DOJ-OGR-00030546.jpg
463 KB
Extraction Summary
5
People
0
Organizations
1
Locations
2
Events
6
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
463 KB
Summary
This document is page 6 of a legal complaint filed on behalf of Plaintiff Jane Doe against defendants Jeffrey Epstein, Haley Robson, and Sarah Kellen. It concludes a count on civil conspiracy and introduces 'COUNT III: Intentional Infliction of Emotional Distress against Defendant Epstein,' alleging his conduct was outrageous and caused severe trauma to Jane Doe and her mother. The plaintiff demands judgment for compensatory and punitive damages, costs, and attorney's fees against all three defendants.
People (5)
| Name | Role | Context |
|---|---|---|
| Jane Doe | Plaintiff |
Alleged victim who has suffered and will continue to suffer severe and permanent traumatic injuries. She is the plain...
|
| Jane Doe's Mother | Parent and natural guardian |
Represents her daughter, Plaintiff Jane Doe, in the lawsuit. Also individually demands judgment for emotional distres...
|
| Jeffrey Epstein | Defendant |
One of the defendants against whom judgment is demanded. Specifically accused in COUNT III of Intentional Infliction ...
|
| Haley Robson | Defendant |
One of the defendants against whom judgment is demanded for compensatory damages, costs, and attorney's fees.
|
| Sarah Kellen | Defendant |
One of the defendants against whom judgment is demanded for compensatory damages, costs, and attorney's fees.
|
Timeline (2 events)
2017-07-26
Filing of a complaint where Plaintiff Jane Doe demands judgment against defendants for damages resulting from a civil conspiracy and intentional infliction of emotional distress.
Allegation of Intentional Infliction of Emotional Distress by Defendant Epstein against Plaintiff Jane Doe and her mother.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the context of seeking punitive damages pursuant to Florida Law.
|
Relationships (6)
The document states Jane Doe's Mother is her 'parent and natural guardian' in the lawsuit.
Jane Doe is the Plaintiff suing Jeffrey Epstein, who is a Defendant, for civil conspiracy and intentional infliction of emotional distress.
Jane Doe is the Plaintiff suing Haley Robson, who is a Defendant.
Jane Doe is the Plaintiff suing Sarah Kellen, who is a Defendant.
Both are listed as Defendants in the same lawsuit brought by Plaintiff Jane Doe.
Both are listed as Defendants in the same lawsuit brought by Plaintiff Jane Doe.
Full Extracted Text
Complete text extracted from the document (1,803 characters)
24. As a direct and proximate result of Defendants' civil conspiracy, Jane Doe has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages.
WHEREFORE, Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, demands judgment against Defendants Jeffrey Epstein, Haley Robson, and Sarah Kellen for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complaint to add a claim for punitive damages pursuant to Florida Law.
COUNT III
Intentional Infliction of Emotional Distress against Defendant Epstein
Intentional Infliction of Emotional Distress against Defendant Epstein
25. Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, repeats and realleges paragraphs 1 through 16 above.
26. Epstein's conduct was intentional or reckless.
27. Epstein's conduct was outrageous, going beyond all bounds of decency.
28. Epstein's conduct caused severe emotional distress not only to Jane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe and her mother.
29. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe will continue to suffer severe mental anguish and pain.
WHEREFORE, Plaintiff Jane Doe, by and through her Mother as parent and natural guardian, demands, and Jane Doe's Mother, individually, demand judgment against Defendants Jeffrey Epstein, Haley Robson, and Sarah Kellen for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff
Page 6 of 9
07/26/17
Page 79 of 131
Public Records Request No.: 17-295
DOJ-OGR-00030546
Page 79 of 131
Public Records Request No.: 17-295
DOJ-OGR-00030546
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