document_description: This Tolling Agreement is made between Jeffrey Epstein and various entities related to D.B. Zwirn Special Opportunities Fund, including Fortress Investment Group LLC. The agreement addresses disputes concerning Epstein's investment in the fund and aims to resolve these disputes without litigation by tolling the statute of limitations until October 22, 2010, or earlier termination. The agreement specifies that neither party will commence litigation during the tolling period and outlines the terms for notices and amendments.


source: doj

document_description: This document is a legal response and counterclaim by Jeepers, Inc. and Financial Trust Company, Inc. against D.B. Zwirn Special Opportunities Fund, L.P. and related entities. It details allegations of breach of contract, promissory estoppel, fraud, breach of fiduciary duty, and negligent misrepresentation related to investment withdrawal requests. The document outlines the history of investments made by Jeffrey Epstein through Financial Trust Company, Inc., the subsequent transfer to Jeepers, Inc., and the disputes arising from attempts to withdraw funds from the D.B. Zwirn Special Opportunities Fund.


document_description: A letter from Maria Tankenson Hodge requesting the transfer of Jeffrey Epstein's supervision from Florida to the Virgin Islands under the Interstate Compact Relating to Probation and Parole. The letter outlines Epstein's residency and business ties to the Virgin Islands, his plea agreement in Florida, and the conditions of his probation. It seeks approval in principle for the transfer and mentions contact with Florida's Correction Services Administrator.


document_description: Proposal for installing a better residential antenna system using existing cabling. Includes installation of a Yagi Antenna, signal combiner, and a 10db amplifier. The proposal outlines the costs for equipment and labor.


document_description: A to-do list for DKI, including tasks related to legal motions, financial settlements, and follow-ups on various cases and transactions.


document_description: Affidavit by Juan Pablo Molyneux regarding a contractual dispute with Fancelli Paneling, Inc. over the incomplete and defective installation of library cabinetry on Little Saint James Island for Jeffrey Epstein. The affidavit details the agreement, design specifications, and the alleged failures of Fancelli to meet the contractual obligations.


document_description: The document is an estate report for Little St. James, detailing various projects and their statuses. It includes information on current events, active projects, and projects on hold, with specific details on each project's status, responsible person, and comments.


document_description: A letter from Darren K. Indyke to Jay Goldberg discussing issues related to the Design Services Agreement involving Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC, and Jeffrey Epstein. The letter addresses concerns about the timeline for delivery of woodworking materials and tools to Little St. James and the quality of globes to be delivered under the agreement. An extension of the completion deadline to February 1, 2010, is proposed, contingent on certain conditions being met.


document_description: A letter from Darren K. Indyke to Jay Goldberg addressing potential breach of obligations under a Design Services Agreement related to the completion of the Office Pavilion on Little Saint James island. The letter highlights delays and lack of response from Juan Pablo Molyneux and his studio regarding the installation of bookcases, paneling, and other design elements.


document_description: This document contains a table listing floor levels and key areas for a building project, along with notes on the status of the project and the involvement of Donald Insall Associates Limited.


document_description: Governor John P. deJongh, Jr. issued a proclamation granting administrative leave for government employees to celebrate the 58th Virgin Islands Carnival. The leave is intended to encourage participation in cultural activities and boost the local economy. The proclamation acknowledges contributions from key figures like Gerard Nicholson and J. Ingerborg Marrero, and names Lesmore Howard and former governor Roy L. Schneider as parade marshals.


document_description: Invoice from Podhurst Orseck, P.A. to Kirkland & Ellis, LLP for legal services related to Jeffrey Epstein case, detailing services provided, hours, and amounts charged.


document_description: A letter from Darren K. Indyke to Jay Goldberg regarding outstanding issues in a Design Services Agreement involving Jeffrey Epstein and Juan Pablo Molyneux. The letter references emails sent by Epstein to Molyneux about design details and requests a follow-up for completion by the extended deadline.


document_description: This document is a working draft of the Zwirn chronology, detailing the timeline of events related to the investments and agreements involving FTC, Highbridge Capital Management, and D.B. Zwirn & Co. It includes information on fund investments, advisory agreements, organizational document amendments, and various communications and agreements between the involved parties. Key events include the transition of Zwirn's role, amendments to partnership agreements, and issues related to fund management and redemption rights.


document_description: This letter from Jay P. Lefkowitz addresses questions posed by R. Alexander Acosta regarding the notification to alleged victims under 18 U.S.C. § 3771 and the 18 U.S.C. § 2255 component of the deferred-prosecution agreement in the Jeffrey Epstein case. Lefkowitz argues that the alleged victims do not qualify as 'crime victims' under the Attorney General Guidelines and raises concerns about the manageability of the § 2255 component. He requests reconsideration of sending notices to alleged victims and seeks further information from the U.S. Attorney's Office to resolve the § 2255 issue.


document_description: This document is a legal request for the production of documents in an arbitration case involving Fortress VRF I LLC, Fortress Value Recovery Fund I LLC, Jeepers, Inc., and Financial Trust Company, Inc. The document outlines definitions, instructions, and specific document requests related to the arbitration, including communications, financial transactions, and management details of the involved entities. Jeffrey Epstein is mentioned as an affiliate of the Financial Trust Company, Inc. and Jeepers, Inc.


document_description: A financial statement from Dr. Thomas Magnani and Dr. Alvin Grayson detailing patient charges and account balance for Jeff Okard.


document_description: A fax from Brian J Manning of Brown Harris Stevens to an unspecified recipient regarding a property at 9 E. 71st St. It includes a confidentiality agreement for a prospective customer interested in the property.


document_description: This document is a floor plan of the 33rd floor of TOWER 56, located at 126 E. 56th Street. The total area is 3,843 RSF. The plan includes dimensions for various offices, a conference room, a pantry, and other areas. The drawing is not to scale and includes a DWG number SSK-33.


document_description: Invoice for legal services rendered by Bruce E. Reinhart, P.A. to Jack Goldberger regarding Jeffrey Epstein. The invoice includes details of meetings, research, and drafting services provided between April and May 2009.


document_description: Maguire Group Inc. presents a proposal for revised Work Order No. 13 under a Master Agreement to provide engineering services for Little St. James Island. The services include site/civil engineering design for SWPPP, drainage improvement plans, and an island-wide CZM drawing package. The proposal outlines the scope, deliverables, and budget for the project.


document_description: This document is a legal request from Bradley J. Edwards, represented by Searcy Denney Scarola Barnhart & Shipley, to Jeffrey Epstein. It requests the production of various documents related to the case, including statements, documents related to communications with minor females, and evidence intended for trial.


document_description: This document is a legal notice from Bradley J. Edwards, the defendant/counterplaintiff, to Jeffrey Epstein, the plaintiff/counterdefendant, regarding expert interrogatories in a legal case. The notice includes a list of 16 expert interrogatories directed to Jeffrey Epstein, asking for details about expert witnesses, their qualifications, and any reports they have submitted. The document also includes a request to produce expert reports and information about expert compensation.


document_description: This document is a legal request for admissions and interrogatory filed by Bradley J. Edwards against Jeffrey Epstein. It includes a series of admissions related to Epstein's alleged sexual activities with minors, asset transfers, and frivolous lawsuits. The document also mentions socializing with notable figures and transporting minors on airplanes.


document_description: This document includes a motion filed by Bradley J. Edwards to expand the number of interrogatories in the case of Epstein v. Rothstein, et al. It also contains a notice of hearing scheduled for September 23, 2010, before Judge David F. Crow. The motion argues that the complexity of the case requires more than the standard 25 interrogatories. The document is signed by Jack Scarola, attorney for Bradley J. Edwards.


document_description: Invoice detailing legal services provided by Podhurst Orseck, P.A. to Kirkland & Ellis, LLP for the matter concerning Jeffrey Epstein. The invoice includes a breakdown of services, hours, and amounts charged.


document_description: Flight itinerary for Jeffrey Epstein on October 31, 2010, from Laurence G Hanscom Field (KBED) to Teterboro (KTEB) on a Beechjet/Hawker 400XP. The lead passenger is Jeffrey Epstein, with two other passengers whose names are redacted. The flight is operated by Shmitka Air, Inc. and includes details about the flight duration, distance, and FBOs used.


document_description: Statement of account for Gulfstream IIB N909JE as of November 23, 2010, detailing invoices, payments, and balance due.


document_description: This document is an Agreed Order regarding Jeffrey Epstein's Motion for Enlargement of Time to File the Joint Statement in the case against Scott Rothstein and others. The motion is granted, allowing Epstein until October 8, 2010, to file the statement.


document_description: This document is a Joint Statement and Initial Case Management Report for the case of Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards. The plaintiff, Jeffrey Epstein, seeks damages against the defendants based on an alleged illegal Ponzi scheme to market investments to outside investors in lawsuits against Epstein. The document outlines the legal theories, likelihood of settlement, proposed time limits, and other procedural details of the case.


document_description: This document is a legal motion filed by Bradley J. Edwards against Jeffrey Epstein, seeking to compel the plaintiff to respond to a Request to Produce or alternatively to strike the plaintiff's claim for damages. It includes a notice of hearing scheduled for October 21, 2010, at the Palm Beach County Courthouse. The motion argues that the plaintiff's objections to the request are not well-founded and that the plaintiff cannot seek affirmative relief while maintaining privilege assertions.


document_description: A letter submitted to the New York State Board of Examiners of Sex Offenders regarding Jeffrey Epstein's risk level and designation determination. The letter argues for a level 1 designation based on Epstein's history, personal characteristics, acceptance of responsibility, completion of sentence, and low risk of reoffending. It includes references to Epstein's philanthropic work, his classification as a low-level sex offender in Florida, and his ongoing therapy with Dr. Stephen R. Alexander.


document_description: Alan Dershowitz provides an accounting of his hours and payments related to his legal work for Jeffrey Epstein. The letter details the hours worked, billing rates, payments received, and amounts still owed. It also mentions a retainer and a 'war chest' provided by Epstein.


document_description: The document outlines the judicial determination process for classifying an offender as a sexual predator, sexually violent offender, or predicate sex offender. It details the procedures for notification, representation, and the determination hearing, including the rights of the offender and the responsibilities of the court and district attorney. It also covers the appeal process and the expungement of records upon reversal of a conviction.


document_description: Maguire Group Inc. presents a proposal for Work Order No. 17 under the Master Agreement to provide architectural and engineering services for Little St. James Island. The proposal includes revisions to the mechanical building design, with specific changes to the architectural, structural, mechanical, electrical, and plumbing plans. The budget for the project is $53,500, with services billed on an hourly basis plus reimbursable expenses.


document_description: This document is an e-Ticket receipt and itinerary for a flight booked with Emirates. The passenger, Jeffrey Epstein, is scheduled to fly from New York (JFK) to Dubai (DXB) on November 4, 2010, in First Class. The total fare is USD 9363.10, paid by credit card. The document includes flight details, fare calculations, and additional information.


document_description: This document is an Emirates e-Ticket receipt and itinerary for a flight from New York (JFK) to Dubai (DXB) on 04 November 2010. The passenger is booked in Business Class with a baggage allowance of 2 pieces. The total fare is USD 6189.10, paid by credit card. The booking reference is CDTTYN and the e-ticket number is 1762138130956.


document_description: Plaintiff M.J. responds to Jeffrey Epstein's motion to quash service of process, alleging that Epstein was properly served and that his submission of a fraudulent affidavit constitutes obstruction. M.J. seeks sanctions against Epstein, a warning against further obstruction, and an accelerated discovery schedule. The document details Epstein's history of obstructing legal proceedings and includes allegations of sexual abuse by Epstein against M.J. when she was a minor.


document_description: This memorandum from Kirkland & Ellis LLP discusses the SORA (Sex Offender Registration Act) determination for Jeffrey Epstein, arguing for a Level 1 classification. It outlines Epstein's conviction in Florida for procuring a person under 18 for prostitution and his subsequent registration as a sex offender in multiple jurisdictions. The memo argues that Epstein poses a minimal risk of reoffense, citing his compliance with legal requirements, psychological evaluations, and the low-level risk assessments by other jurisdictions. It also critiques the Board of Examiners of Sex Offenders' recommendation for a Level 3 classification, arguing it is based on unreliable evidence and hearsay.


document_description: This memorandum from Kirkland & Ellis LLP discusses the SORA (Sex Offender Registration Act) determination for Jeffrey Epstein, arguing against the New York Board of Examiners of Sex Offenders' recommendation to categorize him as a Level 3 sex offender. The memo highlights Epstein's minimal ties to New York, his compliance with registration in other jurisdictions, and the legal inconsistencies in the Board's recommendation. It advocates for a Level 1 designation, citing Epstein's low risk of reoffending and his compliance with legal obligations in other states.


document_description: This letter from Kirkland & Ellis LLP, addressed to Jennifer Gaffney and Patrick Egan of the New York District Attorney's Office, argues for Jeffrey Epstein to be designated as a Level 1 offender under New York's Sex Offender Registration Act (SORA). The letter outlines Epstein's minimal ties to New York, his compliance with registration in other jurisdictions, and the legal arguments against a Level 3 designation. It emphasizes Epstein's low risk of reoffending and his philanthropic contributions.


document_description: Notice of Hearing for the case of Jeffrey Epstein vs. Scott Rothstein and Bradley J. Edwards. The hearing is scheduled for January 5, 2011, at 4:00 p.m. before Judge David F. Crow at the Palm Beach County Courthouse. The specific matter to be heard is Edwards' Motion for Leave to Assert Claim for Punitive Damages.


document_description: This document is a subpoena for a Rule 2004 Examination Duces Tecum related to the bankruptcy case of Rothstein Rosenfeldt Adler, P.A. It commands the Records Custodian for Herbert Stettin, Trustee in Bankruptcy, to appear for a deposition and produce documents related to litigation involving Jeffrey Epstein. The document lists specific documents and communications to be produced, including those involving notable figures such as Bill Clinton, Alan Dershowitz, and Donald Trump.


document_description: This document is a joint statement and initial case management report for the case Epstein v. Rothstein, et al. It outlines the factual background, legal theories, likelihood of settlement, and other procedural details of the case. The plaintiff, Jeffrey Epstein, seeks damages against defendants Scott Rothstein and Bradley J. Edwards for an alleged Ponzi scheme involving fraudulent investments related to lawsuits against Epstein. The document also discusses the legal claims, potential for additional parties, and proposed timelines for the case.


document_description: Defendant Bradley J. Edwards requests the court to compel Jeffrey Epstein to respond to a Request to Produce or to strike Epstein's claim for damages. The motion argues that Epstein's objections deny Edwards access to essential information for his defense. Epstein's response cites attorney/client privilege and constitutional rights, but agrees to produce some redacted documents.


document_description: A series of letters from Fried, Frank, Harris, Shriver & Jacobson LLP to the SEC regarding D.B. Zwirn & Co., L.P. The letters discuss the voluntary production of documents, confidentiality claims, and responses to SEC requests. The correspondence includes Bates-stamped documents and claims of confidentiality under FOIA.


document_description: This document is a legal notice for the deposition of Scott Rothstein in the case of Jeffrey Epstein v. Scott Rothstein, et al. The deposition is scheduled for November 19, 2010, at the Turner Guilford Knight Correctional Center in Miami, Florida. The notice is issued by Joseph L. Ackerman, Jr. of Fowler White Burnett, representing Jeffrey Epstein.


document_description: This document is a legal request for admissions from Jeffrey Epstein to Bradley J. Edwards, asking Edwards to admit or deny various statements related to cases against Epstein. It includes references to depositions, complaints, and motions filed in relation to Epstein's legal matters.


document_description: This document is a legal request for admissions from Jeffrey Epstein to Bradley J. Edwards, asking Edwards to admit or deny various statements related to legal actions involving Epstein. It includes references to multiple cases, depositions, and legal motions.


document_description: This document is a legal request for admissions from Jeffrey Epstein to Bradley J. Edwards, asking Edwards to admit or deny various statements related to a complaint filed in the case M. v. Jeffrey Epstein, Case No. 09-CV-81092. The document includes 53 requests for admissions, covering topics such as the filing of complaints, involvement of other individuals, and the accuracy of previous testimonies and statements.


document_description: Jay Lefkowitz addresses Bob regarding payment disputes related to Jeffrey Epstein's obligations under the Non-Prosecution Agreement (NPA). Lefkowitz clarifies that Epstein's payment obligations are limited to settling cases of identified women and not for adversarial litigation or hiring outside experts. He recalls personal discussions with Bob and suggests involving a neutral third party to evaluate fee issues.


document_description: This letter from Darren K. Indyke addresses concerns regarding the Design Services Agreement between Jeffrey Epstein and Juan Pablo Molyneux. Indyke refutes claims made by Jay Goldberg about Epstein's unreasonable behavior, highlighting Epstein's financial concessions and Molyneux's failure to meet obligations. The letter discusses issues with cabinetry, furniture, and design elements, emphasizing Epstein's reasonable requests and Molyneux's responsibility to complete the Office Pavilion by April 15, 2010.


document_description: This document outlines the New York Penal Law 230.06 regarding the offense of patronizing a prostitute in the first degree, which is classified as a class D felony. It specifies that the offense occurs when a person patronizes a prostitute who is less than eleven years of age.


document_description: This document outlines the legal statute for patronizing a prostitute in the second degree in New York, which is classified as a class E felony. It specifies that the offense occurs when an adult patronizes a prostitute under the age of fourteen. The document includes historical context, notes from the Commission Staff, and references to related legal texts and case notes.


document_description: This document outlines the New York Penal Law 230.04 regarding patronizing a prostitute in the third degree. It states that a person over 21 years of age is guilty if they patronize a prostitute who is less than 17 years old. This offense is classified as a class A misdemeanor.


document_description: This document outlines the definitions and provisions of the New York Sex Offender Registration Act, including definitions of 'sex offender', 'sex offense', 'sexually violent offense', and other related terms. It also discusses the legislative purpose, findings, and amendments to the act over the years.


document_description: A person is guilty of promoting prostitution in the first degree when he knowingly advances or profits from prostitution of a person less than eleven years old. It is classified as a class B felony.


document_description: This document provides the legal definition and implications of the offense of patronizing a prostitute in the fourth degree under New York law, classified as a class B misdemeanor. It includes historical context, research references, practice aids, annotations, and case notes discussing various legal interpretations and applications of the statute.


document_description: This document provides the legal definition and historical context of the offense of promoting prostitution in the fourth degree under New York law. It includes case notes, annotations, and references to related legal provisions and cases.


document_description: This document outlines the New York Penal Law § 230.30, which defines the offense of promoting prostitution in the second degree. It specifies that a person is guilty if they advance prostitution by force or intimidation or profit from the prostitution of a person under sixteen. The offense is classified as a class C felony. The document includes historical amendments, case notes, and references to related legal texts and cases.


document_description: This document outlines the legal statute for promoting prostitution in the third degree in New York, which is classified as a class D felony. It includes historical amendments, notes, references, and case notes related to the statute.


document_description: This document compares the actual financial performance of Spot On Networks, LLC against projected figures from 2005 to 2008. It includes data on equity, debt, actual and projected investments, and revenues. The document highlights that actual revenues as a percentage of actual investment exceeded projected revenues as a percentage of projected investment for all years. A note explains that the percentage of excess actual performance over projected performance increased from 2005 to 2007 but was temporarily affected in 2008 due to issues with a large developer.


document_description: A faxed letter from Sheryl E. Reich of the Law Offices of Gerald B. Lefcourt to Jacqueline Mari, Esq., informing her that they are not authorized to take further action on Mr. Epstein's behalf in the Cordero v. Epstein case. The letter provides contact information for Mr. Epstein's representative, Harry Beller.


document_description: A stipulation agreement extending the return date for Plaintiff-Appellant's Motion and the City of New York's Cross-Motion from September 14, 2009, to September 28, 2009. It also sets deadlines for oppositions and replies.


document_description: This document is an invoice from the law offices of Burman, Critton, Luttier & Coleman, LLP, addressed to Darren K. Indyke, Esq. It details professional services rendered and disbursements incurred for Jeffrey Epstein, with a total amount due of $153,195.64. The invoice includes a breakdown of hours worked by various individuals and associated costs, as well as disbursements for various dates in March 2009.


document_description: A notice of hearing for the case involving Jane Doe and Jeffrey Epstein, scheduled for April 20, 2009, at the Palm Beach County Courthouse. The hearing is for Defendant Jeffrey Epstein's Motion to Transfer Cases. Attempts to resolve the matter prior to the hearing were unsuccessful.


document_description: A letter from Robert D. Critton, Jr. to Brad Edwards, Esq. revising a previous letter dated April 7, 2009. The letter requests scheduling depositions for three individuals as witnesses in cases against Jeffrey Epstein. It mentions the agreement to depose each individual as a witness and as a plaintiff on separate occasions.


document_description: Notice of hearing for Plaintiff's case against Jeffrey Epstein regarding Defendant Epstein's objection to production from non-party, Yellow Cab. Scheduled for April 20, 2009, at Palm Beach Circuit Court.


document_description: A letter from Robert D. Critton, Jr. of Burman, Critton, Luttier & Coleman LLP to Richard H. Willits, Esq., regarding a form authorization for school records in the case G.M.A. v. Epstein, et al. The letter requests the client's signature for discovery purposes.


document_description: Attorney Bradley J. Edwards filed a notice of change of address and firm affiliation, continuing as counsel for Plaintiff Jane Doe in the case against Jeffrey Epstein. The notice requests updates to databases to reflect the new firm name and address, and directs all related correspondence to the new firm.


document_description: The document is a court order from the Fifteenth Judicial Circuit in Palm Beach County, Florida, regarding a motion to reassign and/or transfer a case involving Jeffrey Epstein. The order is signed by Circuit Judge David E. French on April 7, 2009. The decision on the motion is not specified in the document.


document_description: Stuart S. Mermelstein responds to Robert D. Critton, Jr.'s letter regarding non-party subpoenas on employers and medical records in the case of Jane Does 2-7 v. Jeffrey Epstein. Mermelstein argues against serving formal subpoenas to employers and emphasizes the need for a HIPAA compliant protective order for medical records. He also disagrees with the proposal to limit depositions and supports consolidation for discovery purposes.


document_description: The document is a notice of filing correction to a typographical error in the Plaintiff's Memorandum in response to Jeffrey Epstein's motion to dismiss. The error is in a quote from a legal case, which should read 'unambiguous' instead of 'ambiguous'.


document_description: A letter from Robert D. Critton, Jr. of Burman, Critton, Luttier & Coleman LLP to Brad Edwards, Esq. confirming a 20-day extension for Jeffrey Epstein to respond to discovery in two cases. The new due dates are May 15 and May 16, 2009. David Spicer will be substituting as counsel for Epstein.


document_description: This document is a legal response from Jeffrey Epstein's defense team to a motion filed by the plaintiff, Jane Doe No. 2, seeking a protective order and to quash a subpoena for the deposition of Jane Doe No. 3. The response argues against the motion, stating that the defendant is entitled to take depositions of the plaintiffs as both parties and witnesses. The document also discusses the impracticality of consolidating cases for discovery purposes due to the unique circumstances of each plaintiff's case.


document_description: The court orders Jeffrey Epstein to appear for a deposition within 30 days following the denial of his motion for a protective order.


document_description: This document is a legal complaint filed by Jane Doe 101 against Jeffrey Epstein, alleging multiple counts of sexual exploitation and abuse of minors. The complaint details Epstein's systematic pattern of sexually exploitative behavior, including coercion and enticement of minors, sex trafficking, and child pornography. The document outlines the psychological and physical damages suffered by the plaintiff and demands judgment for damages under 18 U.S.C. § 2255.


document_description: A letter from Spencer T. Kuvin to Robert Critton regarding the non-appearance of Critton's client at a deposition scheduled for April 23, 2009. Kuvin requests alternative dates for the deposition within the next 30 days and mentions the possibility of unilaterally scheduling it if no response is received by May 1, 2009.


document_description: David W. Spicer informs Robert Critton about a call from Bob Josefsberg regarding Jeffrey Epstein's cases. Spicer clarifies he is not involved in the cases and that Critton is handling everything. Josefsberg inquired about the lack of settlement offers and any change in strategy, to which Spicer responded he had no knowledge.


document_description: A letter to the Assistant U.S. Attorney regarding civil lawsuits filed against Jeffrey Epstein and the discovery process involved.


document_description: A letter from Spencer T. Kuvin to Robert Critton regarding the lawsuit B.B. v. Jeffrey Epstein. Kuvin asserts that his client, the plaintiff, is not obligated to comply with the demands made by Critton's client, Jeffrey Epstein, and suggests filing a motion with the court if there is disagreement.


document_description: Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 filed a motion for a No-Contact Order against Jeffrey Epstein, prohibiting him and his agents from contacting the plaintiffs directly or indirectly. The motion cites previous agreements and court orders prohibiting contact with victims, and highlights the potential harm and intimidation caused by any contact from Epstein. The motion seeks to ensure the protection and peace of mind for the plaintiffs.


document_description: The United States, represented by Assistant United States Attorney A. Marie Villafana, responds to the court's request for its position on Jeffrey Epstein's motion to stay civil proceedings. The U.S. argues that a stay is not necessary and was not part of the Non-Prosecution Agreement (NPA) with Epstein. The document discusses the standards for imposing a stay, the assertion of the Fifth Amendment, and the balancing of equities. It concludes that no 'special circumstances' warrant a stay of the civil cases pending the 'expiration' of the NPA.


document_description: Plaintiff E.W. files the original transcript of proceedings before Judge Donald W. Hafele dated May 22, 2009. Certificate of service included, listing attorneys served.


document_description: Two letters from Robert D. Critton, Jr. to Robert Josefsberg and Katherine W. Ezell regarding the Epstein Matter. The letters discuss the resolution of outstanding fee issues through a Special Master and the confidentiality of upcoming discussions.


document_description: This document includes a letter from Robert D. Critton, Jr., Esq. to Judge Donald Hafele regarding the scheduling of hearings for two cases against Jeffrey Epstein. The hearings are set for October 2, 2009, to address Epstein's Motion to Stay or Continue Action due to parallel civil and criminal proceedings. The document also contains the official court orders setting the hearing times for the cases.


document_description: This letter from Acting United States Attorney Jeffrey H. Sloman addresses Jay P. Lefkowitz's concerns regarding the Non-Prosecution Agreement (NPA) related to Jeffrey Epstein. Sloman clarifies that the Office did not agree to modifications of the NPA and rejects Lefkowitz's objections. The letter also mentions that the Office will not engage in further discussions about the NPA's scope and will continue to evaluate its position.


document_description: The document is a motion to dismiss filed by Jeffrey Epstein's attorneys, arguing that Counts I and III of Jane Doe No. 8's complaint are barred by the statute of limitations. Count I pertains to 'Sexual Assault and Battery' under Florida common law, and Count III pertains to 'Coercion and Enticement to Sexual Activity' under 18 U.S.C. §2255. The motion argues that the statute of limitations for these claims has expired, as the alleged incidents occurred in 2001, and the complaint was filed in 2009. The motion also references the non-prosecution agreement (NPA) and argues that it does not apply to Jane Doe No. 8's claims as she did not rely exclusively on 18 U.S.C. §2255.


document_description: Invoice for legal services rendered to Jeffrey Epstein by Reeder & Reeder for the period through July 10, 2009, totaling $30,365.00. The invoice includes detailed descriptions of legal activities, hours, and costs associated with various legal proceedings involving Jeffrey Epstein.


document_description: A letter from WGCompass Realty Management, LLC regarding a name change for One Clearlake Centre, LLC and instructions for updating insurance certificates and billing information.


document_description: Notice of hearing for Defendant's Motion for Protective Order regarding Jeffrey Epstein's deposition on July 30, 2009. Scheduled for August 12, 2009, at 8:45 AM before Judge Donald Hafele in Palm Beach Circuit Court.


document_description: This document is an agreement between Jeffrey Epstein and the law firm Podhurst Orseck, P.A., appointing Sidney A. Stubbs, Esq. as a Special Master to resolve disputes regarding attorneys' fees and costs related to the Non-Prosecution Agreement (NPA) between Epstein and the United States. The agreement outlines the responsibilities of the Special Master, the binding nature of his decisions, and the payment terms for his services.


document_description: The court addressed the Plaintiff's Motion for Leave to Add Count for Battery and Seek Punitive Damages. The motion was granted/denied for reasons stated on the record. The Plaintiff's Second Amended Complaint is deemed filed, and the Defendant has 20 days to respond.


document_description: Jeffrey Epstein responds to motions for appellate attorney's fees and costs filed by respondents E.W., B.B., and Palm Beach Newspapers. Epstein argues that the court should deny these motions as neither the 15th Judicial Circuit Administrative Order nor Florida Rule of Appellate Procedure 9.410 supports such an award. The response also discusses the confidentiality of the non-prosecution agreement under federal law.


document_description: The document includes a letter from Spencer T. Kuvin to Robert Critton regarding medical records in the case B.B. v. Jeffrey Epstein, and a legal motion to consolidate two proceedings involving Jeffrey Epstein. The motion is filed by L.M. to consolidate with E.W. v. Epstein due to similar discovery orders. The motion is unopposed by Robert Critton, attorney for the respondent.


document_description: This document is a cross-notice for the videotaped deposition of Leslie Wexner in the case involving multiple Jane Doe plaintiffs against Jeffrey Epstein. The deposition is scheduled for August 14, 2009, at McGinnis & Associates in Worthington, OH. The document includes a certificate of service and a service list of attorneys involved in related cases.


document_description: This document is a cross-notice for the videotaped deposition of Ghislaine Maxwell, scheduled for August 17, 2009, at Esquire Court Reporters, New York. It is part of multiple cases involving plaintiffs identified as Jane Doe against Jeffrey Epstein. The deposition is for discovery and trial purposes. The document includes a certificate of service and a service list of attorneys involved in related cases.


document_description: This document is a re-notice for the continuation of the videotaped deposition of Alfredo Rodriguez, related to multiple cases against Jeffrey Epstein. The deposition is scheduled for August 7, 2009, at Kress Court Reporting in North Miami, Florida. The document includes a certificate of service and a service list of attorneys involved in related cases.


document_description: Notice of deposition for Alfredo Rodriguez in the case against Jeffrey Epstein, scheduled for August 7, 2009, at Kress Court Reporting in North Miami, FL.


document_description: A letter from the U.S. Attorney's Office to Spencer T. Kuvin, Esq., regarding the disclosure of the Non-Prosecution Agreement signed by Jeffrey Epstein. The letter explains that the agreement contains a confidentiality provision and that a Protective Order by U.S. District Judge Kenneth Marra requires the U.S. Attorney's Office to provide copies of the agreement to certain individuals under specific circumstances. The letter also notes that the client, B.B., was not identified as a victim during the federal investigation and is not covered by the Court's Protective Order.


document_description: Respondent B.B. moves to supplement the record in Jeffrey Epstein's petition for writ of certiorari, arguing that B.B. cannot obtain the nonprosecution agreement from the U.S. Attorney's Office as she was not identified as a victim. The motion includes a letter from the U.S. Attorney's Office supporting this claim.


document_description: The document includes a Tolling Agreement related to Jeffrey Epstein, signed by Robert C. Josefsberg and Robert D. Critton, Jr., effective August 6, 2009. It outlines terms for tolling legal proceedings until October 15, 2009. Additionally, a court order from the District Court of Appeal of Florida consolidates case numbers 4D09-2409 and 4D09-3001.


document_description: This document is a notice for the videotaped deposition of various individuals related to the Jeffrey Epstein case, scheduled for different dates in August and September 2009. The depositions are for discovery and trial purposes.


document_description: This document is a transcript of court proceedings held on July 31, 2009, in the Circuit Court of the 15th Judicial Circuit in Palm Beach County, Florida, presided over by Judge Donald W. Hafele. The proceedings involve a motion by the plaintiff to add punitive damages against Jeffrey Epstein. The plaintiff's counsel, Brad Edwards, argues that Epstein engaged in intentional misconduct and gross negligence by sexually abusing minors. The defense, represented by Robert D. Critton Jr., argues against the sufficiency of the evidence for punitive damages. The court ultimately grants the motion to amend the complaint to include punitive damages.


document_description: The letter discusses upcoming meetings, motions for extension in Doe 101 and 102, and a trust check payment of $362,474.00 to bring billings current through March 25, 2009. It also mentions agreements regarding Sid Stubbs and the handling of disputes over prior bills.


document_description: Invoice for services rendered by Dr. Richard C. W. Hall, M.D., P.A. to Burman, Critton, Cuttier & Coleman LLP regarding the case Jane Does v. Epstein. The invoice details the hours worked and services provided for multiple Jane Does, including record reviews, consultations, and affidavit preparations. The total amount due is $16,145.72 after deducting retainers.


document_description: A letter from Podhurst Orseck law firm to Storage USA regarding the preservation of items in Jeffrey Epstein's storage units, in compliance with a court preservation order. The letter emphasizes the legal obligation to maintain the integrity of the stored items and warns against any destruction or alteration.


document_description: A Tolling Agreement executed between Robert D. Critton, Jr. for Jeffrey Epstein and Robert C. Josefsberg, Esq. The agreement tolls the time limits for commencing legal proceedings until October 15, 2009. It is confidential and may be extended by written agreement of all parties.


document_description: A letter from Robert D. Critton, Jr. to Spencer T. Kuvin, Esq. regarding the depositions of Donald Trump, Glenn Dubin, and Ghislaine Maxwell in the case B.B. v. Epstein. The letter objects to the participation in these depositions due to improper service of subpoenas.


document_description: A letter from Spencer T. Kuvin to Robert Critton discussing the necessity of subpoenas for witnesses appearing at depositions in the case B.B. v. Jeffrey Epstein. Kuvin argues that subpoenas are unnecessary as the witnesses will be present and suggests filing a motion if Critton insists on subpoenas.


document_description: The document is a legal notice of a hearing scheduled for August 20, 2009, regarding the Plaintiff's request to enter and inspect Jeffrey Epstein's property at 358 El Brillo Way, West Palm Beach, FL. The inspection is planned for August 28, 2009, and will include video and photographic documentation. The notice certifies that efforts have been made to resolve the issues prior to the hearing.


document_description: Declarations by Jane Doe No. 4 and her sister Y.B. regarding harassment by investigators allegedly sent by Jeffrey Epstein. Jane Doe No. 4 expresses concern about her ex-boyfriend being contacted by investigators, while Y.B. recounts an encounter with investigators at her residence.


document_description: This document is an agreement between Jeffrey Epstein and Robert C. Josefsberg, representing Podhurst Orseck, P.A., to appoint Sidney A. Stubbs, Esq. as Special Master to resolve disputes over attorneys' fees and costs related to the Non-Prosecution Agreement (NPA) with the USAO. The agreement outlines the responsibilities and procedures for the Special Master, including the binding nature of his decisions and the payment of his fees.


document_description: Jeffrey Epstein, through his attorneys, responds to the Plaintiff's Second Amended Complaint by asserting his Fifth Amendment privilege against self-incrimination for most allegations. The document includes multiple affirmative defenses, such as consent, statute of limitations, and lack of duty of care. Epstein's attorneys request the court to deny the relief sought by the Plaintiff.


document_description: The document notifies the court and all counsel of record about the change of address for the law offices of Burman, Critton, Luttier & Coleman, effective August 24, 2009. It includes a certificate of service indicating that copies were sent by fax and U.S. Mail to various attorneys involved in cases against Jeffrey Epstein.


document_description: Jeffrey Epstein's legal team filed a motion to strike declarations attached to the plaintiffs' reply in support of their motion for a protective order. The motion argues that the declarations were untimely and outside the scope of the initial motion and response. The motion requests the court to strike these declarations or allow the defendant time to respond.


document_description: This document contains multiple court orders related to cases against Jeffrey Epstein in the Fifteenth Judicial Circuit, Palm Beach County, Florida. The orders address motions for entry upon land, motions for stay, motions to compel compliance with court orders, and motions for special set hearings. The outcomes of these motions vary, with some being granted and others denied.


document_description: Letters from Robert D. Critton, Jr. to various attorneys informing them of Jeffrey Epstein's intention to attend depositions related to lawsuits against him. Epstein plans to be present but not engage in conversation, as is his right as a party-defendant.


document_description: Jeffrey Epstein, through his counsel, objects to subpoenas directed to Greens Pharmacy and Lewis Pharmacy for prescription records, citing privacy concerns, irrelevance, and lack of time specificity. Epstein argues that his health is not at issue in the case and that the subpoenas are overly broad and harassing.


document_description: Notice of hearing for Defendant's objections to notices of production from non-party directed to Greens Pharmacy and Lewis Pharmacy. Scheduled for September 15, 2009, at Palm Beach Circuit Court.


document_description: The document includes a re-notice of hearing for a case involving Jeffrey Epstein, scheduled for September 15, 2009, at the Palm Beach Circuit Court. It also includes a request for copies of records related to a subpoena for medical records of Jeffrey Epstein, with a deposition scheduled for September 22, 2009.


document_description: Invoice 1247 for legal services rendered and costs incurred on behalf of Jeffrey Epstein for the period through September 11, 2009. Total amount: $5,024.50.


document_description: A letter from Robert D. Critton, Jr. to Brad Edwards and William Berger regarding the deposition of three clients in the Epstein case. The letter states that the depositions will be taken simultaneously as witnesses and plaintiffs.


document_description: This document is an excerpt from court proceedings in the case of [Redacted] v. Jeffrey Epstein, held on September 23, 2009, in the Circuit Court of the Fifteenth Judicial Circuit in Palm Beach County, Florida. The proceedings involve discussions about a nonprosecution agreement and orders by Judges Pucillo and Marra regarding victim designation and contact restrictions.


document_description: The document is a legal notice and subpoena for the deposition of William "Bill" Riley in the case against Jeffrey Epstein. The deposition is scheduled for October 20, 2009, at Esquire Court Reporters in Fort Lauderdale, Florida. The subpoena commands Riley to bring various items related to Epstein, including computers, photographs, and documents from Epstein's residence.


document_description: Adam D. Horowitz, attorney for one of Jeffrey Epstein's alleged victims, reports a probation violation incident to Judge Jeffrey Colbath. The incident involved Epstein intimidating the victim on September 16, 2009, violating a No-Contact Order. An affidavit is attached, and the victim is willing to testify.


document_description: This document is an agreement between Jeffrey Epstein and Robert C. Josefsberg, representing Podhurst Orseck, P.A., to appoint Sidney A. Stubbs, Esq. as a Special Master to resolve disputes over attorneys' fees and costs related to the Non-Prosecution Agreement (NPA) with the USAO. The agreement outlines the responsibilities and procedures for the Special Master, including the binding nature of his decisions and the payment of his fees.


document_description: A hearing is scheduled for Defendant Epstein's Motion For Sanctions Against Spencer Kuvin, Esq. and Alternative Motion to Identify on January 26, 2010, at the Palm Beach County Courthouse. The hearing is set for 30 minutes before Judge Donald Hafele.


document_description: This document is an agreement between Jeffrey Epstein and Robert C. Josefsberg, representing Podhurst Orseck, P.A., to appoint Sidney A. Stubbs, Esq. as Special Master to determine the amount of attorneys' fees and costs owed by Epstein under the Non-Prosecution Agreement (NPA). The agreement outlines the responsibilities of the Special Master, the confidentiality of proceedings, and the binding nature of the Special Master's decisions.


document_description: This document is a deposition of Jane Doe in the case against Jeffrey Epstein, conducted on September 30, 2009. The deposition covers Jane Doe's experiences and interactions with Epstein, including her first visit to his house, the circumstances leading to her involvement, and the events that transpired during her visits. Jane Doe describes being introduced to Epstein by a friend, being paid for her visits, and the nature of her interactions with Epstein. The deposition also touches on Jane Doe's personal background, including her family situation and past experiences.


document_description: The document contains notices and subpoenas for videotaped depositions of various individuals related to the Jeffrey Epstein case. The depositions are scheduled for December 2009 at Prose Court Reporting in West Palm Beach, FL. The individuals subpoenaed include Detective Joseph Recary, Detective Michael Dawson, Detective Michelle Pagan, Robert Meister, Todd Meister, and the Records Custodian of the Palm Beach County Police Department. The subpoenas request all records related to the Jeffrey Epstein investigation.


document_description: A letter from Katherine W. Ezell of Podhurst Orseck to Robert Critton discussing available dates for a meeting with Sid Stubbs and the status of the Special Master Agreement related to Jeffrey Epstein.


document_description: Jeffrey H. Epstein re-affirms the Non-Prosecution Agreement and Addendum signed on October 30, 2007.


document_description: A letter from Katherine W. Ezell of Podhurst Orseck to Robert Critton and Sidney A. Stubbs, Jr. discussing the scheduling of a meeting to resolve a fee situation related to Jeffrey Epstein. The letter mentions the tentative date of December 16 for the meeting and the process of sending redacted invoices.


document_description: Jeffrey Epstein's legal team filed a motion to clarify the record regarding representations made by Plaintiff's counsel at a hearing on September 23, 2009. The motion addresses inaccuracies related to a 'no contact' order and a list of victims associated with a Non-Prosecution Agreement. The motion includes affidavits and references to previous court proceedings.


document_description: A letter from Robert D. Critton, Jr. to Brad Edwards regarding a court motion to compel the production of a book related to a deposition in the case against Epstein. The letter accuses the client of providing false testimony about the existence of the book and threatens a second motion for sanctions if the book is not produced within a week.


document_description: The document includes a letter from Spencer T. Kuvin to Robert Critton and Michael Pike regarding the deposition of Mr. Story in the case B.B. v. Jeffrey Epstein. It also contains a court order from the 15th Judicial Circuit in Palm Beach County, Florida, addressing Defendant's objections to notice production non-party, specifically related to subpoenas for AT&T, Verizon, and Dollar, with a time limitation from May 2003 to February 2006.


document_description: The court orders Plaintiff Jane Doe (08-80893) to respond to Defendant Jeffrey Epstein's motion for an extension of time to complete trial deadlines by November 23, 2009.


document_description: Two letters from Robert D. Critton, Jr. to Robert Josefsberg and Sidney Stubbs requesting confirmation that neither they nor their firms represent any lawyers from Rothstein Rosenfeldt Adler, P.A. due to significant issues related to the sale of Epstein assets.


document_description: A letter from Robert D. Critton, Jr. to Bradley J. Edwards, Esq. regarding a court order granting a motion to compel. The letter requests the immediate provision of documents evidencing income, including 'Psalm' books referenced in a deposition.


document_description: Notice of hearing for pending motions to intervene before Judge Jeffrey Streitfeld in Broward County Courthouse on November 23, 2009.


document_description: A letter from John C. Randolph of Jones Foster Johnston & Stubbs, P.A. to various attorneys regarding depositions scheduled in the Jeffrey Epstein case. The letter outlines the schedule for depositions of former and present officers of the Town of Palm Beach Police Department and mentions the consolidation of related federal court cases by Judge Kenneth Marra.


document_description: A letter from Robert D. Critton, Jr. to William Riley confirming a conversation about the transfer of direction and supervision under the Non-Prosecution Agreement related to Jeffrey Epstein. The letter discusses the inventory and preservation of materials taken from Epstein's house in Palm Beach.


document_description: The document is a legal response from the plaintiff's counsel opposing Jeffrey Epstein's motion to delay the trial. The plaintiff argues that Epstein's reasons for the continuance are unfounded, citing health issues as the reason for previous deposition delays. The response details the history of deposition scheduling and disputes Epstein's claims of being unable to proceed with discovery.


document_description: The court allows Defendant Jeffrey Epstein to attend Plaintiff's deposition, mediation, or trial despite a no contact order. The order is agreed upon by Plaintiff's counsel.


document_description: This document is a transcript of a court hearing in the case of Jeffrey Epstein, held on November 19, 2009, at the Palm Beach County Courthouse. The hearing involved discussions on Epstein's motion for a protective order to prohibit inappropriate deposition questions, and other motions related to the preservation of evidence and a stay in the case. The hearing also touched upon the implosion of the Rothstein, Rosenfeldt and Adler law firm and its implications on the Epstein cases. The court considered the preservation of evidence and the scheduling of future proceedings.


document_description: The court vacated its previous Omnibus Order from November 17, 2009, due to ruling on motions without waiting for Plaintiffs' reply memorandums. A new ruling on the motions will be issued separately.


document_description: The document is a transcript of a court hearing presided over by Judge Jeffrey Streitfeld. The hearing involves a case where Stuart A. Rosenfeldt and Rothstein Rosenfeldt Adler, P.A. are plaintiffs against Scott W. Rothstein. The hearing discusses the appointment of Herbert Stettin as the Chapter Eleven Trustee, the jurisdiction of the bankruptcy court, and the handling of funds related to the case. Various attorneys and parties are present, including discussions about interpleader actions and the preservation of evidence.


document_description: The court denied Jeffrey Epstein's motion for a continuance of the trial, which was set for February 22, 2010. The court found the motion premature as discovery was still open until December 30, 2009, and there was sufficient time before the trial date.


document_description: Notice of cancellation for depositions of Detectives Michael Dawson and Michelle Pagan scheduled for December 8, 2009, and Todd and Robert Meister scheduled for December 14, 2009.


document_description: This document is a legal filing by Jeffrey Epstein's attorneys in response to a motion for inspection and to compel discovery, specifically regarding the photographing of Epstein's genitalia. The response argues against the motion on the grounds of Fifth Amendment rights against self-incrimination, irrelevance, harassment, and violation of privacy. The document also discusses the potential for media exploitation and the lack of material fact that would be proven by the requested inspection. The response includes references to previous court rulings and legal standards regarding the Fifth Amendment and discovery processes.


document_description: A letter from Robert D. Critton, Jr. confirming the cancellation of a mediation scheduled for January 6, 2010, in the case of Jane Doe 101 v. Epstein, due to settlement.


document_description: A letter from Robert D. Critton, Jr. to Spencer T. Kuvin regarding the cancellation of depositions for Robert Meister and Todd Meister in the case of B.B. v. Epstein. The letter argues that the depositions are unnecessary and serve only to harass and increase litigation costs. It also mentions previous depositions and the intention to defend against abusive litigation.


document_description: Correspondence from Spencer T. Kuvin to Robert Critton regarding scheduling videotaping of Jeffrey Epstein's home and a new date for deposing Epstein.


document_description: Two letters from Robert D. Critton, Jr. to Jeffrey Epstein and John G. White, III, Esq. The first letter discusses a motion for sanctions related to a case involving Epstein and Mr. Kuvin, and the potential withdrawal of the motion. The second letter addresses a fee dispute hearing between Epstein and the Podhurst Orseck Firm, mentioning a spreadsheet being prepared for $2 million in fees.


document_description: A letter from Robert D. Critton, Jr. to Robert Josefsberg regarding billing statements and the need for detailed information on costs and qualifications of those who worked on the file related to Jane Doe cases.


document_description: Notice of cancellation for video depositions of Jeffrey Epstein and Igor Zinoview scheduled for December 16-18, 2009.


document_description: This document is an agreement between Jeffrey Epstein and Robert C. Josefsberg, representing Podhurst Orseck, P.A., to appoint a Special Master to resolve disputes regarding attorneys' fees and costs related to the Non-Prosecution Agreement (NPA) with the USAO. The Special Master will make binding decisions on the amount of fees and costs due to Podhurst Orseck by Epstein.


document_description: The court denied the Plaintiff's Motion for Inspection and to Compel Discovery (Photographs).


document_description: A letter from Robert D. Critton, Jr. to Robert Josefsberg regarding the Epstein Matter and a fee issue. The letter mentions the intention to finalize the Special Master Agreement after the new year and discusses proposed names for a special master.


document_description: This document is a transcript of a compulsory medical evaluation of Jane Doe No. 5, conducted as part of a legal case against Jeffrey Epstein. The evaluation was conducted by Dr. Ryan Hall and involved a detailed interview with Jane Doe No. 5 about her personal history, family background, and experiences with Jeffrey Epstein. The document includes discussions about her childhood, family dynamics, educational history, relationships, and the traumatic experience with Epstein. Jane Doe No. 5 describes being taken to Epstein's house under the pretense of giving a massage for money, where she was subjected to inappropriate and non-consensual sexual advances by Epstein. The document also covers her feelings of shame and fear about the incident, her reluctance to report it, and the impact it has had on her life.


document_description: This document is a motion filed by Jeffrey Epstein's attorneys for the entry of a default by the Clerk against Scott Rothstein for failing to serve or file any required papers in response to a complaint. The motion includes details of the service of the complaint and the lack of response from the defendant. It also includes a verified return of service and an amended summons.


document_description: A letter from John K. Dema to Darren K. Indyke regarding the conditional transfer of the case Financial Trust Company, Inc. v. The Bear Stearns Companies Inc. to the MDL in the Southern District of New York. The letter advises FTC to retain stateside counsel and outlines the necessary actions and deadlines.


document_description: An architectural floor plan sketch depicting multiple interconnected building sections with dimensions, labeled areas, staircases, courtyards, and landscape elements. The plan includes sections labeled '30 x 50' and '20 x 70', areas marked with numbers (56, 56., 561, 59, 46, 44), and wavy lines suggesting proximity to water or uneven terrain. A large letter 'B' is drawn below the main structure.


document_description: An architectural sketch of a multi-level property featuring a main house, two gazebos, terracing, and landscaping. The sketch includes elevation markers indicating height measurements.


document_description: A transmittal document from Jorge Porta to Doug Schoettle regarding LSJ-Kitchen millwork shop drawings. The document includes a cover page and 9 pages of red-lined shop drawings from Tom Hoch. The drawings are marked 'APPROVED AS NOTED' with minor comments. The document also includes detailed architectural and cabinetry plans for a kitchen, specifying materials, finishes, and dimensions.


document_description: This document contains detailed architectural drawings and specifications for kitchen and island sections for the Little St. James project. It includes information on cabinetry, finishes, and dimensions, with instructions for designer and owner approvals.


document_description: Jay P. Lefkowitz addresses Robert C. Josefsberg regarding the payment of legal fees by Jeffrey Epstein. Lefkowitz clarifies that Epstein's obligation to pay is limited to the terms of the Non-Prosecution Agreement (NPA) and disputes any authorization for additional expenses incurred by Josefsberg. The letter emphasizes that Epstein is not responsible for fees related to adversarial litigation or hiring outside counsel.


document_description: The document contains the Directors' Report and Financial Statements for Dukes Hotel Limited for the year ended 31 March 2010. It includes details on the company's principal activities, business review, financial results, directors, auditors, and financial risk management. The company reported a profit of £893,668 for the year and declared a dividend of £750,000. The report also covers the responsibilities of directors, auditors' report, profit and loss account, balance sheet, cash flow statement, and notes to the financial statements.


document_description: The 2010 World Science Festival will take place in New York City from June 2-6, featuring 40 unique programs in various scientific disciplines. Highlights include honoring Stephen Hawking, the world premiere of Philip Glass's 'Icarus at the Edge of Time,' and the introduction of NASA's James Webb Space Telescope. The festival aims to bring science to the general public through interactive exhibits and performances.


document_description: Harry P. Susman writes to Virginia S. Cruger to inform her of an agreed extension for submitting strikes and rankings for arbitrators in the case between FORTRESS VERF I LLC and FORTRESS VALUE RECOVERY vs. JEEPERS, INC. The new deadline is May 28, 2010.


document_description: Daily News, L.P. and George Rush appeal to the United States Court of Appeals for the Second Circuit from the Order dated June 23, 2010, adjudging them in civil contempt for refusing to consent to the production of certain newsgathering material.


document_description: A memorandum from Kirkland & Ellis LLP to the Sex Crimes Unit of the New York District Attorney's Office regarding the SORA (Sex Offender Registration Act) determination for Jeffrey Epstein. The memo argues that Epstein should be classified as a Level 1 offender under SORA, indicating a low risk of reoffense. It discusses Epstein's conviction in Florida for a prostitution-related offense, his compliance with legal requirements, and the assessments of various jurisdictions and a psychologist that suggest a low risk of reoffense. The memo criticizes a Level 3 recommendation by the Board of Examiners of Sex Offenders, arguing it is based on unreliable evidence.


document_description: A letter from Kirkland & Ellis LLP to the New York District Attorney's Office regarding the SORA determination for Jeffrey Epstein. The letter argues against the Board of Examiners' recommendation to classify Epstein as a Level 3 offender, presenting evidence and arguments to support a Level 1 designation. It highlights discrepancies in police reports and the lack of credible evidence for certain allegations, suggesting that Epstein's conduct would not be a registerable offense under New York law.


document_description: A letter from Kirkland & Ellis LLP to the New York District Attorney's Office regarding the SORA determination for Jeffrey Epstein. The letter argues against the Board of Examiners' recommendation to classify Epstein as a Level 3 offender, presenting evidence and testimonies to support a Level 1 designation. It highlights discrepancies in police reports and argues that Epstein's conduct does not meet the criteria for registration under New York law. The letter also questions the necessity of Epstein's registration in New York, given his primary residence in the U.S. Virgin Islands.


document_description: This document is an Agreed Order on Preservation of Evidence related to the case against Jeffrey Epstein. It includes a subpoena duces tecum for deposition directed to Herbert Stettin, who was appointed as a receiver and trustee in bankruptcy for Rothstein, Rosenfeldt & Adler, P.A. The order outlines the preservation of evidence obligations and requests access to information without needing Stettin's deposition.


document_description: A letter discussing alleged false postings on Google about Jean Luc Brunel and potential legal actions to address them.


document_description: Jeffrey Epstein responds to a letter from Kenneth H. Byrk of The Florida Bar regarding complaints against attorneys William Joseph Berger and Bradley James Edwards. Epstein discusses the involvement of these attorneys in the Scott Rothstein/Rothstein, Rosenfeldt & Adler matter, suggesting they knew or should have known about the sale of tort cases against him. The letter mentions lawsuits, bankruptcy proceedings, and stays that have prevented further information gathering.


document_description: Notice of deposition for Jeffrey Epstein scheduled for January 27, 2010, at Prose Court Reporting, New York. The deposition is for discovery and trial purposes.


document_description: A letter from Robert C. Josefsberg of Podhurst Orseck to Robert D. Critton, Jr. Esq. regarding the Epstein Matter. The letter addresses previous correspondences, discusses billing and expenses related to the Epstein case, and mentions issues with the Special Master Agreement and the selection of Special Masters. It also expresses frustration over delays in finalizing agreements and scheduling hearings.


document_description: A letter from Robert D. Critton, Jr. to Joanne O'Connor regarding the Non-Party Town of Palm Beach Police Officers' Motion to Quash Subpoena and/or Motion for Protective Order related to the Epstein matter. The letter discusses the need for a response to subpoenas and the identification of privileged documents.


document_description: Notice of Hearing for Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions scheduled for January 14, 2009, at 8:45 a.m. before Judge Donald Hafele at Palm Beach County Courthouse, Room 11B.


document_description: The document is a legal response from the plaintiff in a case against Jeffrey Epstein, addressing Epstein's motion for sanctions and to identify. The response argues against the motion by highlighting the defense's use of media to influence public opinion and the ethical concerns surrounding Epstein's legal team's actions. It also discusses the non-prosecution agreement and the release of deposition details, emphasizing the public interest and legal precedents supporting the plaintiff's actions.


document_description: A letter from Michael J. Pike of Burman, Critton, Luttier & Coleman, LLP to Judge Donald Hafele regarding a 30-minute special set hearing on January 26, 2010. The letter encloses Defendant Epstein's Supplement to His Motion for Sanctions Against Spencer Kuvin, Esq. and Alternative Motion to Identify. The correspondence discusses statements made by Spencer Kuvin to the media and the identification of a plaintiff by her full legal name in a public document.


document_description: The document includes a Notice of Hearing for a case involving Jeffrey Epstein, scheduled for January 20, 2009, and a Motion for Protective Order regarding Epstein's deposition set for January 29, 2010. The motion argues against a third deposition of Epstein, citing harassment and previous completion of deposition. The document also includes orders from the United States District Court for the Southern District of Florida consolidating multiple cases for discovery purposes.


document_description: The document includes a notice of hearing for a motion to amend the complaint to add a RICO count, a notice of taking deposition of Charles Gerald Goldsmith, and a subpoena for his deposition. The hearing is scheduled for January 20, 2010, and the deposition for February 8, 2010. The document is related to the case of B.B vs. Jeffrey Epstein in the Circuit Court of the 15th Judicial Circuit in Palm Beach County, Florida.


document_description: This document is a transcript of a court hearing held on December 14, 2009, in the Circuit Court of the 15th Judicial Circuit, Palm Beach County, Florida. The hearing was presided over by Judge Donald Hafele. The plaintiff, represented by Spencer T. Kuvin, filed a motion to compel discovery of photographs related to the case against Jeffrey Epstein. The discussion centered around the relevance and admissibility of evidence regarding Epstein's private parts, with arguments about whether such evidence was necessary for the case. The motion was ultimately denied without prejudice, allowing for the possibility of revisiting the issue if it becomes relevant in the future.


document_description: This document is a transcript of a videotaped compulsory medical evaluation of an individual referred to as E.W. conducted on November 11, 2009, in West Palm Beach, Florida. The evaluation was part of a legal proceeding involving Jeffrey Epstein. The transcript includes discussions about the individual's personal history, relationships, substance use, and medical history. Key figures mentioned include Jeffrey Epstein and various individuals from the interviewee's personal life. The document also touches on the interviewee's aspirations and current living situation.


document_description: Confidential settlement discussion letter from Spencer T. Kuvin to Robert Critton regarding a case against Epstein, seeking to resolve the matter amicably before filing a lawsuit.


document_description: Jeffrey Epstein, through his attorneys, responds to the affirmative defenses of Defendant L.M., denying all allegations and demanding proof. Epstein argues that L.M. has not provided facts to support estoppel or waiver defenses, and requests these defenses be stricken.


document_description: Jeffrey Epstein, as Counter-Defendant, files a motion for a more definite statement or to dismiss the Counterclaim filed by Bradley J. Edwards. Epstein argues that the Counterclaim lacks a clear cause of action and is based on vague allegations related to a racketeering conspiracy involving Scott Rothstein's law firm.


document_description: Jeffrey Epstein, through his attorneys, filed a motion to compel the plaintiff, L.M., to respond to a second request for production of documents. The request was initially served on October 21, 2009, and was due by November 20, 2009. However, a court stay delayed the response deadline. The motion also seeks attorney fees for the necessity of filing the motion. The document includes a certificate of service to various attorneys involved in the case.


document_description: Notice of Hearing for Jeffrey Epstein's motion for a more definite statement and motion to dismiss, scheduled for February 9, 2010, at the Palm Beach County Courthouse.


document_description: This document is a transcript of a videotaped compulsory medical evaluation of Jane Doe No. 6, conducted as part of a legal proceeding related to the Jeffrey Epstein case. The evaluation took place on November 23, 2009, in West Palm Beach, Florida. Dr. Ryan Hall conducted the evaluation, which included a series of psychological tests and a detailed interview covering Jane Doe No. 6's personal history, medical history, and her experience with Jeffrey Epstein. The document also includes discussions about her family, relationships, substance use, and mental health. Jane Doe No. 6 describes an incident involving Epstein when she was 13 years old, where she was taken to his house under the pretense of giving a massage and was subsequently sexually abused. The document captures her emotional state, her reluctance to discuss the incident, and her reasons for joining the lawsuit against Epstein.


document_description: The document includes a notice of inspection and video of Jeffrey Epstein's property at 350 El Brillo Way, Palm Beach, Florida, scheduled for January 18, 2010. It also contains a court order granting a limited video inspection of Epstein's property, focusing on entryways and pathways allegedly used by plaintiffs. The video is restricted in scope and distribution. The document also includes correspondence regarding the scheduling of a deposition.


document_description: Re-notice of hearing for Jeffrey Epstein's motion for a more definite statement and motion to dismiss, scheduled for January 26, 2009, before Judge David F. Crow. This cancels the February 9, 2010 UMC hearing.


document_description: A letter from Robert D. Critton, Jr. of Burman, Critton, Luttier & Coleman, LLP to Richard H. Willits, Esq. regarding a settlement payment of $145,000 related to the case C.M.A. v. Epstein, et al. The letter includes a check for the settlement amount as per the Settlement Agreement directed by Jack Hill.


document_description: The document includes a court order regarding Jeffrey Epstein's motion for a protective order to prohibit inappropriate deposition questions. The order was issued by Circuit Court Judge Donald Hafele on January 14, 2010. Additionally, there is correspondence from Joanne M. O'Connor of Jones, Foster, Johnston & Stubbs, P.A., addressing responses and objections to subpoenas served on the Town of Palm Beach Police Department and certain officers.


document_description: This document is an agreement between Jeffrey Epstein and Robert C. Josefsberg regarding the appointment of a Special Master to determine the amount of attorneys' fees and costs owed by Epstein to Podhurst Orseck, P.A. under the Non-Prosecution Agreement (NPA) with the USAO. The agreement outlines the selection and responsibilities of the Special Master, the process for determining fees, and the binding nature of the Special Master's decision.


document_description: A letter discussing settlement negotiations related to Jane Doe cases involving Jeffrey Epstein. The letter outlines agreed terms, including jurisdictional agreements and conditions on representation. It also mentions the Non-Prosecution Agreement and expectations regarding client solicitation and confidentiality.


document_description: The court grants the plaintiff's amended motion to compel and for sanctions, allowing the deposition of the defendant to continue as per court instructions.


document_description: A default is entered against Scott Rothstein for failing to serve a pleading in the case filed by Jeffrey Epstein. The motion for entry of default was filed by Epstein's attorneys due to Rothstein's failure to respond to the complaint.


document_description: A hearing is scheduled for Jeffrey Epstein's Motion for Partial Summary Judgment on Count I of Plaintiff's Second Amended Complaint. The hearing is set for April 9, 2009, at 11:00 a.m. at Palm Beach County Courthouse, with Judge Donald Hafele presiding. The hearing is part of two back-to-back cases involving the same defendant.


document_description: The court granted the Plaintiff's motion for a protective order regarding the Defendant's request for a medical examination. The court ruled that the doctor could observe the Plaintiff during a six-hour examination but denied the request for a video feed to another room. The court referenced previous cases, Maguire and McGarrah, in its decision.


document_description: The document includes a notice of production from a non-party and a subpoena duces tecum without deposition related to the case of B.B vs. Jeffrey Epstein. It commands Worth Builders, Inc. to produce documents related to work performed at 358 El Brillo Way, Palm Beach, Florida.


document_description: This document includes a Notice of Production from Non-Party and a Plaintiff's Subpoena for Deposition Duces Tecum in the case of B.B vs. Jeffrey Epstein. The notice informs that a subpoena will be issued to Wackenhut Corporation for documents related to work performed for Jeffrey E. Epstein at his Palm Beach address. The subpoena commands Wackenhut Corporation to produce documents including correspondence, emails, service logs, reports, and other related documents. The subpoena specifies that no testimony will be taken and outlines the consequences of non-compliance.


document_description: This document contains the Plaintiff's first set of interrogatories and requests for admissions directed to the Defendant, Jeffrey Epstein, in a legal case filed in the Circuit Court of the 15th Judicial Circuit in Palm Beach County, Florida. The Plaintiff, B.B., requests detailed responses to several admissions related to emotional trauma and other effects allegedly caused by Epstein.


document_description: This document is a transcript of a court proceeding in the Circuit Court of the Fifteenth Judicial Circuit in Palm Beach County, Florida, regarding a motion for sanctions against Spencer Kuvin, Esquire, by the defendants in a case involving Jeffrey Epstein. The hearing was presided over by Judge Donald Hafele. The motion was related to the dissemination of a video deposition of Jeffrey Epstein to the media, which the defendants argued was done in bad faith to create a media frenzy. The court denied the motion for sanctions and the request to identify the plaintiff, B.B., emphasizing the importance of respect for the judicial process and the right to a fair trial.


document_description: The document is a legal notice regarding the psychological examination of a plaintiff in a case against Jeffrey Epstein. It includes details about the examination process, objections to the presence of third parties during the examination, and the qualifications of the examining psychologist, Dr. Richard Hall. The document also contains an affidavit from Dr. Ryan C.W. Hall, outlining the importance of conducting the examination without third-party interference to maintain its integrity.


document_description: A letter from Joanne M. O'Connor of Jones Foster Johnston & Stubbs, P.A. to Spencer T. Kuvin and Robert Critton regarding the case B.B. v. Jeffrey Epstein. The letter references photographs taken by Detective Recarey of Mr. Epstein in 2009, enclosed with the letter.


document_description: This document is a legal notice for the deposition of Detective Joseph Recary, scheduled for February 25, 2010, at Prose Court Reporting. It is part of the case B.B. vs. Jeffrey Epstein in the Circuit Court of the 15th Judicial Circuit in Palm Beach County, Florida. The notice is issued by Spencer T. Kuvin, Esq. of Leopold~Kuvin, P.A.


document_description: This document is a transcript of a court hearing in the case of L.M. vs. Jeffrey Epstein, held on February 4, 2010, at the Palm Beach County Courthouse. The hearing involved discussions on motions to compel documents, issues of Fifth Amendment rights, and the relevance of certain evidence related to the plaintiff's claims of emotional and psychological trauma. The plaintiff's attorney, Bradley J. Edwards, and the defendant's attorney, Robert D. Critton, Jr., presented arguments regarding the production of diaries, journals, and videos, as well as the plaintiff's alleged earnings as a prostitute. The court addressed issues of relevance, privacy, and the plaintiff's medication history.


document_description: Notice of deposition for Charles Gerald Goldsmith scheduled for April 19, 2010, at ProseCourt Reporting, West Palm Beach, FL. The deposition is for discovery and trial purposes.


document_description: A schedule of depositions related to the Epstein case, listing plaintiffs, deponents, dates, times, locations, and who noticed the deposition.


document_description: A letter discussing the settlement and fee issues related to the Epstein matter, including the role of a Special Master to resolve fee disputes. The letter outlines the amounts billed and unbilled, the involvement of outside contractors, and the proposal to resolve all fee and cost issues. It also mentions the settlement of claims and the involvement of various individuals in the legal process.


document_description: This document is an agreement between Jeffrey Epstein and Robert C. Josefsberg, representing Podhurst Orseck, P.A., to appoint a Special Master to determine the amount of attorneys' fees and costs Epstein owes under a Non-Prosecution Agreement (NPA) with the USAO. The Special Master will resolve disputes regarding fees and costs, and their decision will be final and binding. Epstein has already paid $526,466.15, but disagreements remain about the total amount due.


document_description: The document is a legal notice for the video deposition of Jeffrey Epstein, scheduled for February 17, 2010, at 11:00 a.m. The deposition is for discovery purposes and will be conducted by US Legal Support Reporting Agency. The notice is issued by Bradley J. Edwards from the law firm Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. A certificate of service is included, indicating the notice was sent via U.S. Mail and email on February 10, 2010.


document_description: Notice of hearing for Defendant's objections to notices of production from non-parties dated January 29, 2010. Scheduled for March 4, 2010, at 8:45 AM before Judge Donald Hafele in Palm Beach Circuit Court.


document_description: This document is a cross notice of deposition for Detective Joseph Recary in multiple cases involving Jeffrey Epstein. The depositions are scheduled for February 25, 2010, at Prose Court Reporting in West Palm Beach, FL. The document includes certification of service to various attorneys involved in the cases.


document_description: This document is a notice for the videotaped deposition of a deponent related to the case Jane Doe No. 2 vs. Jeffrey Epstein. The deposition is scheduled for February 22, 2010, at 1:00 p.m. at Prose Court Reporting. The notice is signed by attorneys Robert D. Critton, Jr. and Michael J. Pike, representing Jeffrey Epstein.


document_description: This document is a legal request for production of documents from Defendant Jeffrey Epstein by Plaintiffs Jane Doe Nos. 2-8. It outlines definitions and instructions for the production of documents, including those related to the plaintiffs and any documents Epstein may use for impeachment purposes. It also includes a request for documents related to expert witnesses retained by the defendant.


document_description: Notice of deposition for Detective Joseph Recary in the case of Jane Doe II vs. Jeffrey Epstein and another defendant. The deposition is scheduled for February 25, 2010, at Prose Court Reporting.


document_description: Notice of deposition for a case involving Jeffrey Epstein, scheduled for March 24, 2010, at Prose Court Reporting in New York. The deposition is for discovery and trial purposes.


document_description: This document is a floor plan for a building complex on Little St. James, detailing existing and proposed spaces. It includes an indoor pool, covered terrace, and screening room, with support spaces below the courtyard.


document_description: The Town of Palm Beach Police Officers filed a motion to quash subpoenas or for a protective order against discovery requests by Jeffrey Epstein in a civil case. The motion argues that the subpoenas seek private and confidential information not subject to public records law, are overly broad, and constitute a fishing expedition. The motion also highlights the protection of crime victims' identities and personal information of law enforcement officers under Florida law.


document_description: This document is a legal notice regarding the videotaped deposition of witnesses in the case of Jane Doe v. Jeffrey Epstein, scheduled for March 5, 2010. It includes details about the deposition's purpose, location, and the attorneys involved.


document_description: This document includes a notice of hearing for Defendant Scott Rothstein's motion to set aside a default judgment in a case involving Jeffrey Epstein as the plaintiff. The hearing is scheduled for March 9, 2010, before Judge David F. Crow. The motion argues that Rothstein was not properly served with the lawsuit and requests the court to set aside the default due to excusable neglect.


document_description: A letter from The Florida Bar to Spencer Todd Kuvin regarding the handling of a matter by the Ft. Lauderdale Branch Office. It mentions that Bar Counsel will be in contact soon.


document_description: Notice of deposition for Jane Doe No. 103 against Jeffrey Epstein, scheduled for March 1 and March 24, 2010, at a location in Florida. The depositions are to be taken by Prose Court Reporting and are part of the discovery process for the case.


document_description: A letter discussing the interpretation and implications of the Non-Prosecution Agreement (NPA) related to Jeffrey Epstein's civil cases. The letter highlights disagreements between Epstein's attorneys and those representing alleged victims regarding the NPA's civil aspects. It mentions resolved cases, ongoing fee disputes, and new legal challenges faced by Epstein.


document_description: This document is a deposition of Jane Doe No. 4 in the case of Jane Doe No. 2 vs. Jeffrey Epstein. The deposition covers various topics including Jane Doe No. 4's interactions with Epstein, her emotional and psychological state, and her personal relationships. It also touches on her religious beliefs and her reflections on past events. The deposition was taken on February 12, 2010, and reported by Cynthia Hopkins.


document_description: This document is a deposition taken on February 12, 2010, in the case of Jane Doe No. 2 vs. Jeffrey Epstein. The deposition involves discussions about the relationship between the deponent and Jane Doe No. 4, including their personal issues, counseling sessions, and Jane Doe No. 4's past involvement with Jeffrey Epstein. The deponent discusses Jane Doe No. 4's drinking habits, their relationship dynamics, and her legal actions against Epstein. The deposition also touches on the deponent's knowledge of Jane Doe No. 4's past and their future plans together.


document_description: This document includes notices of service for plaintiff's answers to defendant's third interrogatories in two separate cases involving Jeffrey Epstein. It includes details of interrogatories related to abortion procedures undergone by plaintiffs E.W. and L.M., along with their responses.


document_description: Letter from Robert D. Critton, Jr. to Adam Horowitz regarding the completion of a deposition for Jane Doe 4. The letter seeks confirmation that the deposition can be deemed complete and ready for the deponent to read and sign.


document_description: Jane Doe seeks a court order to release FBI records about Jeffrey Epstein to support her civil damage action against him for sexual abuse. The motion argues that the need for disclosure outweighs Epstein's privacy interests, especially since he has invoked the Fifth Amendment to block discovery. The motion includes a subpoena to the FBI for evidence related to Epstein's investigation.


document_description: Defendant/Counterplaintiff Bradley J. Edwards denies each affirmative defense in Jeffrey Epstein's Answer to Counterclaim and demands strict proof. Document includes certification of service to all counsel.


document_description: A letter from Robert D. Critton, Jr. to Aaron Podhurst discussing the resolution of three cases related to Mr. Epstein's obligations under the NPA. An offer of $50,000 is extended to each of the three new clients, excluding Jane Doe 103, with a request for a release to be signed. The offer is open for 14 days, with a possibility of extension. The letter also mentions the potential resolution of outstanding attorney fees after these cases are resolved.


document_description: The U.S. Attorney's Office responds to Roy Black regarding Jeffrey Epstein's obligations under the Non-Prosecution Agreement, specifically addressing a motion to dismiss a suit filed by Jane Doe 103.


document_description: Gary M. Bagliebter is a partner at Shutts & Bowen LLP in Fort Lauderdale, specializing in commercial trial practice, anti-money laundering, and compliance matters. He has extensive experience in federal and state courts, and has served in various legal roles including Assistant United States Attorney and Air Force judge advocate. He is involved in several community and professional organizations and serves as adjunct faculty at the University of Miami Law School.


document_description: This document is a legal response from Jane Doe No. 5 to Jeffrey Epstein's request for production of documents. It includes general objections to the requests, citing attorney-client privilege and other protections. The response also mentions the provision of supplemental documents related to medical reports and records.


document_description: A letter from Robert D. Critton, Jr. to Aaron Podhurst and Robert Josefsberg discussing settlement efforts regarding outstanding fee issues related to Jeffrey Epstein. The letter outlines a proposal to review bills on a line-by-line basis to determine obligations under the NPA and offers a monetary settlement alternative.


document_description: Notice of deposition for Ghislane Noelle Maxwell scheduled for May 13, 2010, at Cohen & Gresser, LLP in New York, NY. The deposition is for discovery and trial purposes.


document_description: Plaintiff Jane Doe requests the court to allow filing of Composite Exhibit C (flight logs) under seal due to potential privacy concerns of passengers listed in the logs. The motion is related to the Plaintiff's Corrected Response to Defendant's Motion for Summary Judgment.


document_description: This document is a legal notice for the deposition of Herbert Stettin, Trustee in Bankruptcy for Rothstein Rosenfeldt Adler, P.A., in the case of Jeffrey Epstein v. Scott Rothstein, Bradley J. Edwards, and L.M. The deposition is scheduled for May 19, 2010, at Prose Court Reporting in Fort Lauderdale, FL. The document includes a subpoena duces tecum for various documents related to litigation involving Jeffrey Epstein.


document_description: This document is a court order from the Fifteenth Judicial Circuit in Palm Beach County, Florida, setting a jury trial for the case of Jeffrey Epstein vs. Scott Rothstein, et al. The trial is scheduled to begin on October 25, 2010, with a calendar call on October 15, 2010. The order outlines pretrial procedures, including the exchange of trial exhibits and witness lists, mediation requirements, and potential sanctions for noncompliance.


document_description: Jeffrey Epstein filed a motion requesting a 30-day extension to respond to Bradley J. Edwards' Request to Produce. The request includes documents related to Epstein's claim for damages, such as agreements with attorneys and invoices. Epstein has no objection to providing prescriptions for corrective lenses and has attached the relevant document. The motion argues that the extension will not prejudice Edwards as the trial is set for October 25, 2010.


document_description: A letter from Jessica D. Arbour of Mermelstein & Horowitz PA to Robert D. Critton, Jr. regarding discovery responses in the case of Jane Doe 8 v. Jeffrey Epstein. The letter addresses the plaintiff's current understanding of damages and responses to interrogatories.


document_description: The court grants Defendant L.M.'s Motion for Protective Order without prejudice to the Plaintiff to establish revenue and documentary evidence of the internet.


document_description: Notice of deposition for the case C.L. vs. Jeffrey Epstein, scheduled for May 18, 2010, at 10:00 AM. The deposition will be taken before a videographer and a notary public in Florida.


document_description: A letter from Robert D. Critton, Jr. to Robert Josefsberg discussing settlement negotiations in the Epstein matter. The letter outlines the offers and demands made during a meeting, including a demand for $500,000 to settle four cases and an offer from Epstein for $750,000. The letter emphasizes the inclusion of attorney fees and costs in the settlement amounts.


document_description: A letter from Robert D. Critton, Jr. to Aaron Podhurst and Robert Josefsberg regarding settlement discussions related to fees in the Epstein matter. The letter discusses reviewing bills on a line-by-line basis to resolve fee issues under the NPA and proposes using a neutral special master if necessary.


document_description: A letter from attorney Warren R. Trazenfeld to Robert D. Critton, Jr. regarding a counterclaim filed in the case of Jeffrey Epstein v. Scott Rothstein, et al. The letter mentions the counterclaim being stayed due to bankruptcy proceedings and a declaratory action filed to void malpractice policies. Trazenfeld expresses regret for not being able to assist further.


document_description: A letter from Robert D. Critton, Jr. to Spencer T. Kuvin regarding the case B.B. v. Epstein, providing a copy of Dr. Hall's CME report and discussing the conditions of sharing the report.


document_description: A legal request for documents related to Jeffrey Epstein's business transactions, property interests, financial statements, and communications with the recipient.


document_description: Jeffrey Epstein filed a motion to compel E.W. to provide complete answers to his Fourth Set of Interrogatories, specifically Interrogatory No. 1, which requests detailed employment information. E.W.'s response was deemed inadequate as it lacked business addresses, contact numbers, supervisor details, and rates of pay. The motion seeks a court order for E.W. to fully answer the interrogatory.


document_description: This document is a legal request from Jeffrey Epstein's attorneys to the plaintiff, B.B., to produce documents related to agreements and communications with other plaintiffs in lawsuits against Epstein. It includes definitions, instructions, and specific requests for documents and communications that may involve privileged information.


document_description: This document contains the first set of interrogatories and requests to produce documents directed to Plaintiff Jane Doe No. 103 by Defendant Jeffrey Epstein. It includes definitions, instructions, and specific questions regarding agreements with other plaintiffs and privileged information exchanges.


document_description: This document is a legal notice filed by Defendant Jeffrey Epstein, serving a second set of interrogatories and a request to produce documents to Plaintiff Jane Doe II. It includes definitions, instructions, and specific requests for information and documents related to agreements with other plaintiffs and privileged information exchanges.


document_description: This document contains Jeffrey Epstein's legal requests for production of documents and interrogatories directed to the plaintiff, Jane Doe, in a civil case. It outlines definitions, instructions, and specific requests for documents and information related to agreements between the plaintiff and other parties involved in lawsuits against Epstein.


document_description: Jeffrey Epstein, through his attorneys, filed a motion to amend his previously filed Answer & Affirmative Defenses and Motion to Strike directed to the Plaintiff's Second Amended Complaint. The motion seeks to strike allegations related to a RICO claim that was voluntarily dismissed by the Plaintiff. Epstein also asserts his Fifth Amendment privilege against self-incrimination in response to various allegations.


document_description: The document includes a re-notice for a deposition in the case against Jeffrey Epstein, scheduled for June 15, 2010. It also contains agreed orders related to motions for partial summary judgment in two separate cases involving Epstein, with the court allowing amendments to the complaints.


document_description: The document is a legal memorandum submitted by non-party Town of Palm Beach Police Officers opposing Jeffrey Epstein's motion to compel the production of cell phone records. The officers argue that the records are not likely to lead to discoverable evidence and are protected under Florida's Public Records Law. They also argue that Epstein has not shown 'exceptional necessity' or 'extraordinary circumstances' to warrant disclosure of exempt records.


document_description: This document is a legal notice filed by Defendant Bradley Edwards, serving his answers to the Plaintiff Jeffrey Epstein's first set of interrogatories. The document includes a certificate of service and a list of counsel involved in the case. It also contains detailed answers to the interrogatories, addressing issues related to damages to reputation, professional relationships, and costs incurred due to the lawsuit. The document also includes objections to certain questions based on relevance and privilege.


document_description: This document is a legal response from Defendant Bradley J. Edwards to a request for production by Plaintiff Jeffrey Epstein. The response includes objections based on relevance, privilege, and other legal grounds. It also certifies service to all counsel involved.


document_description: This document outlines the statutes of limitations for various legal actions in the state of Florida, including those related to tax collection, real property, and adverse possession. It specifies time limits for initiating legal proceedings based on different types of claims, such as tax assessments, professional malpractice, and real property recovery. The document also details conditions under which adverse possession claims can be made, both with and without color of title.


document_description: A letter from Robert D. Critton, Jr. to Mark Buckstein regarding the mediation of cases involving Jane Does 3, 4, and 7 against Epstein, scheduled for May 17, 2010. The letter mentions the sequence of events involving JD4 and Mr. Epstein's home, and evaluations by Dr. Kliman. It includes enclosures and is copied to Jack Goldberger and Michael J. Pike.


document_description: Letter from Robert D. Critton, Jr. to Robert Josefsberg and Kathy Ezell regarding trial subpoenas for Jane Does 2 through 7. The letter discusses the authority to accept subpoenas on behalf of clients and the No-Contact Order in place.