DOJ-OGR-00031549.jpg
671 KB
Extraction Summary
4
People
2
Organizations
2
Locations
4
Events
5
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
671 KB
Summary
This legal document is a response filed by defendant Jeffrey Epstein's attorney to a 'Motion for Protective Order' submitted on behalf of a state's witness, Jane Doe No. 1. Epstein's counsel refutes the claim that serving a deposition subpoena constituted 'continuous and systematic harassment' and denies allegations of misconduct by any agent. The response also highlights a legal conflict between two attorneys, Theodore Leopold and Jeffrey Herman, who are both claiming to represent Jane Doe No. 1 in a separate civil case.
People (4)
| Name | Role | Context |
|---|---|---|
| JEFFREY EPSTEIN | Defendant |
Named as the Defendant in case no. 2006CF009454A, filing this response to a motion.
|
| Jane Doe No. 1 | State's witness |
The subject of a Motion for Protective Order, whom the Defendant sought to depose.
|
| Theodore Leopold | Attorney |
Filed the Motion for Protective Order, purporting to represent Jane Doe No. 1.
|
| Jeffrey Herman | Attorney |
Also claims to represent the interests of Jane Doe No. 1 in a separate civil proceeding.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT | government agency |
The court where the case STATE OF FLORIDA vs. JEFFREY EPSTEIN is being heard.
|
| STATE OF FLORIDA | government agency |
The plaintiff in the case against Jeffrey Epstein.
|
Timeline (4 events)
2017-07-26
Jeffrey Epstein's attorney filed a 'RESPONSE TO MOTION FOR PROTECTIVE ORDER'.
CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, PALM BEACH COUNTY, FLORIDA
An attempt was made to serve a subpoena for deposition on State's witness Jane Doe No. 1 and her parents.
Jane Doe No. 1
process server
Attorney Theodore Leopold filed a 'Motion For Protective Order' on behalf of Jane Doe No. 1.
CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, PALM BEACH COUNTY, FLORIDA
Two law firms are litigating in a separate civil proceeding over who represents the interests of Jane Doe No. 1.
Locations (2)
| Location | Context |
|---|---|
|
The location of the Fifteenth Judicial Circuit Court where the case is filed.
|
|
|
The state in which the legal proceedings are taking place.
|
Relationships (5)
Jeffrey Epstein is the Defendant in a case brought by the State of Florida (Case No. 2006CF009454A).
Jane Doe No. 1 is a witness for the State in the case against Jeffrey Epstein. Epstein's counsel is responding to a motion filed on her behalf.
Theodore Leopold is an attorney who filed a Motion for Protective Order purporting to represent Jane Doe No. 1.
Jeffrey Herman is an attorney who also claims to represent the interests of Jane Doe No. 1.
The two attorneys, representing different law firms, are currently litigating in a separate civil proceeding to determine who represents Jane Doe No. 1.
Key Quotes (3)
"continuous and systematic harassment"Source
— counsel for Jane Doe No. 1
(Used in the Motion for Protective Order to describe the serving of a deposition subpoena on the witness and her parents.)
DOJ-OGR-00031549.jpg
Quote #1
"himself as an attorney who needed to contract (sp) her"Source
— Motion for Protective Order (allegation)
(An allegation from paragraph 8 of the Motion for Protective Order, which Defendant's counsel denies knowledge of.)
DOJ-OGR-00031549.jpg
Quote #2
"on information and belief"Source
— Motion for Protective Order (allegation)
(A legal term used in the allegation that an agent of the Defendant misrepresented himself at the witness's place of employment.)
DOJ-OGR-00031549.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,695 characters)
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 2006CF009454A
STATE OF FLORIDA
vs.
JEFFREY EPSTEIN,
Defendant.
RESPONSE TO MOTION FOR PROTECTIVE ORDER
COMES NOW the Defendant, JEFFREY EPSTEIN, by and through his attorney and files his response to the Motion For Protective Order filed by counsel for State's witness Jane Doe No. 1.
1. In summary fashion, counsel for Jane Doe No. 1 complains that serving a witness for deposition by the use of a process server and the service of the witness' parents for the deposition to ensure service, amounts to “continuous and systematic harassment”. ¹
2. The Motion For Protective Order was filed by one of the attorneys purporting to represent Jane Doe No. 1 in a separate civil proceeding.² While disagreeing with the
¹ Undersigned counsel for the Defendant responds only to the issues in the Motion for Protective Order concerning service of a subpoena for deposition and the date for that deposition. Defendant and undersigned counsel have no knowledge of any agent of the Defendant going to the witness’ place of employment representing “himself as an attorney who needed to contract (sp) her” as alleged “on information and belief” in paragraph 8 of the Motion for Protective Order.
² The Motion for Protective Order was filed by attorney Theodore Leopold. While he purports to represent Jane Doe No.1, attorney Jeffrey Herman also claims to represent the interests of Jane Doe No. 1. In that separate civil proceeding, the two law firms are presently litigating who represents the interests of Jane Doe No. 1.
07/26/17
Page 28
Public Records Request No.: 17-295
DOJ-OGR-00031549
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