ATTERBURY, GOLDBERGER & WEISS, P.A.
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082.pdf
A Notice of Hearing filed in the Circuit Court of Palm Beach County, Florida, regarding the case State of Florida vs. Jeffrey Epstein (Case No. 2008CF009381A). The document, signed by Epstein's attorney Jack A. Goldberger on December 16, 2009, schedules a hearing for December 18, 2009, before Judge Jeffrey Colbath to discuss a 'Motion to Authorize Travel'. The notice is addressed to Barbara Burns at the State Attorney's Office and Carmen Sloane at the Department of Corrections.
081.pdf
This document is a Motion for Authorization to Travel filed on December 17, 2009, in Palm Beach County, Florida, on behalf of Jeffrey Epstein. Epstein requests permission to travel to New York for three days to meet with his attorney, Harry Susman, review confidential documents, and interview witnesses related to ongoing litigation. The motion notes that his community control officer, Carmen Sloane, has no objection to the travel provided dates are cleared in advance.
077.pdf
This document is a motion filed on November 25, 2009, in Palm Beach County Circuit Court requesting authorization for Jeffrey Epstein to travel to New York City on two specific dates while under community control. The first request is for December 3, 2009, to review confidential documents with his civil counsel, Stephen Susman, at the law offices of Davis Polk and Wardwell regarding claims against D.B. Zwirn. The second request is for December 12, 2009, for a meeting with an unnamed 'governmental official from a foreign country.' Attached is a letter from Stephen Susman confirming the necessity of the December 3rd meeting.
076.pdf
This document is a 'Notice of Hearing' filed in the Circuit Court of Palm Beach County, Florida, for the case State of Florida vs. Jeffrey Epstein (Case No. 2008CF009381A). Defense attorney Jack A. Goldberger notifies State Attorney Barbara Burns of a hearing scheduled for November 30, 2009, before Judge Jeffrey Colbath regarding a 'Motion for Travel'. The document was filed on November 25, 2009.
071.pdf
This document is a Notice of Hearing filed in the Circuit Court of Palm Beach County, Florida, for Case No. 2008CF009381A (State of Florida vs. Jeffrey Epstein). The notice, signed by defense attorney Jack A. Goldberger on November 10, 2009, schedules a 'Status Conference RE: No Contact Order' for November 18, 2009, at 8:30 a.m. before Judge Jeffrey Colbath. The document was filed with the clerk on November 17, 2009.
068.pdf
This document is a Mandate from the Fourth District Court of Appeal of Florida, dated September 18, 2009, regarding the case of Jeffrey Epstein v. State of Florida. The mandate follows an opinion issued on September 2, 2009, where the court affirmed the lower court's decision, treating Epstein's petition for writ of certiorari as a full appeal. The document lists numerous attorneys involved, including R. Alexander Acosta on the distribution list, and identifies Palm Beach Newspapers, Inc. as an appellee alongside the State and a redacted party.
053.pdf
This document is a court order from June 26, 2009, issued by Judge Jeffrey J. Colbath in the Circuit Court of Palm Beach County, Florida. The order denies Jeffrey Epstein's motion to stay the disclosure of his Non-Prosecution Agreement and sets a deadline of July 2, 2009, for the Clerk to release the documents, allowing time for an appeal to the 4th DCA. The document includes a service list of attorneys involved, including U.S. Attorney R. Alexander Acosta and defense attorneys like Jack Goldberger.
041.pdf
This document is a 'Motion to Make Court Records Confidential' filed by Jeffrey Epstein's attorneys on June 11, 2009, in the Circuit Court of Palm Beach County. The defense seeks to maintain the seal on the Non-Prosecution Agreement (filed July 2008) and its Addendum, citing threats to the administration of justice and privacy rights of third parties. The motion references interventions by the Palm Beach Post and a non-party identified as 'EW' (whose name is redacted in one section) seeking access to these records.
034.pdf
This document is a motion filed on June 3, 2009, by a redacted nonparty (a victim of Jeffrey Epstein) seeking to unseal the Non-Prosecution Agreement (NPA) and its addendum in the Florida state criminal case. The motion argues the sealing violated Florida judicial rules and public policy, and that the documents are material to the victim's pending civil suit. Exhibits include judgments of conviction against Epstein for solicitation and procuring a minor, sealing orders from 2008, and transcripts from the June 30, 2008 plea conference where the existence of the federal NPA was discussed in open court.
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.
016-01.pdf
This document is a transcript of a plea conference for Jeffrey Epstein held in June 2008 in Palm Beach County Court. Epstein pleads guilty to state charges involving solicitation of prostitution and procuring a minor, agreeing to an 18-month jail sentence followed by community control (probation). The transcript details the specific conditions of his release, including residency at his Palm Beach home, work release at his own 'Florida Science Foundation' (located in the same building as his attorney), and strict prohibitions on contacting victims or minors.
MOTION-EXT%20OF%20TIME%20(JURIS%20BRIEF).pdf
This is a legal motion filed on December 14, 2015, in the Supreme Court of Florida (Case No. SC15-2286) by Jeffrey Epstein's attorney, Paul Morris. Epstein requests an extension of time until January 19, 2016, to file his initial brief on jurisdiction. The document notes that the Respondent's counsel, Philip M. Burlington, has no objection to the request, and includes a service list of attorneys involved in the related proceedings.
LETTER.pdf
This document is a legal filing dated December 10, 2015, in which Jeffrey Epstein's attorney, Paul Morris, files a 'Notice to Invoke Discretionary Jurisdiction' with the Supreme Court of Florida. Epstein is appealing a decision made on November 12, 2015, by the District Court of Appeal (Fourth District) in the case of 'Bradley J. Edwards v. Jeffrey Epstein'. The attached opinion reveals that the lower court reversed a summary judgment that had favored Epstein, ruling that 'litigation privilege' does not bar Edwards' claim of malicious prosecution against Epstein.
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 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.
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.
012-01.pdf
This document is a 2008 legal motion filed by Jeffrey Epstein's attorney requesting the return of property seized by the Palm Beach Police Department during the October 20, 2005, raid on Epstein's home at 358 El Brillo Way. Attached to the motion are six pages of police property receipts detailing the evidence confiscated, which includes multiple 'massage tables,' phone message books, computers, surveillance-style equipment described as 'Soap on Rope' found in bathrooms, and explicit materials including a 'black framed photo of nude girl' and pornographic videotapes found in the Master Bedroom. The inventory also lists a school transcript for an individual named Alexander Hall found in the Master Bedroom desk.
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.
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