Relationship Details

This document is a page from a legal filing, listing contact information for various attorneys and their respective clients in several related court cases. It details counsel for plaintiffs, including C.M.A., and counsel for defendants Sarah Kellen and Jeffrey Epstein, along with their law firms and contact details.

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.

This document is a Reply filed by Jeffrey Epstein's legal team in November 2009 requesting a permanent order for the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), which was undergoing restructuring. The filing highlights that the Department of Justice had seized approximately 40 boxes of documents from RRA, including about 13 boxes related to Epstein cases, amidst concerns of 'serious ethical and potentially criminal issues' at the firm. The document also argues against delaying the deposition of RRA's Chief Restructuring Officer, Herbert Stettin, citing upcoming trial deadlines.

This document is a motion filed on November 20, 2009, in the US District Court for the Southern District of Florida, requesting permission for Jeffrey Epstein to attend mediation in the case involving Carolyn Andriano (C.M.A.). The motion notes that a previous no-contact order exists regarding Andriano, but her counsel has no objection to Epstein attending the deposition, mediation, or trial. The document includes a service list detailing the attorneys involved in this and related cases, including Bruce Reinhart representing Sarah Kellen.

This document is a legal response filed by Plaintiff Carolyn M. Andriano (Jane Doe No. 2) opposing a motion by third-party witness Igor Zinoview to avoid deposition. Zinoview, who worked as Epstein's driver, bodyguard, and trainer starting in November 2005, claimed he had no relevant knowledge of Epstein's legal matters. The Plaintiff argues that Zinoview worked for Epstein during the police investigation period and likely has relevant observations, regardless of whether he discussed legal matters with Epstein.

This document is a Plaintiff's Memorandum of Law filed on July 14, 2009, in the case of Jane Doe II v. Jeffrey Epstein and Sarah Kellen. The Plaintiff opposes Sarah Kellen's motion to set aside a default judgment, arguing that Kellen was properly served via 'nail and mail' in New York on April 23, 2009, after six attempts, and deliberately ignored the lawsuit. The filing asserts Kellen has provided no evidence she didn't receive service and has failed to present a meritorious defense as required by law.

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.

Legal filing from July 2, 2010, in the case of Jane Doe II vs. Jeffrey Epstein and Sarah Kellen. Plaintiff's counsel Isidro Garcia responds to a court order, apologizing for delays in filing a scheduling report, partly attributing the delay to difficulty serving Sarah Kellen who was 'believed to have been avoiding service.' The document announces that a settlement has been reached resolving all claims in this federal case and a companion state court case.

This document is a legal response filed on November 28, 2009, by Plaintiff Carolyn M. Andriano (Jane Doe No. 2) in her civil case against Jeffrey Epstein. The filing opposes a motion by third-party witness Igor Zinoview—Epstein's driver, bodyguard, and trainer since November 2005—who sought to avoid being deposed by claiming he had no knowledge of relevant facts. The Plaintiff argues that Zinoview must be deposed because he worked for Epstein during the active Palm Beach Police investigation (2005-2006) and likely possesses knowledge regarding activities at the Epstein residence, especially since Epstein himself invoked the Fifth Amendment.

This document is a response filed by Plaintiff Carolyn M. Andriano on November 28, 2009, opposing a motion by third-party witness Igor Zinoview to prevent his deposition. Zinoview, who worked as Epstein's driver, bodyguard, and trainer starting in November 2005, claims he has no relevant knowledge of legal matters involving Epstein. The Plaintiff argues that because Zinoview worked for Epstein during the active police investigation (2005-2006), he likely possesses relevant information regarding activities at the Epstein residence, and that a complete bar on his deposition is legally unjustified.

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.

A 2009 legal motion filed in the Southern District of Florida on behalf of Jeffrey Epstein requesting permission to attend mediation in a case involving Carolyn Andriano (C.M.A.). The motion notes that a prior 'no contact order' exists regarding Andriano, but states that neither she nor her counsel object to Epstein's presence at depositions, mediation, or trial. The document includes a comprehensive service list of attorneys involved in multiple related cases against Epstein.

This document is a legal motion filed on November 9, 2009, by Igor Zinoviev, a third-party witness and employee of Jeffrey Epstein, seeking a protective order to prevent or limit his deposition in the civil case 'Jane Doe No. 2 v. Jeffrey Epstein'. Zinoviev claims he has no relevant information for the civil cases as his employment with Epstein began in November 2005, after the period of the alleged misconduct, and he has not discussed Epstein's criminal or civil cases with him.

This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, seeking a protective order to prevent or limit his deposition in the case of Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, a driver and bodyguard for Epstein since November 2005, claims he has no relevant information regarding Epstein's criminal or civil cases, particularly concerning events prior to September 2005. The motion cites legal precedents regarding the scope of discovery and Federal Rules of Civil Procedure Rule 26(c) to argue against the deposition.

This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, requesting a protective order to prevent his deposition in the case Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, who worked as a driver and bodyguard for Epstein since November 2005, argues he has no relevant information for the civil cases as his employment began after the alleged events and he never discussed the criminal or civil cases with Epstein.

This document is page 22 of a legal filing (likely a motion) detailing attorney Edwards' attempts to depose Jeffrey Epstein and his associates in 2010. It highlights that Epstein refused to answer questions on advice of counsel, and that associates Sarah Kellen, Nadia Marcinkova, and Adriana Mucinska Ross all invoked the Fifth Amendment to avoid self-incrimination regarding the procuring of young girls. The document specifically notes that Bruce Reinhart represented Sarah Kellen during her deposition.