William J. Berger
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
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Documents | Actions |
|---|---|---|---|---|
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person
E.W.
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Client |
1
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1 | |
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person
LM
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Client |
1
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1 | |
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organization
Subway
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Client |
1
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1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2009-09-17 | N/A | Deposition scheduled but canceled due to an incident involving Jeffrey Epstein and the plaintiff. | Florida Science Foundation ... | View |
| 2006-04-25 | N/A | Order Granting Custodial Parent Modification signed by Judge. | Palm Beach County, FL | View |
091.pdf
A court order from the Florida Fourth District Court of Appeal dated July 1, 2009, in the case of Jeffrey Epstein v. State of Florida. The court granted Epstein's motion to file under seal and stayed a previous June 25, 2009 order that had granted a motion to unseal documents. The State (Respondent) was ordered to show cause within 10 days why Epstein's petition should not be granted.
068.pdf
This document is a Mandate from the Fourth District Court of Appeal of Florida, dated September 18, 2009, regarding the case of Jeffrey Epstein v. State of Florida. The mandate follows an opinion issued on September 2, 2009, where the court affirmed the lower court's decision, treating Epstein's petition for writ of certiorari as a full appeal. The document lists numerous attorneys involved, including R. Alexander Acosta on the distribution list, and identifies Palm Beach Newspapers, Inc. as an appellee alongside the State and a redacted party.
061.pdf
This document is a Supplemental Appendix filed by Palm Beach Newspapers, Inc. in a Florida state court case involving Jeffrey Epstein. It contains a transcript of a June 2009 hearing regarding the unsealing of court records, administrative orders, case law, and federal court filings including a declaration by AUSA A. Marie Villafana regarding the federal Non-Prosecution Agreement (NPA). The appendix documents the legal arguments surrounding the transparency of the Epstein proceedings and the government's interaction with victims under the Crime Victims' Rights Act.
060.pdf
This document is a response filed by Palm Beach Newspapers, Inc. (The Palm Beach Post) to an emergency petition for writ of certiorari by Jeffrey Epstein. The Post argues that the trial court correctly unsealed a Non-Prosecution Agreement (NPA) and its addendum related to Epstein's solicitation of minors, asserting that the documents were improperly sealed in the first instance and that no valid legal basis exists for their continued closure.
055.pdf
This document is a transcript of court proceedings from June 26, 2009, regarding State of Florida vs. Jeffrey Epstein. The hearing concerns a 'Motion to Stay' filed by Epstein's defense to prevent the immediate release of sealed documents, specifically a Non-Prosecution Agreement (MPA) and grand jury materials, pending an appeal. The Judge denies the indefinite stay and the request for a bond but grants a short delay until the following Thursday to allow the defense time to file with the appellate court. The document also touches on potential redactions of children's names, which the Judge notes were not actually found in the documents in question.
053.pdf
This document is a court order from June 26, 2009, issued by Judge Jeffrey J. Colbath in the Circuit Court of Palm Beach County, Florida. The order denies Jeffrey Epstein's motion to stay the disclosure of his Non-Prosecution Agreement and sets a deadline of July 2, 2009, for the Clerk to release the documents, allowing time for an appeal to the 4th DCA. The document includes a service list of attorneys involved, including U.S. Attorney R. Alexander Acosta and defense attorneys like Jack Goldberger.
047.pdf
Legal motion filed on June 25, 2009, by Jeffrey Epstein's defense team (Critton, Pike, Goldberger) in Palm Beach County Circuit Court. Epstein requests a stay on the disclosure of his Non-Prosecution Agreement (NPA) pending an appellate review, arguing that unsealing the document would cause irreparable harm to privacy rights and innocent third parties. The motion opposes efforts by the Palm Beach Post and a redacted non-party to unseal these court records.
041.pdf
This document is a 'Motion to Make Court Records Confidential' filed by Jeffrey Epstein's attorneys on June 11, 2009, in the Circuit Court of Palm Beach County. The defense seeks to maintain the seal on the Non-Prosecution Agreement (filed July 2008) and its Addendum, citing threats to the administration of justice and privacy rights of third parties. The motion references interventions by the Palm Beach Post and a non-party identified as 'EW' (whose name is redacted in one section) seeking access to these records.
035.pdf
This document is a motion filed on June 2, 2009, by The Palm Beach Post seeking to intervene in the criminal case against Jeffrey Epstein to unseal a non-prosecution agreement and its addendum. The Post argues that the sealing was improper, lacked necessary legal findings, and that the documents are of significant public interest given the accusations of soliciting minors. The document cites numerous civil lawsuits against Epstein and criticizes the secrecy surrounding his plea deal.
034.pdf
This document is a motion filed on June 3, 2009, by a redacted nonparty (a victim of Jeffrey Epstein) seeking to unseal the Non-Prosecution Agreement (NPA) and its addendum in the Florida state criminal case. The motion argues the sealing violated Florida judicial rules and public policy, and that the documents are material to the victim's pending civil suit. Exhibits include judgments of conviction against Epstein for solicitation and procuring a minor, sealing orders from 2008, and transcripts from the June 30, 2008 plea conference where the existence of the federal NPA was discussed in open court.
029.pdf
A Notice of Hearing filed in the Circuit Court of Palm Beach County regarding the case State of Florida vs. Jeffrey Epstein (Case No. 2008-CF9381 AXX). The hearing, scheduled for May 29, 2009, before Judge Jeffrey J. Colbath, concerns a motion by a redacted non-party (represented by Bradley J. Edwards for client 'E.W.') to vacate an order sealing records and to unseal said records. The file path in the footer references 'Wild v. Epstein', suggesting the redacted party may be named Wild.
027.pdf
A court order from the Circuit Court of the Fifteenth Judicial Circuit in Palm Beach County, Florida, setting a hearing for May 29, 2009. The hearing concerns a motion by a redacted nonparty to vacate an order sealing records and to unseal records in the case of State of Florida vs. Jeffrey Epstein. Copies were sent to the Assistant State Attorney, Epstein's lawyer Jack Goldberger, and William J. Berger, attorney for an individual identified as E.W.
017-01.pdf
This document is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Jane Doe in the United States District Court for the Southern District of Florida against Jeffrey Epstein. The plaintiff argues that Epstein's blanket invocation of Fifth Amendment privileges to refuse producing documents (such as phone records, tax returns, and correspondence) is improper and that he should be compelled to answer or provide a privilege log. The motion details specific discovery requests and Epstein's uniform response asserting his constitutional rights against self-incrimination.
016-12.pdf
This document is a Motion for Sanctions filed by Plaintiff Jane Doe No. 4 against Jeffrey Epstein for violating a no-contact order and a written stipulation. On September 16, 2009, Epstein appeared in the lobby of the building where Jane Doe No. 4's deposition was scheduled, staring her down and causing her to flee in distress, despite an agreement that he would not attend. The document includes a declaration from attorney Adam Horowitz, a transcript of the cancelled deposition where defense counsel Robert Critton argues Epstein was simply leaving his office in the same building, and an email confirming the prior stipulation.
014-02.pdf
This document contains notices for the videotaped deposition of Jean Luc Bruhel (spelled Bruhnel in one instance), scheduled for November 3, 2009, at Esquire Court Reporters in West Palm Beach, Florida. The deposition is relevant to two civil cases pending in the 15th Judicial Circuit Court of Palm Beach County: B.B. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. The document lists numerous attorneys involved in the litigation, including Spencer Kuvin, Bradley Edwards, Jack Goldberger, and Bruce Reinhart.
045.pdf
This document is a Motion to Compel filed by Plaintiff Jane Doe against Jeffrey Epstein on July 10, 2009, in the Southern District of Florida. The plaintiff lists 23 specific interrogatories regarding Epstein's finances, properties, travel, and alleged sexual abuse of minors, all of which Epstein refused to answer by invoking his Fifth and Sixth Amendment rights. The motion argues that Epstein's blanket refusals are improper and requests the court force him to answer or provide a privilege log.
043.pdf
This document is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the United States District Court, Southern District of Florida (Case No. 08-CV-80119-MARRA/JOHNSON). The motion argues that Epstein has improperly asserted blanket Fifth Amendment privileges in response to sixteen specific requests for production of documents, including telephone records, appointment books, financial records, and correspondence. The Plaintiff requests the Court to order Epstein to answer the requests, provide a particularized justification for his Fifth Amendment invocations, and produce a privilege log.
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.
040.pdf
This document is a Motion to Compel filed on July 10, 2009, in the US District Court for the Southern District of Florida by Plaintiff Jane Doe (represented by Bradley Edwards). The motion requests the court to force Jeffrey Epstein to answer a set of interrogatories regarding his financial assets, net worth, foreign travel, property ownership, and alleged interactions with the plaintiff and other minor females. Epstein refused to answer nearly all questions (except for providing the name/address of the person answering), invoking his Fifth and Sixth Amendment rights against self-incrimination and right to counsel.
039.pdf
This legal filing is a Motion to Compel submitted by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the United States District Court for the Southern District of Florida. The motion requests the court to order Epstein to answer 23 specific requests for admission regarding his net worth, asset transfers, and allegations of sexual abuse and trafficking of minors, which he had previously refused to answer by asserting Fifth Amendment privileges. The plaintiff argues that Epstein's blanket assertion of the privilege is improper and that he must provide a particularized justification for each refusal or face an adverse inference.
061.pdf
This document is a Motion to Compel filed on July 10, 2009, in the Southern District of Florida by Plaintiff Jane Doe against Defendant Jeffrey Epstein. The motion seeks to force Epstein to answer 23 specific Requests for Admission regarding his net worth (specifically if it exceeds $1 billion), his financial support of modeling agency MC2, his ownership of Caribbean property, and specific allegations of sexual battery, assault, and sex trafficking of minors. Epstein had previously refused to answer these questions by invoking his Fifth Amendment privilege against self-incrimination.
060.pdf
This is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the Southern District of Florida. The motion seeks a court order requiring Epstein to answer 16 specific requests for production of documents (including telephone records, photos, tax returns, and passport copies) or to provide a privilege log, as Epstein has refused to produce documents by asserting a blanket Fifth Amendment privilege against self-incrimination. The plaintiff argues that Epstein's boilerplate objections are invalid, violate local rules requiring a privilege log, and that he must provide a particularized justification for his Fifth Amendment invocation for each request.
DOJ-OGR-00030305.tif
This document is a partial transcript from a court proceeding on September 17, 2009, detailing the cancellation of a deposition involving Jeffrey Epstein. The deposition was called off because Jeffrey Epstein made face-to-face contact with the plaintiff, Jane Doe 4, which her counsel, Adam Horowitz, stated intimidated her and violated a prior stipulation that Epstein would not be present. Defense counsel, Robert Critton, argued that Epstein was instructed to leave the building and planned to appear via Skype, and that the encounter would not have happened if the plaintiff and her counsel had arrived on time.
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