HOUSE_OVERSIGHT_014103.jpg
1.74 MB
Extraction Summary
7
People
3
Organizations
2
Locations
4
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (response to request for production of documents)
File Size:
1.74 MB
Summary
This document is a legal response filed on March 24, 2015, in the Southern District of Florida, containing a Defendant's responses to discovery requests regarding Jeffrey Epstein. The requests seek documents proving the presence of the Defendant's nephew and Epstein's legal team on Epstein's private plane, as well as flight manifests linking the Defendant to Epstein. The Defendant objects to requests regarding the legal team by citing allegations from 'Jane Doe #3' regarding her abuse between 1999 and 2002, arguing that post-2002 travel records are irrelevant to the specific action.
People (7)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Subject |
Owner of private plane; alleged to have kept Jane Doe #3 as a sex slave.
|
| Alan M. Dershowitz | Declarant |
Author of a sworn declaration referenced in requests 6, 7, and 9.
|
| Defendant | Respondent |
The individual responding to the legal requests (unnamed in text, but referred to as 'he' and 'Defendant').
|
| Jane Doe #3 | Alleged Victim |
alleged she was kept as Epstein's sex slave (1999-2002) and moved to Australia.
|
| Jane Doe #4 | Plaintiff |
Party to the Joinder Motion.
|
| Jane Doe #1 | Plaintiff |
Lead plaintiff in the referenced Federal Action.
|
| Nephew of Defendant | Subject of Inquiry |
Request 6 asks for proof of his presence on Epstein's plane.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States |
Defendant in the referenced civil action (Case No. 08-80736).
|
|
| S.D. Fla. |
Southern District of Florida (Court jurisdiction).
|
|
| House Oversight |
Congressional committee (indicated by footer stamp).
|
Timeline (4 events)
1999-2002
Period Jane Doe #3 alleges she was kept as a sex slave by Jeffrey Epstein.
Unknown
Post-2002
Plane travel by members of Mr. Epstein's legal team referenced in Dershowitz declaration.
Epstein's private plane
Epstein's legal team
Locations (2)
| Location | Context |
|---|---|
|
Location where Jane Doe #3 allegedly moved in 2002.
|
|
|
Location of the Federal Court action.
|
Relationships (2)
Text states she alleges she was kept as his sex slave.
Request 6 refers to 'your nephew'.
Key Quotes (4)
"kept as [Jeffrey Epstein's] sex slave from about 1999 through 2002."Source
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Quote #1
"she 'escape[d]' from Mr. Epstein and moved to Australia in 2002."Source
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Quote #2
"Copies of any and all documents evidencing the presence of your nephew on Jeffrey Epstein's private plane"Source
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Quote #3
"Defendant responds that he has no responsive, non-privileged documents."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,973 characters)
Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 20 of 34
6. Copies of any and all documents evidencing the presence of your nephew on Jeffrey Epstein's private plane, as described in paragraph 5 of the sworn Declaration of Alan M. Dershowitz.
RESPONSE:
Subject to and without waiving the General Objections, Defendant responds that he will produce all responsive, non-privileged documents currently in his possession, custody or control.
7. Copies of any and all documents evidencing the presence of "members of Mr. Epstein's legal team", as described in paragraph 5 of the sworn Declaration of Alan M. Dershowitz.
RESPONSE:
Defendant objects to this Document Request as overly broad because Jane Doe #3 alleges in the filing titled "Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 For Joinder In Action" (Doc. No. 279) (the "Joinder Motion") in the civil action captioned Jane Doe #1, et al. v. United States, Case No. 08-80736 (S.D. Fla.) (the "Federal Action") that she was "kept as [Jeffrey Epstein's] sex slave from about 1999 through 2002." Jane Doe #3 further alleges in the Joinder Motion that she "escape[d]" from Mr. Epstein and moved to Australia in 2002. Paragraph 5 of the sworn Declaration of Alan M. Dershowitz refers to plane travel by members of Mr. Epstein's legal team after 2002 and therefore Defendant further objects because this Document Request does not seek documents relevant to this action or documents reasonably calculated to lead to the discovery of admissible evidence.
8. Copies of any and all flight manifests reflecting your presence or the presence of any member of your family on any aircraft on which Jeffrey Epstein was also a passenger during the same flight.
RESPONSE:
Defendant responds that he has no responsive, non-privileged documents.
9. Copies of any and all "absolute proof" as described in paragraph 8 of the sworn Declaration of Alan M. Dershowitz.
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