Fort Lauderdale, Florida
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076.pdf
This document is a Joint Stipulation for Dismissal filed on December 8, 2020, in the U.S. District Court (SDNY). The plaintiff 'VE' and the defendants (Epstein's estate executors Indyke and Kahn, along with associated entities) agreed to dismiss the case with prejudice because the plaintiff resolved her claims through the Epstein Victims' Compensation Program. The order was signed by Judge Alison J. Nathan.
065.pdf
This document is a Joint Stipulation and Proposed Order filed on June 12, 2020, in the U.S. District Court for the Southern District of New York (Case No. 1:19-cv-07625). The plaintiff, identified as 'VE', and the defendants (Executors of the Epstein Estate and associated entities) agreed to stay the lawsuit to allow the plaintiff to participate in the 'Epstein Victims' Compensation Program', a non-adversarial alternative for resolving sexual abuse claims. The document is signed by attorneys Brad Edwards (for the plaintiff) and Bennet J. Moskowitz (for the defendants).
006.pdf
This document is a Motion for Admission Pro Hac Vice filed on August 27, 2019, in the Southern District of New York. Attorney Brittany N. Henderson of Edwards Pottinger, LLC requests permission to represent Plaintiff 'VE' in a civil case against the Estate of Jeffrey E. Epstein and associated entities (Nine East 71st Street Corp, Financial Trust Company, NES LLC). Henderson certifies her good standing with the Florida bar.
061.pdf
This document is a Supplemental Appendix filed by Palm Beach Newspapers, Inc. in a Florida state court case involving Jeffrey Epstein. It contains a transcript of a June 2009 hearing regarding the unsealing of court records, administrative orders, case law, and federal court filings including a declaration by AUSA A. Marie Villafana regarding the federal Non-Prosecution Agreement (NPA). The appendix documents the legal arguments surrounding the transparency of the Epstein proceedings and the government's interaction with victims under the Crime Victims' Rights Act.
060.pdf
This document is a response filed by Palm Beach Newspapers, Inc. (The Palm Beach Post) to an emergency petition for writ of certiorari by Jeffrey Epstein. The Post argues that the trial court correctly unsealed a Non-Prosecution Agreement (NPA) and its addendum related to Epstein's solicitation of minors, asserting that the documents were improperly sealed in the first instance and that no valid legal basis exists for their continued closure.
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.
026.pdf
This document is a Court Order from the Southern District of Florida dated December 6, 2010, in the case of M.J. v. Jeffrey Epstein and Sarah Kellen. Magistrate Judge Lurana S. Snow granted Jeffrey Epstein's unopposed motion for an extension of time to respond to the Plaintiff's motions regarding a protective order and preservation of evidence. The new deadline for Epstein's response was set for December 13, 2010.
024.pdf
A court order from the Southern District of Florida dated November 23, 2010, in the case of M.J. vs. Jeffrey Epstein and Sarah Kellen. Judge William P. Dimitrouleas granted a motion allowing attorney Paul G. Cassell to appear on behalf of the Plaintiff and receive electronic filings.
017-19.pdf
Plaintiff Jane Doe filed an emergency motion to hold Jeffrey Epstein in contempt for failing to comply with discovery orders in a civil case (08-CV-80893). The motion alleges that Epstein failed to produce state criminal discovery materials and provided only heavily redacted correspondence with the U.S. Attorney's Office, obscuring the defense counsel's side of the communications. Doe seeks immediate production of unredacted documents, sanctions of $5,000 against Epstein's counsel, and a ruling that withheld materials be deemed admissible at trial.
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.
016-05.pdf
This document is a motion filed on June 30, 2010, by Plaintiff Jane Doe requesting the modification of a court order regarding an upcoming settlement conference with Jeffrey Epstein. Doe requests that Epstein be kept in a secure, separate room to prevent any contact or intimidation, citing his status as a convicted sex offender and previous incidents where he intimidated victims, specifically Jane Doe No. 4, during court proceedings. The motion references Epstein's 2008 guilty plea and strict no-contact orders issued by both state and federal courts.
015.pdf
This document is a Plaintiff's Response to Defendant Jeffrey Epstein's Motion to Quash Service of Process. The plaintiff, M.J., argues that service was properly effected on October 8, 2010, when a private investigator handed the papers to an employee named 'Mark' at Epstein's New York mansion. The filing accuses Epstein and his associate Richard Barnett of fraud and perjury for submitting an affidavit claiming service never occurred, and details a pattern of obstruction by Epstein and his associates (including Ghislaine Maxwell and Jean Luc Brunel) in similar civil cases.
014.pdf
A legal motion filed on November 10, 2010, by Jeffrey Epstein's attorneys requesting the court to quash service of process in the case of M.J. v. Epstein. The defense argues that leaving an unmarked envelope in the mailbox of Epstein's New York vacation home and claiming to leave papers with a non-existent person named 'Mark' violates Federal, New York, and Florida service laws. The document includes arguments citing specific statutes and an affidavit from Richard Barnett denying the presence of anyone named 'Mark' at the residence.
007.pdf
This document is a Motion to Quash Service of Process filed by Jeffrey Epstein's legal team on October 29, 2010, in the Southern District of Florida. Epstein's lawyers argue that the plaintiff, 'M.J.', failed to properly serve Epstein with the lawsuit because the documents were merely left in an unmarked envelope in the mailbox of his New York residence (9 East 71st Street) rather than being delivered personally as required by law. The document details the specific dates of the attempted service and cites Florida, New York, and Federal laws to support the argument that the service was legally ineffective.
020.pdf
This document is a Motion to Dismiss filed by Jeffrey Epstein's legal team on June 16, 2010, in the case of L.M. v. Epstein. Epstein's lawyers argue the case should be dismissed because the plaintiff failed to serve the complaint within the required 120 days (Rule 4(m)). Furthermore, the motion alleges that the complaint filed by L.M. (represented by Bradley Edwards) was used as a prop in Scott Rothstein's massive $1.2 billion Ponzi scheme to lure investors with fabricated settlement agreements. The document cites depositions where L.M. contradicts allegations made in her complaint regarding sexual acts and travel.
020-01.pdf
This document contains a series of court orders and motions from the case *Morse v. Jan Jones International, Inc.* (Case 9:09-cv-81092-KAM) in the Southern District of Florida. The Plaintiffs, represented by Scott Rothstein, successfully argued that Jan Jones committed fraud and illegally moved funds to the Cayman Islands, resulting in an order for over $23 million in damages and the seizure of assets. The document includes a Stipulated Confidentiality Order and a subsequent Order on Emergency Writ of Mandamus from the 11th Circuit Court of Appeals, which reinstated the District Court's orders and mandated review by the Department of Treasury and FBI due to the sensitive nature of the government's investigation.
004.pdf
A court order from the U.S. District Court for the Southern District of Florida transferring civil case 09-81092 (L.M. v. Jeffrey Epstein) from Judge James I. Cohn to Judge Kenneth A. Marra. The order was signed by Judge Cohn on July 28, 2009, and accepted by Judge Marra on July 29, 2009, citing Internal Operating Procedure 2.15.C.
003.pdf
This document is a 'Motion to Proceed Anonymously' filed on July 24, 2009, in the U.S. District Court for the Southern District of Florida (Case No. 09-CV-81092). The plaintiff, identified as 'L.M.', is a 20-year-old female alleging she was sexually abused by Jeffrey Epstein between the ages of 14 and 17. The motion argues that her identity should be protected due to the sensitive nature of the allegations and notes she was previously identified as a victim by the FBI and U.S. Attorney's office in a criminal investigation against Epstein.
001-02.pdf
This document is a legal filing (Counts 108 through 156 of a larger complaint) from Case 9:09-cv-81092-KAM, filed on July 24, 2009, in the Southern District of Florida. Plaintiff L.M. alleges that Jeffrey Epstein committed multiple federal sexual offenses against her, including coercion, prostitution, and sex trafficking of a minor, occurring repeatedly between October 2004 and October 2005. The document concludes with a civil cover sheet demanding a jury trial and damages in excess of $1,000,000.
013-02.pdf
This document is a Notice of Withdrawal of Motion for Partial Summary Judgment filed on April 8, 2016, in a Florida Circuit Court case between Bradley J. Edwards/Paul G. Cassell and Alan M. Dershowitz. The plaintiffs withdraw their motion pursuant to a confidential settlement agreement but explicitly state that their client, Virginia Giuffre, reaffirms her allegations and that the withdrawal is not an admission that her allegations were mistaken. They concede that filing certain allegations in a separate Crime Victims' Rights Act case was a 'tactical mistake' that caused distractions.
001-01.pdf
Legal declaration by attorney Bradley J. Edwards filed on June 13, 2016, in support of a motion to quash a subpoena from Ghislaine Maxwell. Edwards details his representation of Virginia Giuffre and the undue burden of reviewing over 200,000 emails for communications with journalists. He explicitly states that Ghislaine Maxwell and Jeffrey Epstein share a joint defense agreement and mentions Giuffre's association with the organization 'Victims Refuse Silence, Inc.'
042.pdf
This document is a 'Joint Stipulation for Dismissal' filed on November 9, 2020, in the U.S. District Court for the Southern District of New York (Case 1:19-cv-11869). Plaintiff 'Anastasia Doe' agrees to dismiss her case against the Co-Executors of the Jeffrey Epstein Estate (Indyke and Kahn) with prejudice because her claims were resolved through the Epstein Victims' Compensation Program. The order is signed by Judge Mary Kay Vyskocil.
016.pdf
This document is a Joint Proposed Discovery Schedule filed on February 6, 2020, in the Southern District of New York case 'Anastasia Doe v. Darren K. Indyke and Richard D. Kahn'. It outlines the timeline and procedural rules for the discovery phase of the lawsuit against the Estate of Jeffrey Epstein, including deadlines for initial disclosures, document requests, and expert discovery.
011-01.pdf
This document is an affirmation filed on January 13, 2020, by attorney Brittany N. Henderson of Edwards Pottinger, LLC, in support of her application for admission pro hac vice in the case of Anastasia Doe v. The Estate of Jeffrey Epstein. Henderson declares she has no criminal record or disciplinary history and includes certificates of good standing from the Supreme Court of Florida (dated Dec 31, 2019) and The Florida Bar (dated Jan 10, 2020).
003.pdf
This document is a Motion for Admission Pro Hac Vice filed on December 27, 2019, in the Southern District of New York. Attorney Bradley J. Edwards seeks permission to represent Plaintiff Anastasia Doe in her lawsuit against Darren K. Indyke and Richard D. Kahan, the co-executors of the Estate of Jeffrey E. Epstein. Edwards attests to his good standing with the Florida and New York bars and lack of disciplinary history.
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