plaintiff
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Jeffrey Epstein
|
Legal representative |
7
|
2 | |
|
person
Jeffrey Epstein
|
Abuser victim |
6
|
2 | |
|
person
GHISLAINE MAXWELL
|
Legal representative |
6
|
2 | |
|
person
Dorothy [REDACTED]
|
Family |
6
|
2 | |
|
person
Robert Glassman, Esq.
|
Professional |
5
|
1 | |
|
person
Jeffrey Epstein
|
Professional |
5
|
1 | |
|
person
MR. EPSTEIN
|
Legal representative |
5
|
1 | |
|
person
client (defendant)
|
Legal representative |
5
|
1 | |
|
person
Tyler McDonald
|
Legal representative |
5
|
1 | |
|
person
MC2
|
Owner affiliate |
5
|
1 | |
|
person
defendant
|
Legal representative |
5
|
1 | |
|
person
ALAN DERSHOWITZ
|
Alleged abuser victim |
5
|
1 | |
|
person
Jeffrey Epstein
|
Client |
5
|
1 | |
|
person
Shawn [REDACTED]
|
Business associate |
5
|
1 | |
|
person
[REDACTED Friend]
|
Friend |
5
|
1 | |
|
person
Shawn [REDACTED]
|
Friend |
5
|
1 | |
|
person
lawyers
|
Client |
5
|
1 | |
|
person
SARAH KELLEN
|
Acquaintance |
5
|
1 | |
|
person
SARAH KELLEN
|
Legal representative |
5
|
1 | |
|
person
MAXWELL
|
Adversarial |
5
|
1 | |
|
person
Plaintiff's brother
|
Family |
5
|
1 | |
|
person
Robert S. Glassman
|
Client |
5
|
1 | |
|
person
Jeffrey Epstein
|
Alleged abuser victim |
5
|
1 | |
|
person
David Boies
|
Client |
2
|
2 | |
|
person
Epstein
|
Defendant plaintiff |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | N/A | Sexual abuse of Plaintiff by JEFFREY EPSTEIN, aided by SARAH KELLEN, while Plaintiff was a minor. | Palm Beach mansion of JEFFR... | View |
| N/A | N/A | Sessions with photographers | Unknown | View |
| N/A | N/A | Taking of photographs of Plaintiff as a minor without her knowledge | Unknown | View |
| N/A | N/A | SARAH KELLEN arranging for Plaintiff to come to Epstein's mansion for 'massages'. | Palm Beach mansion of JEFFR... | View |
| N/A | N/A | Plaintiff suffering mental anguish, pain, suffering, psychic trauma, and loss of enjoyment of lif... | N/A | View |
| N/A | N/A | SARAH KELLEN arranging for gifts to be sent to Plaintiff. | N/A | View |
| N/A | N/A | SARAH KELLEN paying Plaintiff for 'sessions' with JEFFREY EPSTEIN. | N/A | View |
| N/A | Exhibit indexing | The document lists Plaintiff Exhibits and the page number on which they were received or referenc... | N/A | View |
| N/A | N/A | Publication of false statements | Internet / Domain hosting s... | View |
| N/A | N/A | SARAH KELLEN taking nude photographs of Plaintiff at JEFFREY EPSTEIN's request and paying Plainti... | N/A | View |
| N/A | N/A | Plaintiff being brought to and escorted within Epstein's mansion for 'massages'. | Palm Beach mansion of JEFFR... | View |
| 2023-07-20 | N/A | Deadline for Answering Papers on Motion to Dismiss (Handwritten) | SDNY Court | View |
| 2021-07-23 | N/A | Deadline for Plaintiff to file a motion if she wishes to proceed anonymously | Court | View |
| 2020-12-01 | N/A | Joint Status Report submitted to the Court. | New York | View |
| 2020-10-05 | N/A | Plaintiff accepted offer of compensation. | Unknown | View |
| 2020-09-24 | N/A | Filing of Document 60 in Case 1:20-cv-00484-DGC | Court | View |
| 2020-09-04 | N/A | Court Order (ECF No. 15) | Court | View |
| 2020-08-27 | Legal filing | The Plaintiff submitted a letter vigorously opposing the requested stay. | Court | View |
| 2020-08-14 | N/A | Deadline for parties to submit a joint status report | New York, New York | View |
| 2020-07-13 | N/A | Joint Stipulation and Order Staying Action (ECF No. 13) | United States Courthouse | View |
| 2020-06-26 | N/A | Plaintiff submitted a claim to the Compensation Program. | Unknown | View |
| 2020-04-13 | N/A | Deadline for parties to confer and stipulate protocol for document exchange. | N/A | View |
| 2020-03-27 | N/A | Deadline for motions to amend pleadings or join additional parties. | N/A | View |
| 2020-03-20 | N/A | Proposed deadline for Plaintiff's opposition papers | Court Filing | View |
| 2020-02-07 | N/A | Deadline for initial disclosures pursuant to Rule 26(a)(1) | N/A | View |
EFTA00016285.pdf
This document is an email dated August 28, 2020, sent by an Assistant United States Attorney for the Southern District of New York. The email transmits an attachment titled '2020.08.27_Letter.pdf', described as the plaintiff's opposition to a stay motion. The identities of the sender and recipients are redacted.
DOJ-OGR-00030275.tif
This document, a court filing from September 17, 2009, details the events surrounding an attempted deposition of Epstein that was ultimately cancelled. Epstein's attorneys initially decided he would not attend, but he later attempted to leave the building and watch via video feed, only to encounter the Plaintiff at the exit, leading to the deposition's cancellation due to the Plaintiff's distress.
DOJ-OGR-00015189.tif
This document is a legal pleading detailing accusations against Sarah Kellen for aiding and abetting Jeffrey Epstein's sexual abuse of a minor Plaintiff. It describes Kellen's actions including arranging for the Plaintiff to provide 'massages' to Epstein, escorting her, paying her, arranging gifts, and taking nude photographs of the Plaintiff at Epstein's request. The Plaintiff seeks damages in excess of fifteen thousand dollars and demands a jury trial for the severe mental and emotional trauma suffered.
DOJ-OGR-00001056.jpg
This document is page 115 of a court transcript from April 1, 2021, involving a defense attorney arguing before a judge regarding bail conditions for a female client (implied to be Ghislaine Maxwell). The attorney rebuts the government's claim that the client is a flight risk or 'hiding out,' arguing instead that she has been actively litigating civil cases since 2015 and denying impropriety regarding Mr. Epstein. The attorney also notes that a plaintiff seeking millions of dollars had spoken earlier in the proceeding.
DOJ-OGR-00015263.jpg
This document is page 16 of a Plaintiff's response to interrogatories in a civil case against the Estate of Jeffrey Epstein (represented by executors Indyke and Kahn), dated June 3, 2020. The text alleges that Jeffrey Epstein took photographs of the Plaintiff as a minor without her knowledge, and claims these photos are currently held by the federal government. It is signed by attorney Robert S. Glassman of Panish Shea & Boyle LLP.
DOJ-OGR-00015198.jpg
This is page 17 of a legal document titled 'Plaintiff's Answers to Defendant's First Interrogatories' from a case involving a plaintiff versus 'Epstein, et al.'. In response to Interrogatory #20, which asks for the identification of any males besides Mr. Epstein who committed lewd acts against the plaintiff since age 10, the plaintiff's sworn answer is 'None'. The document is marked as subject to a protective order.
DOJ-OGR-00015192.jpg
This document is page 3 of a 'First Amended Complaint' in a legal case against Jeffrey Epstein and others. It alleges that the plaintiff was first brought to Jeffrey Epstein's mansion in late May or early June of 2002, at which time she was fifteen years old and in middle school.
DOJ-OGR-00002356(1).jpg
This document, a legal filing from February 2021, discusses the handling of confidential material under a Protective Order and details events surrounding Maxwell's April and July 2016 depositions. It notes Maxwell's agreement to testify without invoking self-incrimination privilege and Giuffre's subsequent motion to compel further answers. A footnote also highlights concerns about the misuse and leaking of confidential information by the plaintiff and her lawyers to the media, other claimants, and the government.
DOJ-OGR-00001929.jpg
This document is page 52 of a court transcript from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on December 10, 2020. The defense attorney is arguing for the client's release on strict conditions, refuting the government's claim that the client is a flight risk or has been 'hiding out.' The attorney highlights that the client has been actively litigating civil cases since 2015 and denying impropriety regarding Jeffrey Epstein.
DOJ-OGR-00019456.jpg
This document is page 12 of a court order filed on September 14, 2020. The Court grants Ghislaine Maxwell's motion to stay the civil action against her in its entirety until her criminal prosecution is complete. The Judge reasons that a partial stay would prejudice the Co-Executors (of the Epstein Estate) by forcing them into duplicative discovery without the ability to depose Maxwell, who is a central figure.
DOJ-OGR-00019453.jpg
This document is page 9 of a court order filed on September 14, 2020, granting a stay in a civil case against Ghislaine Maxwell. The court rules that proceeding with civil discovery would prejudice Maxwell due to her concurrent criminal prosecution (raising Fifth Amendment issues) and the restrictive detention conditions at the MDC during the COVID-19 pandemic, which hinder her ability to consult with counsel.
DOJ-OGR-00019451.jpg
This document is page 7 of a court order or legal filing (Case 1:20-cv-00484) dated September 24, 2020. It discusses the motion to stay civil proceedings against Ghislaine Maxwell due to the parallel criminal indictment. The text highlights the substantial overlap between the civil and criminal allegations, specifically noting accusations of grooming victims and facilitating Jeffrey Epstein's abuse.
DOJ-OGR-00019446.jpg
This legal document, filed on September 14, 2020, outlines the arguments surrounding a motion for a stay in a civil case involving a defendant named Maxwell. Maxwell requested the stay pending her criminal case, a motion supported by the Co-Executors who argued against a partial stay. The Plaintiff vigorously opposed the motion, accusing Maxwell of attempting to gain an unfair discovery advantage.
DOJ-OGR-00019319.jpg
This document is the third page of a legal letter from attorney David Boies to Judge Debra C. Freeman, dated May 18, 2020, regarding a civil case against Ghislaine Maxwell. Boies argues that the court should deny Maxwell's motion to stay discovery and her request for a pre-motion conference, citing Judge Schofield's previous comments that Maxwell's motion to dismiss lacks merit. The letter also asserts that the existence of the Epstein Estate's Victim Compensation Fund (in the Virgin Islands probate court) is not a valid reason to stay the current action without the Plaintiff's consent.
DOJ-OGR-00003080.jpg
This legal document is a page from a court filing, dated April 16, 2021, concerning a defendant's motion to dismiss two counts of perjury. The charges stem from depositions in April and July 2016, where the defendant was ordered to answer questions about her involvement with Epstein and Giuffre in a prior defamation case. The document outlines the court's previous orders and introduces the applicable law for perjury, citing legal standards for determining if a statement is knowingly false.
HOUSE_OVERSIGHT_017962.jpg
This document is the final signature page (page 28) of a legal complaint filed on April 16, 2019, in Case 1:19-cv-03377. It includes a prayer for relief in excess of $75,000 and a formal Jury Demand. The document is signed by attorneys Joshua Schiller and Sigrid McCawley of the law firm Boies Schiller Flexner LLP. The page bears a 'HOUSE_OVERSIGHT' Bates stamp, indicating it was part of a document production to Congress.
HOUSE_OVERSIGHT_017937.jpg
This document is page 3 of a civil complaint filed on April 16, 2019. It alleges that Alan Dershowitz was not only Jeffrey Epstein's attorney and friend but also a co-conspirator and participant in sex trafficking who abused the Plaintiff. It details how Dershowitz helped negotiate a Non-Prosecution Agreement (NPA) in Florida while keeping victims, including 'Roberts,' in the dark, and later attacked the credibility of Epstein's accusers.
HOUSE_OVERSIGHT_011923.jpg
This document is page 12 of a legal filing outlining Count IV (Equitable Relief for Loss of Business) and Count V (Defamation) against defendant Tyler McDonald (d/b/a Yi.Org). The Plaintiff, owner of agency MC2 (historically associated with Jean-Luc Brunel), alleges that McDonald published false statements via a domain hosting service that damaged the agency's reputation and revenue. The Plaintiff seeks damages in excess of $15,000 and a trial by jury.
HOUSE_OVERSIGHT_025938.jpg
This document is a sworn declaration by a witness using the pseudonym Tiffany Doe, filed in a 2016 legal case. The witness details witnessing sexual abuse and physical threats committed by Mr. Trump and Mr. Epstein against a plaintiff and other minors between 1990 and 2000, and states that she and her family have received death threats to prevent disclosure.
HOUSE_OVERSIGHT_032322.jpg
This is page 2 of a court order from Case 1:16-cv-07673-RA, filed on October 4, 2016, and signed by U.S. District Judge Ronnie Abrams. The document outlines requirements for the parties to submit a joint case management plan by December 9, 2016, and orders the Plaintiff to serve the Defendants with the order. The document bears a House Oversight Committee Bates stamp.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| N/A | Received | SARAH KELLEN | plaintiff | $15,000.00 | Demanded judgment for damages in excess of fift... | View |
| N/A | Received | Client | plaintiff | $0.00 | Civil lawsuits seeking 'millions of dollars' fr... | View |
| N/A | Received | defendant | plaintiff | $0.00 | Lawsuits seeking millions of dollars from the c... | View |
| N/A | Received | Unknown (implied ... | plaintiff | $100.00 | Plaintiff was paid $100.00 for bringing a 22 ye... | View |
| N/A | Received | Unknown (implied ... | plaintiff | $100.00 | Plaintiff was paid $100.00 for bringing a femal... | View |
| N/A | Received | Unknown (implied ... | plaintiff | $100.00 | Plaintiff was paid $100.00 for bringing a femal... | View |
| N/A | Received | N/A | plaintiff | $150,000.00 | Statutory damages claimed by Plaintiff per even... | View |
| N/A | Received | N/A | plaintiff | $50,000.00 | Minimum statutory damages argued by Defendant. | View |
| N/A | Received | defendant | plaintiff | $30,000,000.00 | Plaintiff's request for damages mentioned by De... | View |
| N/A | Received | defendant | plaintiff | $5,000,000.00 | Claimed lost wages by Plaintiff. | View |
| N/A | Received | Media Sources | plaintiff | $0.00 | Defense claims Plaintiff received 'hundreds of ... | View |
| N/A | Paid | plaintiff | defendants | $15,000.00 | Action for damages in excess of $15,000. | View |
| N/A | Received | SARAH KELLEN | plaintiff | $0.00 | Paid Plaintiff for 'sessions' with JEFFREY EPSTEIN | View |
| N/A | Received | SARAH KELLEN | plaintiff | $0.00 | Paid Plaintiff for posing for photographs | View |
| 2019-12-12 | Received | Greyhound | plaintiff | $20,000,000.00 | Verdict amount | View |
| 2019-04-22 | Received | Novozymes A/S | plaintiff | $7,500,000.00 | Jury verdict in patent case mentioned in Federa... | View |
| 2019-04-22 | Received | Samsung | plaintiff | $19,200,000.00 | Patent infringement verdict mentioned in Federa... | View |
| 2015-09-21 | Received | GHISLAINE MAXWELL | plaintiff | $75,000.00 | Amount in controversy exceeds $75,000 exclusive... | View |
| 2010-12-13 | Received | defendants | plaintiff | $0.00 | Settlement referenced in stipulation (amounts n... | View |
| 2010-05-07 | Received | Jeffrey Epstein | plaintiff | $50,000,000.00 | Offer to stipulate that net worth is in excess ... | View |
| 2009-08-01 | Paid | plaintiff | Jean Luc Bruhel | $0.00 | Witness fees and travel expenses listed as $0.0... | View |
| 2009-07-24 | Paid | plaintiff | Court | $350.00 | Filing fee paid (Receipt #546977). | View |
| 2009-06-01 | Received | defendant | plaintiff | $150,000.00 | Damages sought per violation under 2006 amended... | View |
| 2009-06-01 | Received | defendant | plaintiff | $50,000.00 | Damages minimum under 2005 statute | View |
| 2008-01-24 | Received | Epstein (potential) | plaintiff | $50,000,000.00 | Lawsuit seeking more than $50 million filed aga... | View |
Arranging for gifts
Sarah Kellen made telephone calls to the Plaintiff, when the Plaintiff was a minor, to arrange for gifts to be sent to the Plaintiff.
Exhibit G
Cited as an example of lost business.
Arranging for Plaintiff to come to Palm Beach mansion for...
Sarah Kellen often called the Plaintiff, when the Plaintiff was a minor, to arrange for the Plaintiff to come to the Palm Beach mansion of JEFFREY EPSTEIN, for the ostensible purpose of providing 'massages' to JEFFREY EPSTEIN.
Consent to modification
Court ordered Plaintiff to file a letter stating whether she consents to the modification of the Proposed Order.
Motion to dismiss action with prejudice
Plaintiff moved to dismiss the action following settlement with the Compensation Program.
Discovery
Sixteen interrogatories and twenty-four requests for production of documents.
Request for pre-motion conference
Referenced in the text as a letter raising substantive issues.
Request for pre-motion conference
Referenced in the text as a letter raising substantive issues.
Promise to amend responses
Defendants promised to serve amended responses to interrogatories by the end of the week.
Document Preservation Notice
Plaintiff sent a document preservation notice and identified various email accounts used by Jeffrey Epstein.
Discovery
Requests for names of medical providers, employers, and education history.
Plaintiff’s proposed Protective Order
A proposed Protective Order in redline and clean formats was sent to Laura Menninger.
Service of Process
Discovery of an unmarked envelope in mailbox containing Summons, Complaint, Civil Rico Case Statement, subpoenas, and interrogatories.
Children's Names
Goldberger mentions a letter that identifies children's names, which the Judge could not find in the documents under review.
Summons
Mailing of summons to address where doorman was served.
Interrogatories
Interrogatories propounded by the Defendant.
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