075.pdf
58.6 KB
Extraction Summary
5
People
3
Organizations
5
Locations
3
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal response (response to motion for order to show cause)
File Size:
58.6 KB
Summary
A legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party Jean Luc Bruhnel (spelled 'Bruhnel' in document) in the case of Jane Doe v. Jeffrey Epstein. The filing opposes a motion to compel Bruhnel's deposition, arguing that he is a French citizen who has left the U.S. with no plans to return and cannot be compelled to appear under Federal Rules. The document alleges misrepresentation and nonfeasance by the Plaintiff's counsel and suggests using the Hague Convention to secure testimony abroad.
People (5)
| Name | Role | Context |
|---|---|---|
| Jean Luc Bruhnel | Non-party witness |
French citizen, served with subpoena in NY, left US without plans to return. (Note: Often spelled Brunel in other con...
|
| Jane Doe | Plaintiff |
Plaintiff filing motion to compel Bruhnel's deposition.
|
| Jeffrey Epstein | Defendant |
Defendant in the main civil case.
|
| Tama Beth Kudman | Attorney |
Legal counsel for Jean Luc Bruhnel; author of the filing.
|
| Plaintiff's Counsel | Attorney |
Accused of misrepresentation and nonfeasance; previous law partner involved in a scandal.
|
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 |
Mentioned regarding related cases.
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Timeline (3 events)
2010-03-10
Plaintiff Jane Doe filed Motion for an Order to Show Cause and for an Order to Compel.
Southern District of Florida
2010-03-12
Filing of Response by Jean Luc Bruhnel.
Southern District of Florida
2010-11-03
Scheduled date for Bruhnel's deposition in Florida (Note: Text says 2010, likely typo for 2009 given the filing is March 2010 and refers to past events).
Florida
Locations (5)
| Location | Context |
|---|---|
|
Location where Jean Luc Bruhnel was served with a subpoena.
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Proposed location for deposition; location of related cases.
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Address of Tama Beth Kudman, P.A.
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Country of Bruhnel's citizenship; signatory to Hague Convention.
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Country Bruhnel left with no plans to return.
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Relationships (2)
Undersigned counsel for Mr. Bruhnel
Non-party witness in case against Epstein; served with subpoena.
Key Quotes (5)
"Mr. Bruhnel, a french citizen who is not a party to the instant action..."Source
075.pdf
Quote #1
"This motion is premature at best, and frivolous."Source
075.pdf
Quote #2
"Mr. Bruhnel had left the United States with no firm plan to return..."Source
075.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..."Source
075.pdf
Quote #4
"Accordingly, there has been no malfeasance herein by Mr. Bruhnel or his counsel, only nonfeasance by plaintiff’s counsel."Source
075.pdf
Quote #5
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