against Epstein.
055.pdf
This document is a Motion for Protective Order filed on November 9, 2009, by Igor Zinoviev, a third-party witness and Jeffrey Epstein's driver/bodyguard since November 2005. Zinoviev seeks to prevent or limit his deposition, arguing he has no knowledge relevant to the civil cases as his employment with Epstein began after the alleged events, and he has not discussed Epstein's criminal or civil cases with him. The motion cites legal precedents on the scope of discovery and includes a list of attorneys involved in various related cases.
053.pdf
This is an unopposed motion filed on October 29, 2009, in the US District Court for the Southern District of Florida by Jeffrey Epstein's legal team. Epstein requests an extension until November 16, 2009, to respond to a complaint filed by 'Jane Doe No. 102' on May 1, 2009, citing that the parties are working together to potentially resolve the case. The document lists legal counsel for both sides, including Robert Critton and Jack Goldberger for Epstein, and Robert Josefsberg and Katherine Ezell for the plaintiff.
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. § 2255, and accuses Epstein of using the threat of publicity to intimidate victims into settling.
089.pdf
This document is a Stipulation of Dismissal with Prejudice filed on December 7, 2009, in the United States District Court for the Southern District of Florida for Case No. 09-CV-80591. The plaintiff, Jane Doe No. 101, and defendant, Jeffrey Epstein, agreed to dismiss the lawsuit following a settlement, the terms of which the court retains jurisdiction to enforce. The document is signed by Robert Critton (representing Epstein) and Katherine W. Ezell (representing Jane Doe No. 101).
087.pdf
This document is a Motion for Extension of Time filed on December 2, 2009, by Jeffrey Epstein's legal team in the case of Jane Doe No. 101 v. Jeffrey Epstein. The defense requested an extension until December 15, 2009, to file a reply, citing ongoing settlement negotiations and the need to investigate the implications of the 'Rothstein Rosenfeldt & Adler, PA' firm implosion on the Plaintiff's counsel. The document notes that Plaintiff's counsel opposed this extension request.
082.pdf
This document is a Reply filed by Jeffrey Epstein's legal team in November 2009 requesting a permanent order for the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), which was undergoing restructuring. The filing highlights that the Department of Justice had seized approximately 40 boxes of documents from RRA, including about 13 boxes related to Epstein cases, amidst concerns of 'serious ethical and potentially criminal issues' at the firm. The document also argues against delaying the deposition of RRA's Chief Restructuring Officer, Herbert Stettin, citing upcoming trial deadlines.
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.
078.pdf
This document is an unopposed motion filed on October 29, 2009, by Jeffrey Epstein's legal team requesting an extension of time until November 16, 2009, to file a reply to Plaintiff Jane Doe 101's response to the motion to dismiss. The document indicates that the parties are working together to find a resolution to the case. The motion was filed in the U.S. District Court for the Southern District of Florida.
076.pdf
This document is an unopposed motion filed on October 15, 2009, by Jeffrey Epstein's legal team requesting an extension of time until October 30, 2009, to reply to Plaintiff Jane Doe 101's response to the motion to dismiss. The motion states that the parties are working together to find a resolution to the case and that the plaintiff's counsel agrees to the extension. The document includes a procedural history of filings and a service list of attorneys involved.
064.pdf
This document is a 'Notice of Compliance' filed on July 28, 2009, by Jeffrey Epstein's legal team in the U.S. District Court for the Southern District of Florida. It pertains to multiple civil cases filed by 'Jane Doe' plaintiffs against Epstein. The filing states that while the court ordered the parties to agree on a preservation of evidence order, they were unable to reach a full agreement, leading Epstein to submit his own proposed order. The document includes a comprehensive service list detailing the attorneys representing the various plaintiffs and defendants, including Sarah Kellen.
057.pdf
This document is an unopposed motion filed on July 2, 2009, by Jeffrey Epstein's legal counsel in the US District Court for the Southern District of Florida (Case No. 09-80591). Epstein's attorneys request an extension until August 21, 2009, to reply to Plaintiff Jane Doe 101's response to a motion to dismiss, citing workload from other cases involving Epstein. The document confirms that Plaintiff's counsel agreed to this extension via telephone and correspondence.
041.pdf
This document is a Motion for Limited Appearance filed on June 4, 2009, in the case of Jane Doe 101 v. Jeffrey Epstein in the Southern District of Florida. Attorney Robert D. Critton, Jr. moves for the admission of Jay P. Lefkowitz of Kirkland & Ellis LLP to appear as co-counsel for Jeffrey Epstein. The document includes certificates of service to opposing counsel and a certificate of good standing for Lefkowitz from the District of Columbia court.
038.pdf
This document is a Motion to Reschedule Hearing filed on May 29, 2009, in the United States District Court for the Southern District of Florida. Attorney Robert C. Josefsberg, representing Plaintiffs Jane Doe 101 and 102, requests to move a hearing scheduled for June 12, 2009, because he will be attending his 50th College Reunion in Hanover, New Hampshire. The document includes a comprehensive service list detailing the legal teams associated with Jeffrey Epstein, Sarah Kellen, and various plaintiffs in related cases.
035.pdf
This document is a legal reply filed on May 29, 2009, in the US District Court for the Southern District of Florida by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein. The plaintiffs argue for the right to proceed anonymously, citing fears of harassment, public humiliation, and Epstein's alleged intent to intimidate victims by exposing their identities. The document lists numerous related cases and provides a service list of attorneys representing various parties, including Bruce Reinhart representing co-defendant Sarah Kellen.
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