017-02.pdf
1.46 MB
Extraction Summary
18
People
9
Organizations
2
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal pleading (response in opposition to motion to compel)
File Size:
1.46 MB
Summary
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.
People (18)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Defendant |
Asserting 5th Amendment privilege against self-incrimination to refuse production of photos, financial records, and m...
|
| Jane Doe No. 2 | Plaintiff |
Seeking discovery documents from Epstein including photos, financial records, and medical records.
|
| Dr. Stephan Alexander | Medical Doctor/Expert Consultant |
Hired as an expert consultant for Epstein's defense in criminal matters; Epstein refuses to produce his medical recor...
|
| Sarah Kellen | Defendant (Related Case) |
Mentioned in service list.
|
| Michael J. Pike | Attorney for Defendant |
Signatory on the motion.
|
| Robert D. Critton, Jr. | Attorney for Defendant |
Signatory on the motion.
|
| Jack Alan Goldberger | Attorney for Defendant |
Counsel for Defendant Jeffrey Epstein.
|
| Brad Edwards | Attorney for Plaintiff |
Counsel for Plaintiff in Related Case No. 08-80893.
|
| Paul G. Cassell | Attorney for Plaintiff |
Co-counsel for Plaintiff Jane Doe.
|
| Stuart S. Mermelstein | Attorney for Plaintiff |
Counsel for Plaintiffs.
|
| Adam D. Horowitz | Attorney for Plaintiff |
Counsel for Plaintiffs.
|
| Richard Horace Willits | Attorney |
Listed in Service List.
|
| Jack Scarola | Attorney for Plaintiff |
Counsel for Plaintiff, C.M.A.
|
| Jack P. Hill | Attorney for Plaintiff |
Counsel for Plaintiff, C.M.A.
|
| Bruce Reinhart | Attorney |
Counsel for Defendant Sarah Kellen.
|
| Isidro M. Garcia | Attorney for Plaintiff |
Counsel for Plaintiff in Related Case No. 08-80469.
|
| Robert C. Josefsberg | Attorney for Plaintiff |
Counsel for Plaintiffs in Related Cases Nos. 09-80591 and 09-80656.
|
| Katherine W. Ezell | Attorney for Plaintiff |
Counsel for Plaintiffs in Related Cases Nos. 09-80591 and 09-80656.
|
Organizations (9)
| Name | Type | Context |
|---|---|---|
| United States District Court, Southern District of Florida |
Court where the case is filed.
|
|
| USAO |
United States Attorney's Office for the Southern District of Florida.
|
|
| State Attorney's Office |
Palm Beach County prosecutors.
|
|
| Burman, Critton, Luttier & Coleman |
Law firm representing Jeffrey Epstein.
|
|
| Rothstein Rosenfeldt Adler |
Law firm representing Plaintiff.
|
|
| Mermelstein & Horowitz, P.A. |
Law firm representing Plaintiffs.
|
|
| Searcy Denney Scarola Barnhart & Shipley, P.A. |
Law firm representing Plaintiff.
|
|
| Podhurst Orseck, P.A. |
Law firm representing Plaintiffs.
|
|
| Atterbury Goldberger & Weiss, P.A. |
Law firm representing Defendant.
|
Timeline (2 events)
2008
Epstein entered into a Non-Prosecution Agreement (NPA).
Southern District of Florida
2009-10-06
Filing of Defendant's Response in Opposition to Plaintiff's Motion to Compel.
Southern District of Florida
Locations (2)
| Location | Context |
|---|---|
|
Epstein's home; Plaintiff requested photos of the interior/massage room.
|
|
|
Jurisdiction of the court and the NPA.
|
Relationships (2)
Document states Dr. Stephen Alexander was hired as an expert consultant by Epstein's attorneys in the underlying criminal matter.
Plaintiff vs. Defendant in civil lawsuit.
Key Quotes (5)
"I cannot select, authenticate, and produce documents relevant to this lawsuit without waiving my Fifth Amendment rights and I must accept this advice or risk losing my Sixth Amendment right to effective representation."Source
017-02.pdf
Quote #1
"Epstein's selection and production of photos would constitute compelled testimonial admissions that 'the massages' took place in a given room on a given table etc."Source
017-02.pdf
Quote #2
"the NPA only defers prosecution in the Southern District of Florida, not other districts."Source
017-02.pdf
Quote #3
"the threat of prosecution is real, substantial and present."Source
017-02.pdf
Quote #4
"Requiring Epstein to provide responses would in essence be compelling him to provide assertions of fact that could incriminate him under 18 U.S.C. §2422(b) and 18 U.S.C. §2423(b)..."Source
017-02.pdf
Quote #5
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