Mermelstein & Horowitz, P.A.
OrganizationRelationship Network
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person
Gilbert W. Kliman, M.D.
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Professional retained expert |
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person
Gilbert W. Kliman, M.D.
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Professional retained expert |
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017-02.pdf
This document is a legal response filed by Jeffrey Epstein's legal team on October 6, 2009, opposing a Motion to Compel discovery filed by Plaintiff Jane Doe No. 2. Epstein asserts his Fifth Amendment privilege against self-incrimination to refuse the production of photographs of his Palm Beach home (specifically massage rooms), financial records, tax returns, passport/travel records, and medical records from Dr. Stephan Alexander. The defense argues that despite the Non-Prosecution Agreement (NPA), the threat of federal prosecution remains real and substantial, particularly in districts outside the Southern District of Florida, and that the act of producing these documents would be testimonial and incriminating.
016-13.pdf
This document is a Motion for Sanctions filed by Plaintiff Jane Doe No. 3 against Jeffrey Epstein on January 4, 2010. The motion alleges that Epstein flagrantly violated multiple court orders, including a No-Contact Order, by deliberately appearing at the location of the Plaintiff's Independent Medical Examination (IME) on November 24, 2009. The Plaintiff requests sanctions, attorney's fees, and a protective order moving the remainder of her IME to a different city, citing the trauma caused by the encounter.
016-12.pdf
This document is a Motion for Sanctions filed by Plaintiff Jane Doe No. 4 against Jeffrey Epstein for violating a no-contact order and a written stipulation. On September 16, 2009, Epstein appeared in the lobby of the building where Jane Doe No. 4's deposition was scheduled, staring her down and causing her to flee in distress, despite an agreement that he would not attend. The document includes a declaration from attorney Adam Horowitz, a transcript of the cancelled deposition where defense counsel Robert Critton argues Epstein was simply leaving his office in the same building, and an email confirming the prior stipulation.
016-02.pdf
This document is a Motion for No-Contact Order filed by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein in the Southern District of Florida on May 22, 2009. The plaintiffs argue that despite a state plea agreement prohibiting contact, Epstein's counsel refused to confirm he would not contact federal victims. The filing includes exhibits of correspondence between attorneys and a transcript of the 2008 plea conference where Judge Pucillo explicitly defined 'indirect contact' to include Facebook and MySpace.
017.pdf
This document is a legal notice filed on June 14, 2010, in the United States District Court for the Southern District of Florida, regarding the case of Jane Doe No. 2 v. Jeffrey Epstein. The filing, submitted by attorney Spencer T. Kuvin on behalf of Plaintiff 'C.L.', serves to withdraw a subpoena and cancel the scheduled deposition of Maritza Milagros Vasquez, which was set for the following day, June 15, 2010. The document also includes a certificate of service listing various attorneys representing different parties in related cases against Epstein.
015.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) opposing Jeffrey Epstein's appeal of a Magistrate Judge's order compelling him to produce income tax returns for the years 2003-2008. The Plaintiffs argue that tax returns are 'required records' not protected by the Fifth Amendment privilege against self-incrimination and are critical for determining punitive damages. The document notes that Epstein attempted to avoid producing these records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs rejected as insufficient.
010.pdf
This is a motion filed by Defendant Jeffrey Epstein's attorneys requesting a court order to allow him to attend mediation, deposition, and trial in the case of Jane Doe No. 2 v. Jeffrey Epstein. The motion notes that a prior no-contact order involving Carolyn Andriano might technically preclude this, but states that Plaintiff's counsel and Ms. Andriano have no objection. The document includes a certificate of service listing numerous attorneys involved in related cases.
009.pdf
Legal filing from November 2009 in the case of Jane Doe No. 2 v. Jeffrey Epstein. Epstein's attorneys argue for the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), noting that the DOJ has seized boxes of documents from RRA, including 13 boxes related to Epstein. The document also disputes delays in the deposition of RRA's Chief Restructuring Officer, Herbert Stettin, citing upcoming trial deadlines.
078.pdf
This document is a legal notice filed on June 14, 2010, in the case of Jane Doe No. 2 v. Jeffrey Epstein. The notice, filed by attorney Spencer T. Kuvin on behalf of Plaintiff C.L., withdraws a subpoena and cancels the deposition of Maritza Milagros Vasquez, which was scheduled for the following day, June 15, 2010. The document also includes a certificate of service listing legal counsel for various parties involved in related cases.
076.pdf
This document is a legal memorandum filed by the Plaintiffs (Jane Does 2-8) in response to Jeffrey Epstein's appeal of a Magistrate Judge's order compelling him to produce his income tax returns for the years 2003-2008. The Plaintiffs argue that the tax returns are relevant for determining punitive damages and are not protected by the Fifth Amendment privilege against self-incrimination, citing the 'required records' exception. The document also notes Epstein's attempt to avoid producing records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs reject as insufficient.
071.pdf
A 2009 legal motion filed in the Southern District of Florida on behalf of Jeffrey Epstein requesting permission to attend mediation in a case involving Carolyn Andriano (C.M.A.). The motion notes that a prior 'no contact order' exists regarding Andriano, but states that neither she nor her counsel object to Epstein's presence at depositions, mediation, or trial. The document includes a comprehensive service list of attorneys involved in multiple related cases against Epstein.
069.pdf
This document is a legal motion filed on November 9, 2009, by Igor Zinoviev, a third-party witness and employee of Jeffrey Epstein, seeking a protective order to prevent or limit his deposition in the civil case 'Jane Doe No. 2 v. Jeffrey Epstein'. Zinoviev claims he has no relevant information for the civil cases as his employment with Epstein began in November 2005, after the period of the alleged misconduct, and he has not discussed Epstein's criminal or civil cases with him.
052.pdf
This document is a Motion for Protective Order filed on July 29, 2009, in the Southern District of Florida by Plaintiffs 'Jane Does 2-7' against Jeffrey Epstein. The plaintiffs allege that Epstein hired private investigators to harass and intimidate them by contacting their former employers, ex-boyfriends, and friends to ask intrusive personal questions and potentially 'out' them as sexual abuse victims. The motion seeks a court order to stop Epstein's investigators from making ex parte contacts with nonparties associated with the plaintiffs.
050.pdf
This document is a Notice of Compliance filed by Jeffrey Epstein's legal team (Burman, Critton, Luttier & Coleman) on July 28, 2009, in the US District Court for the Southern District of Florida. It addresses a court order regarding the preservation of evidence and a protective order, noting that while the parties agreed on many sections, they could not finalize a joint order, leading Epstein to submit his own proposed order separately. The document lists numerous related civil cases involving Jane Doe plaintiffs and provides a comprehensive service list of attorneys involved in the various Epstein-related litigations at that time, including Bruce Reinhart representing Sarah Kellen.
034-01.pdf
This document is a sworn declaration by Dr. Gilbert W. Kliman, a forensic psychiatrist, filed on June 8, 2009, in the case of Does v. Jeffrey Epstein. Dr. Kliman argues against the defense's motion to publicly disclose the identities of six Jane Doe plaintiffs, stating that such exposure would cause severe psychological harm, including revictimization, stigmatization, and retraumatization. He details how Epstein manipulated the victims by posing as a mentor and outlines the plaintiffs' diagnoses of PTSD and depression, concluding that anonymity is clinically necessary to prevent further injury.
032.pdf
This document is a legal reply filed on June 4, 2009, by Plaintiffs Jane Doe No. 101 and 102 in the US District Court for the Southern District of Florida. The plaintiffs are requesting a court order prohibiting Jeffrey Epstein and his agents from contacting them directly or indirectly, citing his status as a convicted sex offender and their fear of intimidation. The document also includes a service list detailing the legal representation for various parties, including Bruce E. Reinhart representing co-defendant Sarah Kellen.
027.pdf
This document is a Motion for Leave to File Under Seal submitted on May 29, 2009, by attorneys for Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida. The plaintiffs request permission to file their response to Epstein's Motion to Stay under seal, or alternatively, request the court to unseal the Non-Prosecution Agreement (NPA) so they can adequately respond. The document includes a comprehensive service list detailing attorneys representing Epstein, co-defendant Sarah Kellen (represented by Bruce Reinhart), and various other Jane Doe plaintiffs.
025.pdf
This document is a legal reply filed on May 29, 2009, by Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida, arguing for the right to proceed anonymously in their lawsuit against Jeffrey Epstein. The plaintiffs contend that Epstein aims to reveal their identities to harass and intimidate them, and they cite various legal precedents and the Non-Prosecution Agreement (NPA) to support their request for privacy due to the sexual nature of the crimes committed against them as minors. The document also includes a service list detailing the attorneys representing various parties in related cases against Epstein.
021.pdf
This document is a Notice of Filing Proposed Order submitted to the U.S. District Court for the Southern District of Florida on May 27, 2009. It lists eleven separate civil cases filed against Jeffrey Epstein by various plaintiffs, including Jane Does 2-7, 101, 102, C.M.A., and Doe II. The filing serves to submit a proposed order related to case no. 08-80119 and includes a service list of attorneys involved in the litigation.
030.pdf
This document is a Notice of Withdrawing Subpoena filed on June 14, 2010, in the United States District Court for the Southern District of Florida. Plaintiff C.L., represented by attorney Spencer T. Kuvin, withdrew a subpoena and cancelled the deposition of Maritza Milagros Vasquez, which had been scheduled for June 15, 2010. The document includes a certificate of service listing legal counsel for various parties involved in the primary case (Jane Doe No. 2 v. Jeffrey Epstein) and related cases.
028.pdf
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) in the case Jane Doe No. 2 vs. Jeffrey Epstein (Case No. 08-CV-80119-MARRA/JOHNSON). The memorandum opposes Epstein's appeal of a Magistrate Judge's order compelling him to produce his income tax returns for the years 2003-2008. The Plaintiffs argue that the tax returns are not protected by the Fifth Amendment (citing the 'required records' exception and 'foregone conclusion' doctrine) and are critical for determining punitive damages given the allegations of sexual molestation and Epstein's refusal to provide net worth discovery beyond a stipulation of 'nine figures.'
022.pdf
This document is an unopposed motion filed on December 3, 2009, by Plaintiff Jane Doe No. 8 in the Southern District of Florida, requesting an extension of time until December 14, 2009, to file an Amended Complaint against Jeffrey Epstein. The request cites obligations of the plaintiff's counsel, Stuart Mermelstein and Adam Horowitz, in other matters, including other Epstein cases. The defendant's counsel, identified in the service list as Jack Alan Goldberger and Robert D. Critton, did not object to the extension.
017.pdf
Legal filing from November 2009 in the case of Jane Doe No. 2 v. Jeffrey Epstein. Epstein's attorneys reply to a response regarding the preservation of evidence held by the law firm Rothstein Rosenfeldt Adler (RRA), which was undergoing restructuring. The document notes that the Department of Justice had seized approximately 40 boxes of documents from RRA, including 13 boxes related to the Epstein case, and alludes to serious ethical and criminal issues involving the RRA firm that could impact the validity of the cases against Epstein.
016.pdf
This document is a legal motion filed on November 9, 2009, by third-party witness Igor Zinoviev, seeking a protective order to prevent or limit his deposition in the case of Jane Doe No. 2 v. Jeffrey Epstein. Zinoviev, a driver and bodyguard for Epstein since November 2005, claims he has no relevant information regarding Epstein's criminal or civil cases, particularly concerning events prior to September 2005. The motion cites legal precedents regarding the scope of discovery and Federal Rules of Civil Procedure Rule 26(c) to argue against the deposition.
011.pdf
Legal motion filed on August 11, 2009, in the Southern District of Florida, requesting to consolidate the case of Jane Doe No. 8 v. Jeffrey Epstein with the lead case Jane Doe No. 2 v. Jeffrey Epstein for discovery purposes. The document states that the case involves alleged sexual abuse in Palm Beach, Florida, in 2001. The motion was unopposed by the Defendant's counsel.
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