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017-17.pdf
This document is a Motion for Protective Order filed on June 30, 2010, by Jeffrey Epstein's defense team in the civil case Jane Doe v. Jeffrey Epstein. Epstein seeks permission to redact specific portions of his tax returns regarding investment vehicles, claiming they contain trade secrets and confidential business information. The motion argues that Plaintiff's counsel, Brad Edwards, has a history of sharing discovery material with media and investigators, specifically citing an instance involving Alfredo Rodriguez's journal.
017-15.pdf
This document is a Motion for Protective Order filed on June 28, 2010, by Jeffrey Epstein's legal team in the case of Jane Doe No. 2 vs. Jeffrey Epstein. The motion requests that the court issue an order of confidentiality regarding information Epstein was compelled to produce, specifically his tax returns, passport, and information provided by the federal government during prior criminal proceedings. The defense seeks to prevent this information from being disclosed to third parties or the media and to limit its use strictly to the current litigation.
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.
016-05.pdf
This document is a motion filed on June 30, 2010, by Plaintiff Jane Doe requesting the modification of a court order regarding an upcoming settlement conference with Jeffrey Epstein. Doe requests that Epstein be kept in a secure, separate room to prevent any contact or intimidation, citing his status as a convicted sex offender and previous incidents where he intimidated victims, specifically Jane Doe No. 4, during court proceedings. The motion references Epstein's 2008 guilty plea and strict no-contact orders issued by both state and federal courts.
017.pdf
This document is a legal notice filed on June 14, 2010, in the United States District Court for the Southern District of Florida, regarding the case of Jane Doe No. 2 v. Jeffrey Epstein. The filing, submitted by attorney Spencer T. Kuvin on behalf of Plaintiff 'C.L.', serves to withdraw a subpoena and cancel the scheduled deposition of Maritza Milagros Vasquez, which was set for the following day, June 15, 2010. The document also includes a certificate of service listing various attorneys representing different parties in related cases against Epstein.
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.
036.pdf
A legal filing (Sur-Reply) by Ghislaine Maxwell's attorneys arguing that Plaintiff Bradley Edwards must produce solicitation letters sent to former Epstein employees and their responses. The defense argues Edwards waived work-product privilege by failing to produce a privilege log and that the letters sent to third parties do not constitute work product.
034.pdf
A letter motion filed on March 14, 2017, by attorney Paul G. Cassell to Judge Robert W. Sweet in the case Giuffre v. Maxwell. Cassell requests a one-week continuance for a hearing regarding a Motion to Quash a subpoena served on his client, Bradley J. Edwards, citing a scheduled medical procedure preventing him from traveling to New York. The opposing counsel is noted as having agreed to reschedule the hearing to March 23, 2017.
032.pdf
A legal motion filed on March 13, 2017, in the US District Court for the Southern District of New York (Case 1:17-mc-00025-RWS). Attorney Paul G. Cassell requests admission Pro Hac Vice to represent Plaintiff Bradley J. Edwards in his lawsuit against Ghislaine Maxwell. Cassell attests to his good standing with the Utah Bar and lack of criminal or disciplinary history.
032-01.pdf
This document is a legal declaration filed on March 13, 2017, in the U.S. District Court for the Southern District of New York. Attorney Paul G. Cassell submits this declaration to support his application for admission Pro Hac Vice to represent the plaintiff, Bradley J. Edwards, in his case against Ghislaine Maxwell. Cassell attests to his clean legal record, stating he has no felony convictions or disciplinary actions against him and is a member in good standing of the Utah bar.
001-05.pdf
This document outlines Ghislaine Maxwell's formal objections and responses to Virginia Giuffre's second request for production of documents in the 2015 civil case. Maxwell's counsel objects to numerous requests on grounds of privilege, relevance, and burden, specifically refusing to produce financial documents (tax returns, bank statements, asset lists) pending a motion for a protective order. The document also addresses requests for Joint Defense Agreements with Jeffrey Epstein and Alan Dershowitz, communications regarding sexual abuse allegations, and funding sources for the TerraMar Project, including any from the Clinton Foundation.
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.
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.
044.pdf
This document is a Motion to Compel filed on July 10, 2009, in the Southern District of Florida, requesting the court to force Jeffrey Epstein to answer 23 specific requests for admission in a civil suit brought by Jane Doe No. 2. Epstein had previously asserted his Fifth Amendment privilege against self-incrimination to refuse answering questions regarding his net worth (alleged to be over $1 billion), his financial support of modeling agency MC2, his ownership of foreign property, and specific allegations of sexual assault, battery, and sex trafficking of minors. The plaintiff argues that the Fifth Amendment cannot be used as a blanket refusal in a civil case and demands Epstein answer or provide specific justification for his silence.
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.
021.pdf
This document is a legal response filed by Plaintiff Carolyn M. Andriano (Jane Doe No. 2) opposing a motion by third-party witness Igor Zinoview to avoid deposition. Zinoview, who worked as Epstein's driver, bodyguard, and trainer starting in November 2005, claimed he had no relevant knowledge of Epstein's legal matters. The Plaintiff argues that Zinoview worked for Epstein during the police investigation period and likely has relevant observations, regardless of whether he discussed legal matters with Epstein.
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.
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.
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.
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.
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