017-13.pdf
36.2 KB
Extraction Summary
14
People
2
Organizations
2
Locations
3
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing (plaintiff's protective response)
File Size:
36.2 KB
Summary
This document is a protective response filed by Plaintiff Jane Doe on May 27, 2010, in the Southern District of Florida case against Jeffrey Epstein. The plaintiff requests the court to promptly order the production of tax returns and other documents that Epstein has withheld on Fifth Amendment grounds, emphasizing that the trial date is set for July 19, 2010. The filing notes that negotiations with Epstein's counsel failed and lists numerous related cases and attorneys involved.
People (14)
| Name | Role | Context |
|---|---|---|
| Jane Doe | Plaintiff |
Filing protective response seeking document production
|
| Jeffrey Epstein | Defendant |
Accused of blocking turnover of tax returns and documents
|
| Bradley J. Edwards | Attorney |
Counsel for Plaintiff, filing attorney
|
| Paul G. Cassell | Attorney |
Pro Hac Vice Counsel for Plaintiff
|
| Jack Alan Goldberger | Attorney |
Service List Recipient
|
| Robert D. Critton | Attorney |
Service List Recipient
|
| Isidro Manual 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
|
| Richard Horace Willits | Attorney |
Service List Recipient
|
| Robert C. Josefsberg | Attorney |
Service List Recipient
|
| Adam D. Horowitz | Attorney |
Service List Recipient
|
| Stuart S. Mermelstein | Attorney |
Service List Recipient
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Court where case is filed
|
|
| Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. |
Law firm representing Plaintiff
|
Timeline (3 events)
2010-07-19
Locations (2)
| Location | Context |
|---|---|
|
Address for Bradley J. Edwards
|
|
|
Address for Paul G. Cassell
|
Relationships (2)
Filing submitted by Edwards on behalf of Doe
Plaintiff vs Defendant in Case 08-CV-80893
Key Quotes (3)
"Epstein has blocked turning over tax returns and other documents that the Government has already seen on Fifth Amendment grounds for more than ten months."Source
017-13.pdf
Quote #1
"Jane Doe’s trial date is less than two months away on July 19, 2010, and she needs the requested items soon to prepare for trial."Source
017-13.pdf
Quote #2
"Jane Doe attempted to negotiate a resolution to these issues with counsel for Epstein, but the negotiations failed."Source
017-13.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (3,714 characters)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
SOUTHERN DISTRICT OF FLORIDA
JANE DOE, CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON
Plaintiff,
Vs.
JEFFREY EPSTEIN, et al.
Defendant.
_________________________________/
_________________________________/
Related Cases:
08-80119, 08-80232, 08-80380, 08-80381,
08-80994, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
__________________________________/
08-80119, 08-80232, 08-80380, 08-80381,
08-80994, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
__________________________________/
PLAINTIFF JANE DOE’S PROTECTIVE RESPONSE TO DEFENDANT’S MOTION
FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL
FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL
Plaintiff, Jane Doe, hereby files this protective response to Defendant’s
Consolidated Rule 4 Review and Appeal of Portions of the Magistrate’s Orders Dated
February 4, 2010 (DE 462), (DE 480) and April 1, 2010 (DE 513), with Incorporated
Objections and Memorandum of Law (doc. #454).
Consolidated Rule 4 Review and Appeal of Portions of the Magistrate’s Orders Dated
February 4, 2010 (DE 462), (DE 480) and April 1, 2010 (DE 513), with Incorporated
Objections and Memorandum of Law (doc. #454).
Jane Doe had understood that she had fully briefed the issues raised by the
defendant’s pleading when on March10, 2010, she filed her response in Opposition to
Defendant’s Motion for Reconsideration (doc. #485). It appears, however, the
defendant Epstein may view his “consolidated” appeal as requiring some sort of new
response from Jane Doe. If so, Jane Doe wishes to make clear that she continues to
defendant’s pleading when on March10, 2010, she filed her response in Opposition to
Defendant’s Motion for Reconsideration (doc. #485). It appears, however, the
defendant Epstein may view his “consolidated” appeal as requiring some sort of new
response from Jane Doe. If so, Jane Doe wishes to make clear that she continues to
CASE NO: 08-CV-80119-MARRA/JOHNSON
assert the responses she raised in her earlier response and hereby files this protective
response incorporating by reference all of her earlier arguments.
response incorporating by reference all of her earlier arguments.
Jane Doe would also note she filed her request for these documents on July 20,
2009. Through a seemingly endless series of motions, all of which have been rejected
on the merits, Epstein has blocked turning over tax returns and other documents that
the Government has already seen on Fifth Amendment grounds for more than ten
months. Jane Doe’s trial date is less than two months away on July 19, 2010, and she
needs the requested items soon to prepare for trial.
2009. Through a seemingly endless series of motions, all of which have been rejected
on the merits, Epstein has blocked turning over tax returns and other documents that
the Government has already seen on Fifth Amendment grounds for more than ten
months. Jane Doe’s trial date is less than two months away on July 19, 2010, and she
needs the requested items soon to prepare for trial.
Jane Doe attempted to negotiate a resolution to these issues with counsel for
Epstein, but the negotiations failed.
Epstein, but the negotiations failed.
Jane Doe therefore respectfully requests that the Court promptly order
production of these documents to her.
production of these documents to her.
DATED: May 27, 2010
Respectfully Submitted,
s/ Bradley J. Edwards
Bradley J. Edwards
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Telephone (954) 524-2820
Facsimile (954) 524-2822
Florida Bar No.: 542075
E-mail: brad@pathtojustice.com
Bradley J. Edwards
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Telephone (954) 524-2820
Facsimile (954) 524-2822
Florida Bar No.: 542075
E-mail: brad@pathtojustice.com
and
CASE NO: 08-CV-80119-MARRA/JOHNSON
Paul G. Cassell
Pro Hac Vice
332 S. 1400 E.
Salt Lake City, UT 84112
Telephone: 801-585-5202
Facsimile: 801-585-6833
E-Mail: cassellp@law.utah.edu
Pro Hac Vice
332 S. 1400 E.
Salt Lake City, UT 84112
Telephone: 801-585-5202
Facsimile: 801-585-6833
E-Mail: cassellp@law.utah.edu
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on May 27, 2010 I electronically filed the foregoing
document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
document is being served this day on all parties on the attached Service List in the
manner specified, either via transmission of Notices of Electronic Filing generated by
CM/ECF or in some other authorized manner for those parties who are not authorized to
receive electronically filed Notices of Electronic Filing.
document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
document is being served this day on all parties on the attached Service List in the
manner specified, either via transmission of Notices of Electronic Filing generated by
CM/ECF or in some other authorized manner for those parties who are not authorized to
receive electronically filed Notices of Electronic Filing.
s/ Bradley J. Edwards
Bradley J. Edwards
Bradley J. Edwards
SERVICE LIST
Jane Doe v. Jeffrey Epstein
United States District Court, Southern District of Florida
United States District Court, Southern District of Florida
Jack Alan Goldberger, Esq.
Jgoldberger@agwpa.com
Jgoldberger@agwpa.com
Robert D. Critton, Esq.
rcritton@bclclaw.com
rcritton@bclclaw.com
Isidro Manual Garcia
isidrogarcia@bellsouth.net
isidrogarcia@bellsouth.net
Jack Patrick Hill
iph@searcylaw.com
iph@searcylaw.com
Katherine Warthen Ezell
KEzell@podhurst.com
KEzell@podhurst.com
Michael James Pike
MPike@bclclaw.com
MPike@bclclaw.com
Paul G. Cassell
cassellp@law.utah.edu
cassellp@law.utah.edu
Richard Horace Willits
lawyerswillits@aol.com
lawyerswillits@aol.com
Robert C. Josefsberg
rjosefsberg@podhurst.com
rjosefsberg@podhurst.com
Adam D. Horowitz
ahorowitz@sexabuseattorney.com
ahorowitz@sexabuseattorney.com
Stuart S. Mermelstein
ssm@sexabuseattorney.com
ssm@sexabuseattorney.com
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