027.pdf
58.6 KB
Extraction Summary
4
People
3
Organizations
4
Locations
4
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (response to motion)
File Size:
58.6 KB
Summary
Legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party witness Jean Luc Bruhnel (spelled Bruhnel in document). The filing opposes Plaintiff Jane Doe's motion to compel Bruhnel to appear for a deposition, arguing that Bruhnel is a French citizen who has left the US with no plans to return and cannot be compelled by the Court to return. The document asserts that the Plaintiff should use the Hague Convention or other international mechanisms to secure testimony abroad and accuses Plaintiff's counsel of misrepresentation and failure to follow proper procedure.
People (4)
| Name | Role | Context |
|---|---|---|
| Jean Luc Bruhnel | Non-Party Witness |
French citizen, served with subpoena in NY, currently out of the US with no plans to return. Resisted deposition.
|
| Jane Doe | Plaintiff |
Plaintiff in Case No. 08-CV-80893, seeking to depose Bruhnel.
|
| Jeffrey Epstein | Defendant |
Defendant in Case No. 08-CV-80893.
|
| Tama Beth Kudman | Attorney |
Counsel for Jean Luc Bruhnel, filing the response and requesting sanctions against Plaintiff.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Court where the case is filed.
|
|
| Tama Beth Kudman, P.A. |
Law firm representing Jean Luc Bruhnel.
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| Florida Circuit Court |
Court where related cases are pending.
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Timeline (4 events)
2010-01-01
Approximate date when Plaintiff's counsel contacted Bruhnel's counsel to reschedule deposition after a delay.
N/A
Plaintiff's Counsel
Tama Beth Kudman
2010-03-10
Plaintiff filed Motion for an Order to Show Cause (DE#483)
Southern District of Florida
Plaintiff's Counsel
2010-03-12
Filing of Response to Plaintiff's Motion for an Order to Show Cause
Southern District of Florida
2010-11-03
Date listed in document for a previously agreed deposition (likely a typo for 2009 given the filing date of March 2010, or a future date deemed cancelled).
Florida
Locations (4)
| Location | Context |
|---|---|
|
Location where Bruhnel was visiting when served with the subpoena.
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|
Proposed location for deposition; location of courts.
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Implied residence of Bruhnel (French citizen); signatory to Hague Convention.
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Address of Bruhnel's attorney.
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Relationships (2)
Kudman files response on behalf of Bruhnel as 'undersigned counsel'.
Plaintiff Jane Doe seeks to compel Bruhnel for deposition; Bruhnel resists.
Key Quotes (4)
"Mr. Bruhnel, a french citizen who is not a party to the instant action... sit for a deposition that was canceled and for which he has never been re-noticed."Source
027.pdf
Quote #1
"Mr. Bruhnel had left the United States with no firm plan to return, which was conveyed to plaintiff’s counsel during a telephone conversation in January."Source
027.pdf
Quote #2
"Undersigned counsel told plaintiff’s counsel that there were appropriate mechanisms through which he could secure Mr. Bruhnel’s testimony abroad pursuant to Florida, Federal and International law."Source
027.pdf
Quote #3
"Plaintiff’s counsel has misrepresented to this court that he spoke to Mr. Bruhnel’s counsel about this motion prior to filing it with the Court."Source
027.pdf
Quote #4
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