ICC
OrganizationRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
LANNA BELOHLAVEK
|
Legal representative |
5
|
1 | |
|
person
Wu Shangzhi
|
Employee |
5
|
1 | |
|
person
Wu Shangzhi
|
Professional |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2008-06-18 | N/A | Letter mailed via US Postage | Palm Beach Gardens, FL (Zip... | View |
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.
021.pdf
This document is an 'Opposition to Remand Motion' filed by defendants Jeffrey Epstein and Sarah Kellen in September 2008 in the Southern District of Florida. The defendants argue that the case should remain in federal court because the plaintiff fraudulently joined co-defendant Haley Robson (a Florida resident) solely to destroy diversity jurisdiction. The filing contends that the plaintiff has no valid cause of action against Robson for civil conspiracy, intentional infliction of emotional distress (IIED), or civil RICO under Florida law, arguing that Robson's alleged actions do not meet the legal standards for these torts.
019.pdf
Defendant Jeffrey Epstein moves to dismiss Counts I (sexual assault), II (civil conspiracy), and IV (civil RICO) of Jane Doe's amended complaint. The motion argues that the sexual assault claim improperly relies on a criminal statute with no private right of action, the conspiracy claim lacks an actionable underlying tort, and the RICO claim fails to allege a direct injury resulting from a predicate act. The document outlines relevant Florida case law and statutes to support the dismissal of these claims.
018.pdf
This document is a Motion for Stay filed by defendants Jeffrey Epstein and Sarah Kellen in a civil lawsuit brought by Jane Doe. They argue that a stay is mandatory under federal law because of a pending federal criminal investigation/action (the deferred prosecution agreement). Attached is a declaration from AUSA A. Marie Villafana detailing the government's interaction with victims (T.M., C.W., S.R.) and providing copies of notification letters sent to them and their attorneys regarding their rights and the non-prosecution agreement.
017.pdf
This document is a Motion to File Under Seal submitted by defendants Jeffrey Epstein and Sarah Kellen on July 25, 2008, in the case of Jane Doe v. Epstein et al. The defendants request to seal their 'motion for stay' to protect a confidential agreement between Epstein and the U.S. Attorney's Office for the Southern District of Florida. The document includes certificates of compliance and service, noting that the plaintiff opposes the motion, and lists the legal counsel representing all parties involved.
016-01.pdf
This document contains a Proposed Order and an Unopposed Motion for Enlargement of Time filed by Plaintiff Jane Doe in a civil case against Jeffrey Epstein, Haley Robson, and Sarah Kellen (Case No. 08-80804). Filed on August 13, 2008, the motion requests an extension to file a Civil RICO Case Statement until after the court rules on an upcoming motion to remand the case back to state court. The plaintiff argues the case was improperly removed to federal court and lacks federal jurisdiction. The document includes a service list identifying legal counsel for all parties, including Bruce Reinhart representing Sarah Kellen.
014.pdf
This document is a legal response filed on August 22, 2008, by Jeffrey Epstein's legal team in the case of Jane Doe vs. Jeffrey Epstein, Haley Robson, and Sarah Kellen. Epstein's lawyers state they have no opposition to the plaintiff's Motion to Preserve Evidence (DE 12). However, they dispute the plaintiff's certification of compliance, arguing that plaintiff's counsel filed the motion prematurely without properly conferring with the defense or waiting for a return call regarding Epstein's position.
012.pdf
This document is a motion filed on August 21, 2008, by Plaintiff Jane Doe in a civil case against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The plaintiff requests the court to preserve evidence seized by the Palm Beach Police Department from Epstein's home, citing concerns that Epstein (who had recently pleaded guilty and was in jail) was attempting to retrieve the evidence through State Court and might destroy it. The document includes a service list identifying legal counsel for all parties, including Bruce E. Reinhart representing Sarah Kellen.
011.pdf
This document is a Motion to Remand filed on August 18, 2008, by Plaintiff Jane Doe against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The plaintiff seeks to move the case back to Florida state court, arguing that federal diversity jurisdiction is invalid because both the Plaintiff and Defendant Haley Robson are Florida citizens. The motion details allegations that Robson recruited the plaintiff (a minor at the time) for Epstein's sexual abuse scheme and argues that Robson is a legitimate defendant, not 'fraudulently joined' solely to prevent federal jurisdiction.
008.pdf
This document is a motion filed by Jeffrey Epstein's legal team on August 8, 2008, requesting an extension to file a response to the complaint in the case of Jane Doe #1. Epstein's lawyers argue that the deadline should be aligned with parallel cases (Jane Doe Nos. 2-5) to September 4, 2008, to promote judicial economy. The document notes that co-defendants Haley Robson and Sarah Kellen had not yet been served at the time of filing.
003.pdf
This document is a Motion for Enlargement of Time filed on July 25, 2008, in the Southern District of Florida civil case Jane Doe v. Jeffrey Epstein, et al. Defendants Epstein and Sarah Kellen request an extension to answer the complaint until 10 days after a decision is made on their contemporaneous motion to stay the case, citing 18 U.S.C. § 3509 regarding civil stays during parallel criminal proceedings involving child victims. The document includes a service list detailing legal representation for all parties, including Bruce Reinhart as counsel for Sarah Kellen.
002.pdf
Defendants Jeffrey Epstein and Sarah Kellen filed a request for oral argument on July 25, 2008, in the Southern District of Florida regarding a motion to stay civil proceedings pending the resolution of a criminal action. The document lists legal representation for all parties, including Jane Doe (Plaintiff) and Haley Robson (Co-Defendant). Attorneys Michael R. Tein and Guy A. Lewis are the primary signatories for Epstein.
001.pdf
This document is a Notice of Removal filed by defendants Jeffrey Epstein, Sarah Kellen, and Haley Robson, seeking to move a civil lawsuit filed by Jane Doe from the Circuit Court of the Fifteenth Judicial Circuit in Palm Beach County, Florida, to the United States District Court for the Southern District of Florida. The defendants argue that the non-diverse defendant, Haley Robson, was fraudulently joined solely to defeat diversity jurisdiction and prevent removal. Attached as Exhibit A is a deposition transcript of Jane Doe (whose name is redacted) taken on February 20, 2008, in a related criminal case, where she is questioned about her age, MySpace profiles, inconsistencies in her statements to police regarding sexual contact with Epstein, and her interactions with various attorneys and law enforcement officials.
001-02.pdf
This document is a summons and affidavit of service related to a lawsuit filed in the 15th Judicial Circuit Court in Palm Beach County, Florida. Jane Doe, represented by her mother, is the plaintiff against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The document details the service of the summons on Sarah Kellen in New York City on April 19, 2008, and includes important legal notices in English, Spanish, and French regarding the lawsuit and the defendant's responsibilities.
008.pdf
This document is a Notice of Non-Opposition filed on February 14, 2008, in the case of Jane Doe No. 1 et al. v. Jeffrey Epstein in the Southern District of Florida. The plaintiffs (Jane Doe No. 1, her father, and stepmother) inform the court that they do not oppose the motion to intervene filed by Jane Doe's mother. The document lists the attorneys representing the plaintiffs from the firm Herman & Mermelstein, P.A.
005.pdf
This document is a 'Motion to Intervene and Supporting Memorandum of Law' filed on January 29, 2008, in the US District Court for the Southern District of Florida (Case No. 08-80069). Jane Doe's Mother seeks to intervene as a plaintiff in the lawsuit against Jeffrey Epstein, asserting she has claims sharing common questions of law and fact with the existing action. The document notes that Jane Doe's Father (a current plaintiff) does not agree to her intervention.
004.pdf
This is a Motion to Stay Proceedings filed on January 29, 2008, in the US District Court for the Southern District of Florida. Jane Doe's Mother (Intervenor-Plaintiff) requests the court pause the lawsuit against Jeffrey Epstein until Jane Doe No. 1 turns 18 on May 13, 2008. The motion reveals that Jane Doe No. 1 is estranged from her father (who filed the suit) and that the father filed the suit without her knowledge or consent.
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.
EFTA00037736.pdf
This document is an email chain from August 2019 detailing the FBI's attempt, via UK Metropolitan Police, to interview a female witness (DOB May 1973) regarding the Jeffrey Epstein investigation. While initially willing to cooperate on August 16th, the witness retracted her offer on August 19th following Epstein's death, citing fears for her safety and concerns that her name would appear on Twitter. The document includes a background check on the witness revealing no criminal trace, though a 2013 report of 'suspicious circumstances' exists in police databases.
EFTA00011039.pdf
This document is a daily intelligence news brief sent from a Senior Intelligence Specialist at the SDNY Terrorism & International Narcotics Unit on January 22, 2021. It covers various global and domestic security topics, including the retirement of the FBI Deputy Director, the arrest of a US soldier plotting with ISIS, fallout from the Jan 6 Capitol siege, terrorism in Indonesia and Somalia, and labor union ties to drug trafficking. A specific Epstein-related item notes that a Ghislaine Maxwell hearing was illegally streamed by QAnon followers.
DOJ-OGR-00030427.jpg
This is a page from a Motion for a Protective Order filed on February 5, 2008, by attorney Theodore J. Leopold on behalf of a 'Jane Doe' victim. The motion alleges that Jeffrey Epstein and his agents have been harassing the victim at her workplace, including an incident where a man falsely posed as an attorney to contact her. The document argues these actions are 'insult to injury' for an emotionally scarred girl and requests a court order prohibiting further harassment.
DOJ-OGR-00030399.jpg
This document is a scanned envelope from the law firm Ricci-Leopold P.A., addressed to Lanna Belohlavek, Esq. It was mailed on June 18, 2008, and stamped received on June 19, 2008. The document references File #: 080048 and is part of a larger Department of Justice public records release dated 2017.
DOJ-OGR-00030398.jpg
This document is a legal notice from Ricci~Leopold, P.A., dated June 18, 2008, informing all counsel that hearings scheduled for that day have been cancelled. The hearings pertained to Defendant Jeffrey Epstein's Motion for Enlargement of Time and Defendant Haley Robson's Motion to Quash Service of Process in the case of Jane Doe vs. Jeffrey Epstein, Haley Robson, and Sarah Kellen, filed in Palm Beach County, Florida.
DOJ-OGR-00030549.jpg
This document is the final page of a legal complaint filed in March 2008 by plaintiff "Jane Doe" against defendants Jeffrey Epstein, Haley Robson, and Sarah Kellen. It describes Epstein paying Jane Doe $300 and Robson $200 for bringing Jane Doe to him. The complaint, filed by attorney Theodore J. Leopold, demands a jury trial and seeks compensatory, treble, and punitive damages under Florida law.
DOJ-OGR-00031558.jpg
This document is the final page (page 3) of a legal motion filed on February 5, 2008, by attorney Theodore J. Leopold on behalf of a 'Jane Doe' victim. The motion requests a Protective Order against Jeffrey Epstein and his counsel, alleging systematic harassment, including an incident where an unidentified male claiming to be an attorney approached the victim at her workplace. The document asserts these actions are inflicting further emotional injury on a young girl already 'scarred for life'.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| 2018-01-01 | Received | Aurora | ICC | $0.00 | Acquisition of Uruguayan fully licensed ICC Lab... | View |
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