015.pdf
63.5 KB
Extraction Summary
15
People
2
Organizations
2
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal memorandum (plaintiffs' response to defendant's rule 4 appeal)
File Size:
63.5 KB
Summary
This document is a legal memorandum filed on May 28, 2010, by Plaintiffs (Jane Does 2-8) opposing Jeffrey Epstein's appeal of a Magistrate Judge's order compelling him to produce income tax returns for the years 2003-2008. The Plaintiffs argue that tax returns are 'required records' not protected by the Fifth Amendment privilege against self-incrimination and are critical for determining punitive damages. The document notes that Epstein attempted to avoid producing these records by offering to stipulate to a net worth in the 'nine figures,' which the Plaintiffs rejected as insufficient.
People (15)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 2 | Plaintiff |
Filing memorandum against Epstein to compel production of tax returns.
|
| Jane Does 2-8 | Plaintiffs |
Collective plaintiffs filing the memorandum.
|
| Jeffrey Epstein | Defendant |
Attempting to block discovery of tax returns via Fifth Amendment privilege; alleged to have molested dozens of undera...
|
| Stuart S. Mermelstein | Attorney |
Counsel for Plaintiffs, signer of the document.
|
| Adam D. Horowitz | Attorney |
Counsel for Plaintiffs.
|
| Jack Alan Goldberger | Attorney |
Service List recipient.
|
| Robert D. Critton | Attorney |
Service List recipient.
|
| Bradley James Edwards | Attorney |
Service List recipient (RRA Law).
|
| Isidro Manuel Garcia | Attorney |
Service List recipient.
|
| Jack Patrick Hill | Attorney |
Service List recipient.
|
| Katherine Warthen Ezell | Attorney |
Service List recipient.
|
| Michael James Pike | Attorney |
Service List recipient.
|
| Paul G. Cassell | Attorney |
Service List recipient.
|
| Richard Horace Willits | Attorney |
Service List recipient.
|
| Robert C. Josefsberg | Attorney |
Service List recipient.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Venue of the lawsuit.
|
|
| Mermelstein & Horowitz, P.A. |
Representing the Plaintiffs.
|
Timeline (2 events)
2010-05-28
Filing of Plaintiffs' Memorandum in Response to Defendant's Rule 4 Appeal
Southern District of Florida
Pre-2010-05-28
Magistrate Judge's Orders (DE 480 and DE 513) directing Defendant to produce income tax returns
Magistrate Judge
Jeffrey Epstein
Locations (2)
| Location | Context |
|---|---|
|
Jurisdiction of the court case.
|
|
|
Address of Mermelstein & Horowitz, P.A.
|
Relationships (2)
Plaintiff vs Defendant in Case 08-CV-80119
Attorney for Plaintiffs
Key Quotes (5)
"As this Court knows, Defendant Epstein is alleged to have perpetrated a plan and scheme to sexually molest dozens of underage teenage girls."Source
015.pdf
Quote #1
"Defendant cannot unilaterally by fiat claim a certain net worth for purposes of trial."Source
015.pdf
Quote #2
"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
015.pdf
Quote #3
"The tax returns are indisputably relevant in these cases, particularly as to Plaintiff’s claims for punitive damages"Source
015.pdf
Quote #4
"Defendant cannot reasonably and in good faith argue that in producing these documents to Plaintiff he will somehow be incriminating himself."Source
015.pdf
Quote #5
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