DOJ-OGR-00030437.jpg

598 KB

Extraction Summary

4
People
2
Organizations
0
Locations
1
Events
5
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 598 KB
Summary

This document is page 5 of a legal complaint against Jeffrey Epstein, dated July 26, 2017. It outlines two counts: Count II, 'Intentional Infliction of Emotional Distress,' brought by plaintiff Jane Doe and her parents (Father and Stepmother), and Count III, 'Loss of Parental Consortium,' brought by Jane Doe's Father. The plaintiffs allege Epstein's conduct was intentional and outrageous, causing severe emotional distress and damages for which they seek compensatory and punitive relief.

People (4)

Name Role Context
Jane Doe Plaintiff
Named as a plaintiff in a lawsuit against Jeffrey Epstein, represented by her father.
Jane Doe's Father Plaintiff / Parent and natural guardian
Named as a plaintiff, both individually and as the parent and natural guardian of Jane Doe.
Jane Doe's Stepmother Plaintiff
Named as a plaintiff in the lawsuit.
Jeffrey Epstein Defendant
Named as the defendant against whom judgment is demanded for intentional infliction of emotional distress and causing...

Organizations (2)

Name Type Context
HERMAN & MERMELSTEIN, P. A. Law firm
Appears at the bottom of the document, likely the law firm representing the plaintiffs.
Court Government agency
Mentioned in the 'WHEREFORE' clause as the body from which relief is sought.

Timeline (1 events)

2017-07-26
A legal complaint was filed against Jeffrey Epstein by Jane Doe and her parents, alleging Intentional Infliction of Emotional Distress and Loss of Parental Consortium.

Relationships (5)

Jane Doe's Father Family Jane Doe
The document states Jane Doe's Father is her 'parent and natural guardian'.
The document explicitly names 'Jane Doe's Stepmother' as a plaintiff.
Jane Doe Legal Adversaries Jeffrey Epstein
Jane Doe is a plaintiff demanding judgment against Defendant Jeffrey Epstein.
Jane Doe's Father Legal Adversaries Jeffrey Epstein
Jane Doe's Father is a plaintiff demanding judgment against Defendant Jeffrey Epstein.
Jane Doe's Stepmother Legal Adversaries Jeffrey Epstein
Jane Doe's Stepmother is a plaintiff demanding judgment against Defendant Jeffrey Epstein.

Full Extracted Text

Complete text extracted from the document (1,628 characters)

COUNT II
Intentional Infliction of Emotional Distress
21. Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother, individually, repeat and reallege paragraphs 1 through 16 above.
22. Epstein's conduct was intentional or reckless.
23. Epstein's conduct was outrageous, going beyond all bounds of decency.
24. Epstein's conduct caused severe emotional distress not only to Jane Doe, but also to her parents, Jane Doe's Father and Jane Doe's Stepmother. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe's parents.
25. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe mental anguish and pain.
WHEREFORE, Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother demand judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper.
COUNT III
Loss of Parental Consortium
26. Plaintiff Jane Doe's Father repeats and realleges paragraphs 1 through 16 above.
27. Epstein's tortious conduct is the direct and proximate cause of damages to Jane Doe's Father, consisting of parental loss of comfort, companionship and society and healthcare costs
HERMAN & MERMELSTEIN, P. A.
- 5 -
Page 84 of 114
www.hermanlaw.com
07/26/17
Public Records Request No.: 17-295
DOJ-OGR-00030437

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