McIntosh, Sawran, Peltz & Cartaya, P.A.
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024.pdf
This document is an unopposed motion filed on September 18, 2008, by Plaintiff Jane Doe in the Southern District of Florida (Case 08-80804) against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The plaintiff requests an extension of time to respond to Epstein's Motion to Dismiss until 15 days after the court rules on a pending motion to remand the case to state court due to alleged lack of federal jurisdiction. The document lists legal counsel for all parties, 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.
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. ยง 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.
DOJ-OGR-00032368.jpg
This document is a service list for the 2008 court case No. 50 2008 CA 006596 XXXX MB AB. It provides the names, law firms, and contact information for the attorneys representing various parties in the case. Key parties and their counsel include the State of Florida (represented by Lanna Belohlavek), Jeffrey Epstein (represented by Jack A. Goldberger and Robert Critton), Sarah Kellen (represented by Bruce E. Reinhart), and Haley Robson (represented by Douglas M. McIntosh and Jason A. McGrath).
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