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.
This document is the Curriculum Vitae (CV) of a redacted FBI Expert Witness and Computer Forensic Examiner based in the New York Field Office. The subject has been with the FBI since 2005, following careers in programming and environmental health. The CV details extensive training in digital forensics (cell phones, Windows, Mac, Linux), certifications (EnCase, Cellebrite), and a significant history of instructing and speaking at international conferences and training sessions (including in Ghana and Egypt) regarding cyber security and digital investigations up to July 2021.
This document consists of an exchange of letters between Paul G. Cassell of the University of Utah S.J. Quinney College of Law and an Assistant Commissioner at New Scotland Yard (Metropolitan Police). In the first letter (July 31, 2015), Cassell follows up on previous correspondence regarding allegations of international sex trafficking against Jeffrey Epstein and Ghislaine Maxwell, offering his client's assistance in the investigation. In the response (August 10, 2015), the Metropolitan Police confirm they are progressing with the matter and request formal written confirmation that Cassell is legally authorized to represent the specific client involved.
This document is a legal filing by Ghislaine Maxwell's defense team objecting to the unsealing of specific docket entries (143, 173, 199, 164, and 230) in the civil case brought by Virginia Giuffre. The defense argues that these documents contain sensitive information regarding non-parties ('Does'), inadmissible hearsay, and prejudicial materials such as flight logs and police reports that were improperly filed to bias the court. The filing emphasizes the need to protect the privacy of non-parties and the integrity of ongoing criminal investigations into Jeffrey Epstein's conduct.
This document is a Grand Jury Subpoena issued on August 16, 2019, by the Southern District of New York to Experian, requesting credit records for Ghislaine Maxwell related to a sex trafficking investigation (citing statutes 1591, 2422, etc.). The package includes Experian's response, a Declaration of Custodian of Records dated August 27, 2019, and the credit profile itself. The credit report reveals Maxwell's employment with 'J Epstein and Compny,' an alias 'Ghislaine Borgerson,' and various financial accounts including an active AMEX with a balance over $100,000 at the time of the report.
An email exchange between Paul Cassell (representing victims) and the US Attorney's Office (USAFLS) regarding the wording of a protective order. The order concerns the disclosure of the Non-Prosecution Agreement (NPA) to the victims. Cassell urges speed, citing government representations that 'Epstein is trying to ignore the agreement,' and negotiates the timing of when victims must sign acknowledgments of the protective order.
This document is a 'Counsel List' (Page 20 of 20) from a court filing in the case of 'Edwards, Bradley vs. Dershowitz' (Case No. CACE 15-000072). It provides contact information for attorneys representing the parties involved, including addresses, emails, and phone numbers for law firms such as Boies Schiller & Flexner, Cole Scott & Kissane, and Wiley Rein. The document contains apparent clerical errors, as it lists nearly all attorneys—including the plaintiff Bradley Edwards and his counsel—under the label 'Attorneys for Alan M.Dershowitz, Esquire'.
This document is an email thread from January 23, 2015, between Donna Paine, a freelance TV producer for ITN News, and attorneys Paul Cassell and Brad Edwards. Paine is requesting to be added to a media contact list in anticipation of a ruling by Judge Marra regarding the Jeffrey Epstein case and specific allegations made by Jane Doe #3 against Prince Andrew. Cassell confirms he will have his assistant, Joan, add Paine to their contacts list.
This document is a log of electronic messages from September 9, 2018, between Jeffrey Epstein (via jeeitunes@gmail.com) and a redacted individual. The conversation touches on political commentary regarding Trump and Obama, confirms the redacted individual's travel to NYC by plane, and discusses scheduling meetings with 'Kathy' and Thorbjørn Jagland (Head of Council of Europe).
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