016.pdf

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Extraction Summary

7
People
4
Organizations
3
Locations
2
Events
2
Relationships
5
Quotes

Document Information

Type: Legal pleading (response in opposition to motion to proceed anonymously and motion to compel/identify plaintiff)
File Size: 671 KB
Summary

This document is a legal response filed by Jeffrey Epstein's legal team on May 11, 2009, in the case of Jane Doe No. 101 v. Jeffrey Epstein. Epstein's attorneys oppose the plaintiff's motion to proceed anonymously, arguing that Epstein's due process rights to conduct discovery—specifically issuance of third-party subpoenas to medical providers and employers—require the use of the plaintiff's legal name. The filing asserts that the plaintiff's privacy interests do not outweigh the presumption of open judicial proceedings and Epstein's right to defend himself against allegations of sexual exploitation and coercion.

People (7)

Name Role Context
Jane Doe No. 101 Plaintiff
Alleged victim suing Jeffrey Epstein for sexual exploitation, coercion, and enticement. Seeking to proceed anonymously.
Jeffrey Epstein Defendant
Sued by Jane Doe No. 101. Arguing against her anonymity to conduct defense discovery.
Robert D. Critton, Jr. Attorney
Counsel for Defendant Jeffrey Epstein; Florida Bar No. 224162.
Michael J. Pike Attorney
Counsel for Defendant Jeffrey Epstein; Florida Bar #617296.
Robert C. Josefsberg Attorney
Counsel for Plaintiff.
Katherine W. Ezell Attorney
Counsel for Plaintiff.
Jack Alan Goldberger Attorney
Counsel for Defendant Jeffrey Epstein.

Organizations (4)

Name Type Context
United States District Court Southern District of Florida
Court where the case is filed.
Burman, Critton, Luttier & Coleman
Law firm representing Jeffrey Epstein.
Podhurst Orseck, P.A.
Law firm representing the Plaintiff.
Atterbury Goldberger & Weiss, P.A.
Law firm representing Jeffrey Epstein.

Timeline (2 events)

2009-04-17
Plaintiff filed action against Epstein (Complaint DE 1).
Southern District of Florida
2009-05-11
Document entered on FLSD Docket.
Southern District of Florida
Court Clerk

Locations (3)

Location Context
Jurisdiction of the court.
Address of Epstein's attorneys.
Address of Plaintiff's attorneys.

Relationships (2)

Jeffrey Epstein Legal Adversary/Accused Abuser Jane Doe No. 101
Jane Doe is suing Epstein for coercion, enticement of a minor, and sexual exploitation.
Robert D. Critton, Jr. Attorney-Client Jeffrey Epstein
Signed as Counsel for Defendant Jeffrey Epstein.

Key Quotes (5)

"Epstein has a constitutional due process right to defend himself and to seek the production of information that will assist in his defense of the allegations in the Complaint."
Source
016.pdf
Quote #1
"Allowing JANE DOE to litigate this matter under a pseudonym is preventing Epstein from defending this suit including, but not limited to, preventing him from locating individuals that may have information about this lawsuit"
Source
016.pdf
Quote #2
"It is the undersigned's experience that once identified, witnesses begin to come forward."
Source
016.pdf
Quote #3
"Plaintiff alleges specific disorders as a result of Epstein's alleged conduct - suffer '... physical injury, pain and suffering, emotional distress, psychological and psychiatric trauma...'"
Source
016.pdf
Quote #4
"Epstein is entitled to know whether Jane Doe committed and/or was charged with any crimes."
Source
016.pdf
Quote #5

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