HOUSE_OVERSIGHT_015610.jpg
1.46 MB
Extraction Summary
3
People
2
Organizations
2
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / motion (page 12)
File Size:
1.46 MB
Summary
This is page 12 of a legal filing (Bates stamped HOUSE_OVERSIGHT_015610) arguing for protective measures regarding the deposition of 'Jane Doe No. 3,' a non-party witness identified as a victim of sexual trafficking orchestrated by Jeffrey Epstein. The filing requests that the Defendant be precluded from asking questions about the victim's sexual history or other trafficking victims, prohibits the use of specific derogatory language ('prostitute,' 'liar,' 'bad mother') previously used by the Defendant in the press, and demands that the Defendant not be physically present in the same room during testimony due to the victim's fear.
People (3)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 3 | Non-party witness / Victim |
Described as a sexually trafficked minor; subject of the deposition motion; requesting protection from the Defendant.
|
| Jeffrey Epstein | Orchestrator |
Mentioned as the person who orchestrated the sexual trafficking involving Jane Doe No. 3.
|
| Defendant | Defendant |
Unnamed in text but identified as male ('his goal'); accused of using derogatory language in the press and attempting...
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Court |
Requested to provide cautionary notices and protective orders.
|
|
| House Oversight Committee |
Implied by the Bates stamp 'HOUSE_OVERSIGHT'.
|
Timeline (2 events)
Upcoming/Proposed
Deposition of Jane Doe No. 3
TBD (Requesting separate room/electronic monitoring)
Jane Doe No. 3
Defendant's Counsel
Locations (2)
| Location | Context |
|---|---|
|
Implied by case law citations (Fla. 3d DCA, Fla. 15th Cir. Ct.).
|
|
|
The document ends while proposing a specific physical location for the deposition.
|
Relationships (2)
Text refers to 'sexual trafficking orchestrated by Jeffrey Epstein' involving Jane Doe No. 3.
Defendant is attempting to depose Jane Doe No. 3; Jane Doe No. 3 fears physical proximity to Defendant.
Key Quotes (4)
"victim to foster his goal of putting her into 'jail' or of bringing a new action against Jane Doe No. 3."Source
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Quote #1
"Defendant should be precluded from questioning Jane Doe No. 3 about individuals that she was sexually trafficked to or about other victims or individuals involved in the sexual trafficking orchestrated by Jeffrey Epstein."Source
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Quote #2
"calling Jane Doe No. 3 a 'prostitute,' a 'liar,' or a 'bad mother'"Source
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Quote #3
"Non-party Jane Doe No. 3 has a valid and real basis to fear being in physical proximity of the Defendant."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,135 characters)
victim to foster his goal of putting her into “jail” or of bringing a new action against Jane Doe No. 3.
3. See Peisach v. Antuna, 539 So. 2d 544 (Fla. 3d DCA 1989); see also Citimortgage, Inc. v.
Davis, No. 50 2009 CA 030523, 2011 WL 3360318 (Fla. 15th Cir. Ct. Apr. 4, 2011). Defendant
should be precluded from asking any questions about Jane Doe No. 3’s experiences as a sexually
trafficked minor. Defendant should be precluded from questioning Jane Doe No. 3 about
individuals that she was sexually trafficked to or about other victims or individuals involved in the
sexual trafficking orchestrated by Jeffrey Epstein. Defendant should be precluded from
questioning Jane Doe No. 3 about any rapes that occurred when she was a minor child. Defendant
should be precluded from questioning Jane Doe No. 3 about anything related to her sexual activity
either as a minor or thereafter as these questions would only be intended to embarrass and harass
this non-party witness.
3. See Peisach v. Antuna, 539 So. 2d 544 (Fla. 3d DCA 1989); see also Citimortgage, Inc. v.
Davis, No. 50 2009 CA 030523, 2011 WL 3360318 (Fla. 15th Cir. Ct. Apr. 4, 2011). Defendant
should be precluded from asking any questions about Jane Doe No. 3’s experiences as a sexually
trafficked minor. Defendant should be precluded from questioning Jane Doe No. 3 about
individuals that she was sexually trafficked to or about other victims or individuals involved in the
sexual trafficking orchestrated by Jeffrey Epstein. Defendant should be precluded from
questioning Jane Doe No. 3 about any rapes that occurred when she was a minor child. Defendant
should be precluded from questioning Jane Doe No. 3 about anything related to her sexual activity
either as a minor or thereafter as these questions would only be intended to embarrass and harass
this non-party witness.
b. Language and Harassment Limitations
In addition, Jane Doe No. 3 requests that the Court provide counsel with a cautionary
notice, that counsel for Defendant may not harass the non-party victim in any way during the
deposition. With respect to the language used at the deposition, the Defendant’s counsel should be
directed by the Court to not use any of the derogatory terms the Defendant has used in the press
including calling Jane Doe No. 3 a “prostitute,” a “liar,” or a “bad mother” or any other similar
derogatory and harassing language.
notice, that counsel for Defendant may not harass the non-party victim in any way during the
deposition. With respect to the language used at the deposition, the Defendant’s counsel should be
directed by the Court to not use any of the derogatory terms the Defendant has used in the press
including calling Jane Doe No. 3 a “prostitute,” a “liar,” or a “bad mother” or any other similar
derogatory and harassing language.
c. Physical Location Limitations
Non-party Jane Doe No. 3 has a valid and real basis to fear being in physical proximity of
the Defendant. See Exhibit 8, Affidavit of Jane Doe No. 3. Accordingly, to the extent a
deposition is to go forward, we would request that the Court direct that the Defendant not be
present in the same room as non-party Jane Doe No. 3 and, instead, follow the testimony
electronically from a separate location. In addition, non-party Jane Doe No. 3 respectfully
requests that the Court hold that the physical location of the deposition should be the offices of
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the Defendant. See Exhibit 8, Affidavit of Jane Doe No. 3. Accordingly, to the extent a
deposition is to go forward, we would request that the Court direct that the Defendant not be
present in the same room as non-party Jane Doe No. 3 and, instead, follow the testimony
electronically from a separate location. In addition, non-party Jane Doe No. 3 respectfully
requests that the Court hold that the physical location of the deposition should be the offices of
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HOUSE_OVERSIGHT_015610
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