Robert C. Josefsberg
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Jane Doe No. 101
|
Client |
5
|
5 | |
|
person
Jack Scarola
|
Professional |
5
|
1 | |
|
person
Jane Doe No. 102
|
Client |
3
|
3 | |
|
person
Jeffrey Epstein
|
Legal representative |
2
|
2 | |
|
person
Plaintiffs
|
Client |
2
|
2 | |
|
person
Plaintiffs
|
Counsel for |
1
|
1 | |
|
person
four FBI agents
|
Professional |
1
|
1 | |
|
person
Redacted Sender
|
Professional correspondence |
1
|
1 | |
|
person
Jane Doe No. 103
|
Client |
1
|
1 | |
|
person
Jane Doe 103
|
Client |
1
|
1 | |
|
person
Jane Doe 101 and 102
|
Legal representative |
1
|
1 | |
|
person
Unidentified Clients (Victims)
|
Client |
1
|
1 | |
|
person
Assistant U.S. Attorney (SDNY)
|
Legal representative |
1
|
1 | |
|
person
Jane Doe 102
|
Client |
1
|
1 | |
|
person
SDNY AUSA
|
Professional |
1
|
1 | |
|
person
Hon. Edward B. Davis
|
Professional |
1
|
1 | |
|
person
Plaintiffs
|
Counsel for plaintiffs |
1
|
1 | |
|
person
Katherine W. Ezell
|
Business associate |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Meeting where FBI Victim Assistance counseling payments were discussed. | Miami | View |
| 2009-06-10 | N/A | Travel to Hanover, New Hampshire for Robert Josefsberg's 50th College Reunion and college visits. | Hanover, New Hampshire | View |
| 2009-05-29 | N/A | Filing of Motion for Leave to File Under Seal | United States District Cour... | View |
| 2009-05-21 | N/A | Deadline set by Podhurst Orseck for confirmation that preservation steps have been taken. | N/A | View |
| 2009-05-01 | N/A | Electronic filing of Plaintiff's Response to Court's Order | Southern District of Florida | View |
| 2009-04-17 | N/A | Motion to Proceed Anonymously filed/signed. | Southern District of Florida | View |
017-13.pdf
This document is a protective response filed by Plaintiff Jane Doe on May 27, 2010, in the Southern District of Florida case against Jeffrey Epstein. The plaintiff requests the court to promptly order the production of tax returns and other documents that Epstein has withheld on Fifth Amendment grounds, emphasizing that the trial date is set for July 19, 2010. The filing notes that negotiations with Epstein's counsel failed and lists numerous related cases and attorneys involved.
017-02.pdf
This document is a legal response filed by Jeffrey Epstein's legal team on October 6, 2009, opposing a Motion to Compel discovery filed by Plaintiff Jane Doe No. 2. Epstein asserts his Fifth Amendment privilege against self-incrimination to refuse the production of photographs of his Palm Beach home (specifically massage rooms), financial records, tax returns, passport/travel records, and medical records from Dr. Stephan Alexander. The defense argues that despite the Non-Prosecution Agreement (NPA), the threat of federal prosecution remains real and substantial, particularly in districts outside the Southern District of Florida, and that the act of producing these documents would be testimonial and incriminating.
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.
016-02.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.
015.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) opposing Jeffrey Epstein's appeal of a Magistrate Judge's order compelling him to produce income tax returns for the years 2003-2008. The Plaintiffs argue that tax returns are 'required records' not protected by the Fifth Amendment privilege against self-incrimination and are critical for determining punitive damages. The document notes that Epstein attempted to avoid producing these records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs rejected as insufficient.
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.
076.pdf
This document is a legal memorandum filed by the Plaintiffs (Jane Does 2-8) in response to Jeffrey Epstein's appeal of a Magistrate Judge's order compelling him to produce his income tax returns for the years 2003-2008. The Plaintiffs argue that the tax returns are relevant for determining punitive damages and are not protected by the Fifth Amendment privilege against self-incrimination, citing the 'required records' exception. The document also notes Epstein's attempt to avoid producing records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs reject as insufficient.
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.pdf
This document is a Motion for Protective Order filed on July 29, 2009, in the Southern District of Florida by Plaintiffs 'Jane Does 2-7' against Jeffrey Epstein. The plaintiffs allege that Epstein hired private investigators to harass and intimidate them by contacting their former employers, ex-boyfriends, and friends to ask intrusive personal questions and potentially 'out' them as sexual abuse victims. The motion seeks a court order to stop Epstein's investigators from making ex parte contacts with nonparties associated with the plaintiffs.
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.
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.
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.
027.pdf
This document is a Motion for Leave to File Under Seal submitted on May 29, 2009, by attorneys for Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida. The plaintiffs request permission to file their response to Epstein's Motion to Stay under seal, or alternatively, request the court to unseal the Non-Prosecution Agreement (NPA) so they can adequately respond. The document includes a comprehensive service list detailing attorneys representing Epstein, co-defendant Sarah Kellen (represented by Bruce Reinhart), and various other Jane Doe plaintiffs.
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.
021.pdf
This document is a Notice of Filing Proposed Order submitted to the U.S. District Court for the Southern District of Florida on May 27, 2009. It lists eleven separate civil cases filed against Jeffrey Epstein by various plaintiffs, including Jane Does 2-7, 101, 102, C.M.A., and Doe II. The filing serves to submit a proposed order related to case no. 08-80119 and includes a service list of attorneys involved in the litigation.
028.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) in the case Jane Doe No. 2 vs. Jeffrey Epstein (Case No. 08-CV-80119-MARRA/JOHNSON). The memorandum opposes Epstein's appeal of a Magistrate Judge's order compelling him to produce his income tax returns for the years 2003-2008. The Plaintiffs argue that the tax returns are not protected by the Fifth Amendment (citing the 'required records' exception and 'foregone conclusion' doctrine) and are critical for determining punitive damages given the allegations of sexual molestation and Epstein's refusal to provide net worth discovery beyond a stipulation of 'nine figures.'
022.pdf
Legal document filed on May 18, 2010, in the Southern District of Florida stipulating the dismissal with prejudice of a civil lawsuit (Case No. 10-CV-80309) brought by Jane Doe No. 103 against Jeffrey Epstein. The document indicates that a settlement was reached between the parties, with the court retaining jurisdiction to enforce its terms.
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.
Re: Epstein Victims
Requesting a phone call, noting he is out of the office.
RE: Epstein victims
Informing about a scheduled court conference on Aug 27 regarding dismissal of indictment due to Epstein's death. Mentions Judge Berman will allow victims to be heard. Offers travel assistance for clients.
Re: Epstein victims
Thanking for the offer of counseling and dedication to the situation. Stating they will contact clients regarding the offer.
Re: Epstein victims
Offering counseling and victim services resources. Providing contact info for FBI Special Agent.
RE: call
Notification that news of Epstein's arrest leaked to media; request for a phone call to update the attorney so he can inform his clients (victims).
Motion to Reschedule Hearing
Request to reschedule hearing from June 12, 2009 due to counsel's 50th college reunion.
Response to request
Stating the request is unnecessary as Epstein has not contacted clients, except for one instance where a client contacted Goldberger's office.
Service of Motion
Service of Motion for Limited Appearance via CM/ECF
Epstein No Contact Letter
Follow up on the April 17th letter, threatening court relief if no response.
No Contact Order
Requesting written confirmation that Epstein and his agents will not contact victims.
Re: Jeffrey Epstein
Asking for confirmation that Epstein will know the existence of a zone to avoid it, but not the specific nature (home/office) or owner of the location.
Out of Office AutoReply: Jeffrey Epstein
I will be out of the office on Monday Dec. 22 and return Monday Jan 3.
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