022.pdf
85.4 KB
Extraction Summary
21
People
10
Organizations
5
Locations
0
Events
3
Relationships
5
Quotes
Document Information
Type:
Legal pleading (reply brief)
File Size:
85.4 KB
Summary
This document is a legal reply brief filed on May 29, 2009, by Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida. The plaintiffs seek to proceed anonymously in their lawsuit against Jeffrey Epstein, arguing that revealing their identities would subject them to harassment, shame, and further trauma, particularly given their status as victims of sexual exploitation as minors. The filing also discusses the Non-Prosecution Agreement (NPA), statutory minimum damages under 18 U.S.C. § 2255, and accuses Epstein of using the threat of publicity to intimidate victims into settling.
People (21)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 101 | Plaintiff |
Victim seeking to proceed anonymously in lawsuit against Epstein.
|
| Jane Doe No. 102 | Plaintiff |
Victim seeking to proceed anonymously in lawsuit against Epstein.
|
| Jeffrey Epstein | Defendant |
Accused of sexual exploitation of minors; opposing plaintiffs' anonymity.
|
| Sarah Kellen | Co-Defendant |
Mentioned in service list as co-defendant.
|
| C.M.A. | Plaintiff |
Plaintiff in related case 08-CV-80811.
|
| Jane Doe No. 2 | Plaintiff |
Plaintiff in related case 08-CV-80119.
|
| Katherine W. Ezell | Attorney |
Counsel for Plaintiffs Jane Doe 101 and 102 (Podhurst Orseck, P.A.).
|
| Robert C. Josefsberg | Attorney |
Counsel for Plaintiffs Jane Doe 101 and 102 (Podhurst Orseck, P.A.).
|
| Robert Critton | Attorney |
Counsel for Defendant Jeffrey Epstein.
|
| Michael J. Pike | Attorney |
Counsel for Defendant Jeffrey Epstein.
|
| Jack Goldberger | Attorney |
Co-Counsel for Defendant Jeffrey Epstein.
|
| Bruce E. Reinhart | Attorney |
Counsel for Co-Defendant Sarah Kellen.
|
| Jack Scarola | Attorney |
Counsel for Plaintiff C.M.A.
|
| Jack P. Hill | Attorney |
Counsel for Plaintiff C.M.A.
|
| Adam Horowitz | Attorney |
Counsel for Plaintiffs in related cases.
|
| Stuart Mermelstein | Attorney |
Counsel for Plaintiffs in related cases.
|
| Spencer Todd Kuvin | Attorney |
Counsel for Plaintiff in related case 08-08804.
|
| Theodore Jon Leopold | Attorney |
Counsel for Plaintiff in related case 08-08804.
|
| Richard H. Willits | Attorney |
Counsel for Plaintiff in related case 08-80811.
|
| Brad Edwards | Attorney |
Counsel for Plaintiff in related case 08-80893.
|
| Isidro Manuel Garcia | Attorney |
Counsel for Plaintiff in related case 08-80469.
|
Organizations (10)
Locations (5)
| Location | Context |
|---|---|
Relationships (3)
Case caption: Jane Doe No. 101 vs. Jeffrey Epstein
Service list identifies Sarah Kellen as Co-Defendant
Service list: 'Counsel for Co-Defendant, Sarah Kellen'
Key Quotes (5)
"Defendant openly admits to his desire to reveal the victims’ names in newspapers so that individuals in their community can come forward to assault their credibility and tarnish their reputations (and, as a result, their dignity)."Source
022.pdf
Quote #1
"Defendant committed crimes constituting the 'ultimate violation of self' against minors."Source
022.pdf
Quote #2
"Defendant is using the threat of publicity to attempt to intimidate victims to cause them not to file suit or to settle their claims for the absolute minimum..."Source
022.pdf
Quote #3
"Plaintiffs attempted to utilize the process established by the Non-Prosecution Agreement (“NPA”) with the reasonable expectation that a specific purpose of the NPA was to allow Defendant’s victims to maintain anonymity..."Source
022.pdf
Quote #4
"Defendant has attempted to force settlements on any victims as possible without considering the possibility that the minimum amount recoverable under 18 U.S.C. § 2255 is $150,000 per count and/or per incident."Source
022.pdf
Quote #5
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