020.pdf
213 KB
Extraction Summary
7
People
4
Organizations
3
Locations
10
Events
3
Relationships
4
Quotes
Document Information
Type:
Plaintiff's memorandum of law in opposition to defendant epstein's motion to dismiss
File Size:
213 KB
Summary
This document is the Plaintiff's Memorandum of Law in Opposition to Defendant Epstein's Motion to Dismiss in a civil case. The Plaintiff argues that the federal court has jurisdiction alongside state claims, that the 2006 amendments to 18 U.S.C. §2255 regarding damages should apply retroactively or are procedural, and that interstate commerce requirements were met via phone calls made by co-defendant Sarah Kellen from a New York number. The document details specific dates of solicitation between 2003 and 2005 and alleges a conspiracy involving Epstein, Kellen, and Haley Robson to procure minors for prostitution.
People (7)
| Name | Role | Context |
|---|---|---|
| Jane Doe II | Plaintiff |
Victim suing Jeffrey Epstein and Sarah Kellen for sexual acts committed while she was a minor.
|
| Jeffrey Epstein | Defendant |
Sued for soliciting a minor for prostitution; accused of multiple counts of sexual abuse.
|
| Sarah Kellen | Defendant |
Epstein's employee/assistant; accused of conspiring to solicit young women and using her cell phone to schedule appoi...
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| Isidro M. Garcia | Plaintiff's Attorney |
Attorney filing the memorandum in opposition to dismissal.
|
| Haley Robson | Alleged Co-conspirator |
Named as a person employed by Epstein to solicit young women.
|
| Robert D. Critton | Defense Attorney |
Listed on Certificate of Service.
|
| Michael Pike | Defense Attorney |
Listed on Certificate of Service.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States District Court, Southern District of Florida |
The court where the case is being heard.
|
|
| Garcia Law Firm, P.A. |
Law firm representing the Plaintiff.
|
|
| Burman Critton Luttier & Coleman |
Law firm representing the Defense.
|
|
| United States Attorney's Office |
Mentioned in relation to Epstein's non-prosecution agreement.
|
Timeline (10 events)
2003-06-16
Defendant Epstein solicited the Plaintiff for prostitution while she was a minor.
Palm Beach, FL
2003-07-02
Defendant Epstein solicited the Plaintiff for prostitution while she was a minor.
Palm Beach, FL
2004-04-09
Defendant Epstein solicited the Plaintiff for prostitution while she was a minor.
Palm Beach, FL
2004-06-07
Defendant Epstein solicited the Plaintiff for prostitution while she was a minor.
Palm Beach, FL
2004-07-30
Defendant Epstein solicited the Plaintiff for prostitution while she was a minor.
Palm Beach, FL
2004-08-30
Defendant Epstein solicited the Plaintiff for prostitution while she was a minor.
Palm Beach, FL
2004-10-09
Defendant Epstein solicited the Plaintiff for prostitution while she was a minor.
Palm Beach, FL
2004-10-12
Defendant Epstein solicited the Plaintiff for prostitution while she was a minor.
Palm Beach, FL
2004-10-30
Defendant Epstein solicited the Plaintiff for prostitution while she was a minor.
Palm Beach, FL
2004-11-09
Defendant Epstein solicited the Plaintiff for prostitution while she was a minor.
Palm Beach, FL
Locations (3)
| Location | Context |
|---|---|
|
Location of the alleged incidents and Epstein's home.
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Residence of Sarah Kellen and location associated with her phone number (917 area code).
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Location of legal counsel offices.
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Relationships (3)
Kellen employed to solicit young women; used her phone to schedule appointments; present at Epstein's home.
Named as a person employed by Epstein to solicit young women.
Kellen called Jane Doe II to schedule 'massages' and sexual encounters.
Key Quotes (4)
"Defendant EPSTEIN, in agreement with two (2) persons he employed for this purpose, HALEY ROBSON and Defendant KELLEN, conspired with these other two, and others, to solicit young women of the type Defendant EPSTEIN preferred, blonde, attractive in appearance, and younger than 18 years of age..."Source
020.pdf
Quote #1
"Defendant EPSTEIN would script lines for the Plaintiff to say, including calling out his name and requesting that he perform a certain sexual act 'harder,' while he touched the Plaintiff’s vagina with a vibrator or with his fingers..."Source
020.pdf
Quote #2
"Defendant EPSTEIN would pay the Plaintiff a fee of $200 on each occasion after he ejaculated while masturbating in the presence of the Plaintiff."Source
020.pdf
Quote #3
"Plaintiff was called by Defendant KELLER, who used her cell phone with a 917 exchange, a New York exchange, and presumably set up the event after being instructed by Defendant EPSTEIN..."Source
020.pdf
Quote #4
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