HOUSE_OVERSIGHT_014109.jpg
1.94 MB
Extraction Summary
3
People
2
Organizations
1
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal filing (defendant's response to document requests)
File Size:
1.94 MB
Summary
This legal document is a response by a Defendant to document requests in the case *Jane Doe No. 1 v. United States* (Case 9:08-cv-80736). The Defendant objects to providing travel records from 1998-2007, limiting the scope to 1999-2002 based on Jane Doe #3's allegations that she was Epstein's 'sex slave' during that period before escaping to Australia. The Defendant also objects to producing communications with Jeffrey Epstein from late 2014 to 2015 regarding the sexual misconduct allegations, claiming attorney-client privilege and lack of relevance.
People (3)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Subject of allegations/Owner of transport |
Owned the aircraft/boats in question; accused of keeping Jane Doe #3 as a sex slave.
|
| Jane Doe #3 | Plaintiff/Accuser |
Alleges she was Epstein's sex slave (1999-2002) and alleges misconduct by the Defendant on Epstein's plane.
|
| Defendant | Respondent |
Objecting to document requests; denies allegations of misconduct on Epstein's plane. (Likely Alan Dershowitz given th...
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| FLSD |
Florida Southern District Court (indicated in header).
|
|
| House Oversight Committee |
Indicated by the bates stamp 'HOUSE_OVERSIGHT'.
|
Timeline (2 events)
1999-2002
Locations (1)
| Location | Context |
|---|---|
|
Location where Jane Doe #3 moved to in 2002 after 'escaping' Epstein.
|
Relationships (3)
Allegation of being kept as a 'sex slave'.
Request seeks communications between them regarding the allegations; Defendant asserts attorney-client privilege regarding these communications.
Defendant refutes Jane Doe #3's allegations of misconduct.
Key Quotes (4)
"she was 'kept as [Jeffrey Epstein’s] sex slave from about 1999 through 2002.'"Source
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Quote #1
"Jane Doe #3 further alleges that she 'escape[d]' from Mr. Epstein and moved to Australia in 2002."Source
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Quote #2
"Defendant refutes and asserts are false."Source
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Quote #3
"such documents are not relevant to the subject matter of this action and would be attorney-client privileged communications in any event."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,232 characters)
Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 26 of
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22. Copies of any and all records for the period 1998-2007 reflecting or relating to travel by
you and/or any member of your family on any aircraft, boat, helicopter, or other means of
transport owned, controlled, or under the direction of Jeffrey Epstein and/or any business entity
with which Jeffrey Epstein was affiliated at the time of travel.
you and/or any member of your family on any aircraft, boat, helicopter, or other means of
transport owned, controlled, or under the direction of Jeffrey Epstein and/or any business entity
with which Jeffrey Epstein was affiliated at the time of travel.
RESPONSE:
Defendant objects to this Document Request as overly broad because Jane Doe #3 alleges in the
Joinder Motion that she was “kept as [Jeffrey Epstein’s] sex slave from about 1999 through
2002.” Jane Doe #3 further alleges that she “escape[d]” from Mr. Epstein and moved to
Australia in 2002. Therefore Defendant objects to this Document Request to the extent that it
purports to seek documents relating to any time before 1999 or after 2002. Defendant further
objects to this Document Request as overly broad and premature because Jane Doe #3 has not
specified the dates on which she alleges Defendant engaged in misconduct on Mr. Epstein’s
plane, which are the sole relevant allegations by Jane Doe #3 or her counsel concerning travel on
Mr. Epstein’s plane that Defendant refutes and asserts are false. 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 relating to any occasions that may be
specifically identified by Jane Doe #3 on which she contends that Defendant travelled on Jeffrey
Epstein’s plane between 1999 and 2002.
Joinder Motion that she was “kept as [Jeffrey Epstein’s] sex slave from about 1999 through
2002.” Jane Doe #3 further alleges that she “escape[d]” from Mr. Epstein and moved to
Australia in 2002. Therefore Defendant objects to this Document Request to the extent that it
purports to seek documents relating to any time before 1999 or after 2002. Defendant further
objects to this Document Request as overly broad and premature because Jane Doe #3 has not
specified the dates on which she alleges Defendant engaged in misconduct on Mr. Epstein’s
plane, which are the sole relevant allegations by Jane Doe #3 or her counsel concerning travel on
Mr. Epstein’s plane that Defendant refutes and asserts are false. 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 relating to any occasions that may be
specifically identified by Jane Doe #3 on which she contends that Defendant travelled on Jeffrey
Epstein’s plane between 1999 and 2002.
23. Copies of any and all records, including emails and text messages, between you and
Jeffrey Epstein between December 29, 2014 and today, regarding allegations made by Jane Doe
#3 of sexual misconduct by either of you.
Jeffrey Epstein between December 29, 2014 and today, regarding allegations made by Jane Doe
#3 of sexual misconduct by either of you.
RESPONSE:
Defendant objects to this Document Request to the extent that it seeks documents regarding
allegations made by Jane Doe #3 of sexual misconduct by Jeffrey Epstein because such
documents are not relevant to the subject matter of this action and would be attorney-client
privileged communications in any event. Subject to and without waiving the foregoing specific
allegations made by Jane Doe #3 of sexual misconduct by Jeffrey Epstein because such
documents are not relevant to the subject matter of this action and would be attorney-client
privileged communications in any event. Subject to and without waiving the foregoing specific
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HOUSE_OVERSIGHT_014109
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