| 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 |
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 an unopposed motion filed on July 2, 2009, by Jeffrey Epstein's legal counsel in the US District Court for the Southern District of Florida (Case No. 09-80591). Epstein's attorneys request an extension until August 21, 2009, to reply to Plaintiff Jane Doe 101's response to a motion to dismiss, citing workload from other cases involving Epstein. The document confirms that Plaintiff's counsel agreed to this extension via telephone and correspondence.
This document is a legal response filed on June 26, 2009, by the attorneys for Plaintiff Jane Doe No. 101 in the case against Jeffrey Epstein. The Plaintiff argues against Epstein's motion to dismiss, specifically contesting his claim that multiple violations of sexual exploitation statutes should be merged into a single count with a single penalty. The response asserts that 18 U.S.C. § 2255 allows for separate civil remedies and damages (minimum $150,000) for each distinct violation of a predicate offense.
Legal filing from June 12, 2009, in the case of Jane Doe No. 101 v. Jeffrey Epstein in the Southern District of Florida. Epstein's legal team withdraws seven specific arguments previously made in a Motion to Dismiss regarding the Plaintiff's First Amended Complaint, including arguments about the plaintiff's minority status and predicate offenses. The defense states it will now rely solely on arguments regarding count merger and subparagraph D.
This document is a legal motion filed on June 9, 2009, by Plaintiff Jane Doe No. 101 requesting an extension of time and page limits to respond to Jeffrey Epstein's Motion to Dismiss. The request is based on an upcoming court hearing scheduled for June 12, 2009, in a related case (Jane Doe No. 2 vs. Jeffrey Epstein) which addresses potential breaches of Epstein's Non-Prosecution Agreement. The document includes certificates of conference and service, listing legal counsel for both parties, including Bruce Reinhart as counsel for a co-defendant named Sarah.
This document is a Motion for Limited Appearance filed on June 4, 2009, in the case of Jane Doe 101 v. Jeffrey Epstein in the Southern District of Florida. Attorney Robert D. Critton, Jr. moves for the admission of Jay P. Lefkowitz of Kirkland & Ellis LLP to appear as co-counsel for Jeffrey Epstein. The document includes certificates of service to opposing counsel and a certificate of good standing for Lefkowitz from the District of Columbia court.
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.
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.
This document is a motion filed on May 26, 2009, by Plaintiffs Jane Doe No. 101 and 102 requesting a court order to compel Jeffrey Epstein to preserve all evidence, including electronic data, documents, and physical items located at his six international properties. The plaintiffs argue that given Epstein's status as a sex offender and his previous attempts to reclaim seized property (which may include child pornography), there is a high risk he will destroy incriminating evidence, including flight logs ('records of domestic and international travel') and computer files. The document lists the specific types of digital and physical evidence sought and notes that Epstein's counsel had failed to respond to a previous preservation letter.
This document is a formal legal letter dated May 15, 2009, from Robert C. Josefsberg of Podhurst Orseck to Jeffrey Epstein's attorneys (Robert Critton and Jack Goldberger). The letter demands the immediate preservation of all evidence, particularly electronically stored information (ESI), relevant to pending civil actions by victims of Epstein's sexual exploitation. It specifically references the Non-Prosecution Agreement, the 2005 FBI raid, and warns that failure to preserve data could result in sanctions for spoliation.
This document is a Motion for Limited Appearance filed on May 21, 2009, in the US District Court for the Southern District of Florida (Case 9:09-CV-80591-KAM). Robert D. Critton, Jr. requests the court to admit Michael D. Shumsky of Kirkland & Ellis LLP as co-counsel for the defendant, Jeffrey Epstein. The document lists legal counsel for both the plaintiff (Jane Doe 101) and the defendant, along with their contact information.
This document is a legal motion filed on May 21, 2009, in the Southern District of Florida case Jane Doe 101 v. Jeffrey Epstein. Local counsel Robert D. Critton, Jr. requests the court to admit Jay P. Lefkowitz (of Kirkland & Ellis LLP) pro hac vice to represent Jeffrey Epstein. The document outlines Lefkowitz's qualifications, confirms payment of the admission fee, and provides service information for all counsel of record.
This document is an unopposed motion filed on May 18, 2009, by Jeffrey Epstein's legal counsel in the case of Jane Doe No. 101 v. Jeffrey Epstein in the Southern District of Florida. Epstein's lawyers requested permission to exceed the standard 20-page limit for their upcoming motion to dismiss, citing complex legal issues regarding the interpretation of 18 U.S.C. §2255 and its applicability to the alleged conduct. Plaintiff's counsel agreed to this request via telephone.
This document is a legal response filed by Jeffrey Epstein's legal team on May 11, 2009, in the case of Jane Doe No. 101 v. Jeffrey Epstein. Epstein's attorneys oppose the plaintiff's motion to proceed anonymously, arguing that Epstein's due process rights to conduct discovery—specifically issuance of third-party subpoenas to medical providers and employers—require the use of the plaintiff's legal name. The filing asserts that the plaintiff's privacy interests do not outweigh the presumption of open judicial proceedings and Epstein's right to defend himself against allegations of sexual exploitation and coercion.
This document is a Notice of Appearance filed on May 7, 2009, in the United States District Court for the Southern District of Florida (Case No. 09-80591-MARRA/JOHNSON). Attorneys Robert D. Critton, Jr. and Michael J. Pike of the law firm Burman, Critton, Luttier & Coleman formally enter their appearance as counsel for the Defendant, Jeffrey Epstein. The document includes a Certificate of Service listing counsel for the Plaintiff (Jane Doe No. 101) and co-counsel for the Defendant.
This document is a 'Motion to Proceed Anonymously' filed on April 17, 2009, in the Southern District of Florida by Jane Doe No. 101 against Jeffrey Epstein. The plaintiff, represented by Podhurst Orseck, P.A., requests to use a pseudonym because she was sexually abused by Epstein as a minor and wishes to avoid further psychological trauma and public humiliation. The motion notes that Epstein already knows her identity from the related criminal investigation and cites precedents where other victims (Jane Does 1-7, etc.) were granted anonymity.
Legal filing from May 4, 2009, in the case of Jane Doe No. 101 v. Jeffrey Epstein in the Southern District of Florida. Epstein's legal team accepts consolidation of multiple civil cases for depositions but opposes general consolidation for all discovery, arguing that individual cases have distinct facts and defenses that would be confused by a blanket consolidation. The document lists numerous related case numbers (e.g., 08-80119, 08-80381, 09-80469) and requests clarification on the court's previous orders regarding case management.
This document is an unopposed motion filed on May 4, 2009, by Jeffrey Epstein's attorneys in the case of Jane Doe No. 101 v. Jeffrey Epstein (Case No. 09-80591) in the Southern District of Florida. Epstein's counsel requests an extension until May 26, 2009, to respond to the complaint filed on April 17, 2009. The reasons cited include the burden of other cases naming Epstein as a defendant and a conflicting state court trial scheduled for mid-May involving the defense counsel.
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.
This document is a legal response filed by Plaintiff Jane Doe 101 in the United States District Court for the Southern District of Florida on May 1, 2009. The plaintiff agrees to the court's order to consolidate ten separate cases filed by various Jane Does and C.M.A. against Jeffrey Epstein for the purposes of discovery. The document includes a service list detailing the contact information for attorneys representing the various plaintiffs and the defendant.
Summons in a Civil Case issued on April 17, 2009, by the US District Court for the Southern District of Florida for Case No. 09-80591 (Jane Doe 101 v. Jeffrey Epstein). The document summons Jeffrey Epstein, noted as being located at the Palm Beach County Stockade, to answer the complaint within 20 days. It lists Epstein's defense counsel (Spicer, Goldberger, Critton) and the plaintiff's attorneys (Josefsberg and Ezell of Podhurst Orseck, P.A.).
This document is a civil complaint filed on April 17, 2009, by Jane Doe No. 101 against Jeffrey Epstein in the Southern District of Florida. The plaintiff alleges that in 2003, when she was a 17-year-old high school student, she was recruited and transported to Epstein's Palm Beach mansion where she was sexually assaulted under the guise of giving massages. The complaint asserts causes of action under 18 U.S.C. § 2255 regarding coercion, travel with intent to engage in illicit sexual conduct, sex trafficking, and transport of child pornography.
This document is an Emergency Motion filed on June 14, 2010, by Jeffrey Epstein's legal team to quash a subpoena and prevent the deposition of Maritza Milagros Vasquez, scheduled for the following day. Epstein's lawyers argue that the subpoena issued by C.L.'s counsel (Spencer Kuvin) is premature under Rule 26(d) and that the cross-notice by Jane Doe's counsel (Brad Edwards) is invalid because discovery in the Jane Doe case had already concluded on May 31, 2010. The document includes the motion, a subpoena exhibit, and a cross-notice exhibit.
An email chain from April 2020 involving an FBI agent, attorney Robert Josefsberg, and Brittany Henderson. The correspondence clarifies FBI Victim Assistance policies, specifically stating that while standard coverage is six counseling sessions, victims residing in Florida may be approved for up to 12 sessions by a case agent. The thread also references a previous meeting in Miami regarding these matters.
This document is an email chain between attorney Jack Scarola and an Assistant United States Attorney (SDNY) regarding the prosecution of Jeffrey Epstein. Scarola identifies a victim who was molested in Florida beginning at age 14 and received lingerie gifts from Epstein. The correspondence coordinates a potential meeting between federal investigators and the victim in Florida.
Requesting a phone call, noting he is out of the office.
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.
Thanking for the offer of counseling and dedication to the situation. Stating they will contact clients regarding the offer.
Offering counseling and victim services resources. Providing contact info for FBI Special Agent.
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).
Request to reschedule hearing from June 12, 2009 due to counsel's 50th college reunion.
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 for Limited Appearance via CM/ECF
Follow up on the April 17th letter, threatening court relief if no response.
Requesting written confirmation that Epstein and his agents will not contact victims.
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.
I will be out of the office on Monday Dec. 22 and return Monday Jan 3.
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