076.pdf

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Extraction Summary

15
People
2
Organizations
2
Locations
1
Events
1
Relationships
5
Quotes

Document Information

Type: Legal memorandum (plaintiff's response to rule 4 appeal)
File Size: 63.5 KB
Summary

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.

People (15)

Name Role Context
Jeffrey Epstein Defendant
Accused of sexual molestation; appealing order to produce tax returns; asserting Fifth Amendment privilege.
Jane Doe No. 2 Plaintiff
Named plaintiff in the caption.
Jane Does 2-8 Plaintiffs
Group of plaintiffs filing the memorandum.
Stuart S. Mermelstein Attorney
Attorney for Plaintiffs; signed the memorandum and certificate of service.
Adam D. Horowitz Attorney
Attorney for Plaintiffs.
Jack Alan Goldberger Attorney
On Service List.
Robert D. Critton Attorney
On Service List.
Bradley James Edwards Attorney
On Service List.
Isidro Manuel Garcia Attorney
On Service List.
Jack Patrick Hill Attorney
On Service List.
Katherine Warthen Ezell Attorney
On Service List.
Michael James Pike Attorney
On Service List.
Paul G. Cassell Attorney
On Service List.
Richard Horace Willits Attorney
On Service List.
Robert C. Josefsberg Attorney
On Service List.

Timeline (1 events)

2010-05-28
Filing of Plaintiffs' Memorandum in Response to Defendant's Rule 4 Appeal regarding the production of tax returns.
United States District Court, Southern District of Florida

Locations (2)

Relationships (1)

Jeffrey Epstein Legal Adversaries Jane Does 2-8
Defendant vs. Plaintiffs in civil lawsuit alleging sexual molestation.

Key Quotes (5)

"Defendant appeals the Magistrate Judge’s Orders (DE 480 and DE 513) compelling Defendant to produce income tax returns and related forms and schedules."
Source
076.pdf
Quote #1
"The tax returns are indisputably relevant in these cases, particularly as to Plaintiff’s claims for punitive damages, and given the Defendant’s invocation of the Fifth Amendment in blanket fashion to all requests for net worth discovery..."
Source
076.pdf
Quote #2
"Defendant Epstein is alleged to have perpetrated a plan and scheme to sexually molest dozens of underage teenage girls."
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076.pdf
Quote #3
"Defendant nonetheless contends that there exists an 'alternative' - not to discovery of the necessary information, but through his offer to 'stipulate' to a net worth in the nine figures."
Source
076.pdf
Quote #4
"Plaintiffs are therefore entitled to discovery on the Defendant’s real net worth so that the jury will be in a position to make an award that 'will hurt'."
Source
076.pdf
Quote #5

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