Lake Worth, Florida
LocationRelationship Network
081.pdf
This document is a Motion for Authorization to Travel filed on December 17, 2009, in Palm Beach County, Florida, on behalf of Jeffrey Epstein. Epstein requests permission to travel to New York for three days to meet with his attorney, Harry Susman, review confidential documents, and interview witnesses related to ongoing litigation. The motion notes that his community control officer, Carmen Sloane, has no objection to the travel provided dates are cleared in advance.
016-02.pdf
This document is a Motion for No-Contact Order filed by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein in the Southern District of Florida on May 22, 2009. The plaintiffs argue that despite a state plea agreement prohibiting contact, Epstein's counsel refused to confirm he would not contact federal victims. The filing includes exhibits of correspondence between attorneys and a transcript of the 2008 plea conference where Judge Pucillo explicitly defined 'indirect contact' to include Facebook and MySpace.
010.pdf
This is a motion filed by Defendant Jeffrey Epstein's attorneys requesting a court order to allow him to attend mediation, deposition, and trial in the case of Jane Doe No. 2 v. Jeffrey Epstein. The motion notes that a prior no-contact order involving Carolyn Andriano might technically preclude this, but states that Plaintiff's counsel and Ms. Andriano have no objection. The document includes a certificate of service listing numerous attorneys involved in related cases.
009.pdf
Legal filing from November 2009 in the case of Jane Doe No. 2 v. Jeffrey Epstein. Epstein's attorneys argue for the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), noting that the DOJ has seized boxes of documents from RRA, including 13 boxes related to Epstein. The document also disputes delays in the deposition of RRA's Chief Restructuring Officer, Herbert Stettin, citing upcoming trial deadlines.
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.
052-03.pdf
This document is a legal declaration by Jane Doe No. 6, dated July 22, 2009. She states that on July 9, 2009, an investigator visited her former employer, A Affordable Auto Insurance in Lake Worth, Florida, asking personal questions about her. She expresses concern that Jeffrey Epstein is sending investigators to harass people she knows and potentially out her as a plaintiff in the sexual abuse lawsuit against him.
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.
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.
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.
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.
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.
044-03.pdf
A legal declaration by Jane Doe No. 6 filed on July 29, 2009 (signed July 22, 2009). The plaintiff states that on July 9, 2009, an investigator sent by Jeffrey Epstein visited her former employer at A Affordable Auto Insurance in Lake Worth, Florida, asking personal questions. She expresses fear that Epstein will continue to send investigators to her acquaintances, potentially revealing her identity as a plaintiff in a sexual abuse lawsuit.
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.
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).
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.
066-03.pdf
This document is a legal declaration by Jane Doe No. 6, dated July 22, 2009. She states that on July 9, 2009, an investigator visited her former employer, A Affordable Auto Insurance in Lake Worth, Florida, asking personal questions. She expresses concern that Jeffrey Epstein is sending investigators to harass her associates and reveal her status as a plaintiff in a sexual abuse lawsuit.
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.
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.
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.
010.pdf
This document is a 'Notice of Striking Docket Entry' filed on May 4, 2009, in the United States District Court for the Southern District of Florida, case Jane Doe No. 101 v. Jeffrey Epstein. The plaintiff's counsel, Katherine W. Ezell of Podhurst Orseck, P.A., notifies the court that a previous docket entry was filed without a signature and has been re-filed correctly. The document includes a Certificate of Service listing numerous attorneys involved in this case and related cases against Epstein, including Bruce Reinhart (defense), Jack Scarola, and Brad Edwards.
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