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Plaintiff's counsel

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Documents
4
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1 total relationships
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person Ms. [Redacted]
Legal representative
1
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Date Event Type Description Location Actions
N/A Meeting A 'meet and confer' between Plaintiff's counsel and Maxwell's counsel regarding the criminal inve... N/A View
N/A N/A Epstein carried out a course of action against Plaintiff's counsel. Legal proceedings View
2025-12-20 N/A Deadline for parties to hold a scheduling meeting. N/A View
2020-05-05 N/A Meet and confer between parties Unknown (likely telephonic) View
2020-04-27 N/A Meet and confer where Defendants did not send attorneys involved in drafting objections Unknown View
2020-04-27 N/A Meet-and-confer session N/A View
2020-01-17 N/A Filing of a civil complaint (Friday prior to the email). New York (implied) View
2020-01-17 N/A USANYS contacted plaintiff's counsel regarding the filing. N/A View
2019-12-20 N/A Disqualification of Plaintiff's prior counsel (Boies Schiller Flexner LLP implied due to Boies in... Southern District of New York View
2019-08-20 N/A Plaintiff filed her First Amended Complaint [DE 03] Court View
2018-02-07 N/A Plaintiff's counsel allegedly provided reporters from the Washington Post with submissions from a... Unknown View
2016-07-01 N/A Deposition of the defendant (Ghislaine Maxwell) in a civil case, which forms the basis of the per... Unknown (Deposition setting) View
2016-03-16 N/A Meet and confer between counsel. Unknown View
2010-03-10 N/A Plaintiff Jane Doe filed Motion for an Order to Show Cause and for an Order to Compel. Southern District of Florida View
2010-03-10 N/A Plaintiff filed Motion for Order to Show Cause (DE#483) Southern District of Florida View
2010-01-01 N/A Approximate date when Plaintiff's counsel contacted Bruhnel's counsel to reschedule deposition af... N/A View
2009-12-18 N/A Scheduled deposition of Igor Zinoview. Unspecified View
2009-06-12 N/A Hearing in Jane Doe, et al v. Epstein Court (Case No. 08-80119-Ci... View

014.pdf

This document is a legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party witness Jean Luc Bruhnel (likely Jean-Luc Brunel) in the civil case Jane Doe v. Jeffrey Epstein. Bruhnel opposes the plaintiff's motion to compel his deposition, arguing that he is a French citizen who has left the United States and cannot be legally compelled to return for testimony. The filing claims the plaintiff's motion is frivolous, notes that previous deposition dates were canceled by agreement, and suggests the plaintiff should use the Hague Convention to secure testimony abroad.

Legal response to motion (court filing)
2025-12-26
Analysis Source

075.pdf

A legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party Jean Luc Bruhnel (spelled 'Bruhnel' in document) in the case of Jane Doe v. Jeffrey Epstein. The filing opposes a motion to compel Bruhnel's deposition, arguing that he is a French citizen who has left the U.S. with no plans to return and cannot be compelled to appear under Federal Rules. The document alleges misrepresentation and nonfeasance by the Plaintiff's counsel and suggests using the Hague Convention to secure testimony abroad.

Legal response (response to motion for order to show cause)
2025-12-26
Analysis Source

HOUSE_OVERSIGHT_019299.jpg

This is page 3 of a legal letter from Andrew G. Celli, Jr. representing Professor Dershowitz. The letter accuses opposing counsel of selectively leaking false charges to the Washington Post while withholding exculpatory emails from a redacted witness who allegedly tried to sell a story involving 'two presidential candidates, a former president, and one of the world’s leading entrepreneurs' to the New York Post. Celli demands a stipulation to unseal the witness's emails to allow for full public disclosure.

Legal correspondence / letter
2025-11-19
Analysis Source

HOUSE_OVERSIGHT_013312.jpg

Page 9 of 15 from a legal filing in the case of Edwards vs. Epstein (Case No. 502009CA040800XXXXMBAG). The document argues that the 'litigation privilege' should not protect Epstein from claims of malicious prosecution and abuse of process because his actions were malicious, unfounded, and targeted the Plaintiff's counsel without a legitimate judicial goal. It distinguishes Epstein's actions as an individual party from legal precedents involving attorneys.

Legal document (opposition to motion for summary judgment)
2025-11-19
Analysis Source
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As Sender
13
As Recipient
7
Total
20

Discovery deficiencies

From: Plaintiff's counsel
To: Defendants' Counsel

Plaintiff's counsel met and conferred with Defendants' counsel for an hour and a half regarding discovery deficiencies.

Meet and confer
2020-04-27
Communication Source

Extension Request

From: Plaintiff's counsel
To: Defense counsel

Refusal to consent to extension: 'I cannot agree to extend your time to respond any further and cannot agree to postpone the conference.'

Communication
2019-11-12
Communication Source

Motion to Proceed Anonymously

From: Plaintiff's counsel
To: System

Filing of motion and memorandum of law

Electronic filing
2019-11-08
Communication Source

ECF # 24

From: Plaintiff's counsel
To: Court (implied)

Letter attaching a copy of an Order from Judge P. Kevin Castel.

Letter
2019-10-16
Communication Source

Meet and Confer

From: MR. PAGLIUCA
To: Plaintiff's counsel

Discussion regarding Plaintiff's allegations; Maxwell claims no knowledge of statements attributed to Mr. Pagliuca in the request.

Meeting
2016-03-21
Communication Source

Arrival notification

From: Plaintiff's counsel
To: Chambers (305) 523-5760

Plaintiff's counsel instructed to call Chambers immediately upon arrival at courthouse complex.

Call
2010-07-06
Communication Source

Rule 7.1 Certification

From: Defendant's Counsel
To: Plaintiff's counsel

Counsel communicated by email in good faith effort to resolve issues prior to filing.

Email
2010-06-14
Communication Source

Rule 7.1 Certification

From: Robert D. Critton, Jr.
To: Plaintiff's counsel

Good faith effort to resolve issues; Plaintiff's counsel stated parties already complied with requirements.

Call
2010-06-01
Communication Source

Attempt to resolve issues

From: Plaintiff's counsel
To: Defendant's Counsel

Counsel conferred regarding the relief requested but reached no agreement.

Conferral
2010-01-04
Communication Source

Rescheduling deposition

From: Plaintiff's counsel
To: Tama Beth Kudman

Discussed rescheduling deposition; Kudman informed Plaintiff's counsel that Bruhnel had left the US with no firm plan to return.

Call
2010-01-01
Communication Source

Deposition scheduling

From: Plaintiff's counsel
To: Tama Beth Kudman

Discussed rescheduling deposition; Kudman conveyed Bruhnel left US with no plan to return.

Call
2010-01-01
Communication Source

No Subject

From: Plaintiff's counsel
To: Tama Beth Kudman

Conversation regarding rescheduling deposition; Kudman conveyed Bruhnel had left US with no firm plan to return.

Call
2010-01-01
Communication Source

Rule 7.1 Certification

From: Defense Counsel (Rober...
To: Plaintiff's counsel

Defense counsel spoke with Plaintiff's counsel who has no objection to the proposed agreed order.

Certification
2009-11-20
Communication Source

Notice of IME

From: Epstein's counsel
To: Plaintiff's counsel

Notice served regarding Jane Doe No. 3's IME date and location.

Notice
2009-10-30
Communication Source

Request for enlargement of time

From: Plaintiff's counsel
To: Defendant's Counsel

Plaintiff's counsel conferred with Defendant's counsel regarding the request for enlargement of time and was advised Defendant does not oppose.

Conferral
2009-07-30
Communication Source

Request to exceed page limitation

From: Defendant's Counsel
To: Plaintiff's counsel

Pursuant to communication by telephone, Plaintiff's counsel has no objection to the request to exceed 20 pages herein.

Call
2009-05-18
Communication Source

Motion to Proceed Anonymously

From: Plaintiff's counsel
To: Defendant's Counsel

Undersigned counsel conferred with counsel for Defendant to resolve issues; Defendant opposes the motion.

Meeting/consultation
2009-04-01
Communication Source

Motion to Align Response Date

From: MICHAEL R. TEIN
To: Plaintiff's counsel

Undersigned counsel conferred with counsel for the plaintiff in a good faith effort to resolve the issues raised in this motion, but was unable to do so.

Conference
2008-08-07
Communication Source

Motion to Consolidate

From: Plaintiff's counsel
To: Defendant's Counsel

Conferred regarding the motion; Defendant's counsel advised they do not oppose the relief requested.

Meeting/conferral
-2009-08-11
Communication Source

Agreement on Motion

From: Plaintiff's counsel
To: Robert Critton (Defens...

Robert Critton advised that Plaintiff may represent to the Court that he is in agreement with the motion.

Conferral
-2010-05-13
Communication Source

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