11/20/2008 09:44 AM

Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant, Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing this action for a time certain (i.e., until late 2010 when the NPA expires), pursuant to the application of the Fifth Amendment of the U.S. Constitution and the fact that a parallel proceeding is ongoing and being investigated. In support of his motion, EPSTEIN states: I. Introduction At the outset, EPSTEIN notes this Court's prior Order, (DE 33), in which this Court denied a motion for stay brought by Def

Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 25 Entered on FLSD Docket 0718/2008 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MEMORANDUM OF LAW IN RESPONSE TO DEFENDANT'S MOTION FOR STAY Plaintiff, Jane Doe No. 2, by and through her undersigned counsel, submits this Memorandum of Law in Response to Motion for Stay, as follows: INTRODUCTION Defendant Jeffrey Epstein's Motion to Stay this action is based on the incorrect premise that there are criminal actions pending against him in Palm Beach Circuit Court, State of Florida. Jeffrey Epstein, Case No. 2006 CF 09454 AXXMB (Fifteenth Judicial Circuit, Palm Beach County), and in the Southern District of Florida, In re Grand Jury, No. FGJ 07-103 (WPB) (S.D. Fla.). The Motion to Stay as to the state court criminal action was rendered moot on June 30, 2008 when Jeffrey Epstein entered a plea of guilty to

Epstein Depositions

10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps

EFTA02729648

Unsealed Jeffrey Epstein court papers

January 3, 2024 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Pursuant to the Court’s December 18, 2023, unsealing order, and following conferral with Defendant, Plaintiff files this set of documents ordered unsealed. The filing of these documents ordered unsealed will be done on a rolling basis until c

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 PLAINTIFF JANE DOE'S EMERGENCY MOTION TO HAVE EPSTEIN HELD IN CONTEMPT FOR FAILING TO PRODUCE STATE DISCOVERY AND CORRESPONDENCE AND FOR PRODUCING ONLY REDACTED CORRESPONDENCE WITH THE U.S. ATTORNEY'S OFFICE AND MOTION FOR SANCTIONS Plaintiff, Jane Doe, through undersigned counsel, hereby files this motion to have defendant Epstein held in contempt for (1) failing to produce any state criminal discovery and any correspondence with state prosecutors, and (2) producing only redacted correspondence with the U.S. Attorney's Office. Both of these failures stand in clear violation of this Court's discovery orders. Jane Doe further asks that Epstein be directed to produce these materia