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1.53 MB
Extraction Summary
5
People
4
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal motion / filing (opposition to subpoena)
File Size:
1.53 MB
Summary
This document is a page from a legal filing arguing against a subpoena issued to a non-party (Jane Doe No. 3). The text asserts that the Defendant is abusing subpoena power to harass the non-party by seeking irrelevant personal financial information, specifically requesting records of payments from Jeffrey Epstein between 1999 and 2002, and information regarding a potential book deal. The filing argues that whether Epstein paid the minors he trafficked is irrelevant to the current action.
People (5)
| Name | Role | Context |
|---|---|---|
| Jane Doe #1 | Plaintiff |
Plaintiff in the Federal Action against the US
|
| Jane Doe #2 | Plaintiff |
Plaintiff in the Federal Action against the US
|
| Jane Doe No. 3 | Non-party / Victim |
Subject of the subpoena; described as a subject of sexual trafficking by Jeffrey Epstein
|
| Jeffrey Epstein | Perpetrator |
Accused of sexually trafficking Jane Doe No. 3; alleged payer of remuneration
|
| Defendant | Defendant |
Party issuing the subpoena (unnamed in text, but contextually likely Ghislaine Maxwell in related litigation)
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States District Court for the Southern District of Florida |
Court where the Federal Action was filed
|
|
| United States of America |
Defendant in the referenced Federal Action
|
|
| Fla. 4th DCA |
Florida Fourth District Court of Appeal (cited in case law)
|
|
| Fla. 1st DCA |
Florida First District Court of Appeal (cited in case law)
|
Timeline (2 events)
January 1, 1999 - December 31, 2002
Time period specified in subpoena request regarding payments from Epstein
Unknown
Locations (1)
| Location | Context |
|---|---|
|
Jurisdiction of the Federal Action
|
Relationships (2)
Text refers to her as 'subject of sexual trafficking by Jeffrey Epstein' and mentions 'minor children that he sexually trafficked'
Listed together in case caption 'Jane Doe #1 and Jane Doe #2 v. United States of America'
Key Quotes (4)
"The requests are clearly meant to intimidate and harass her by, for example, seeking information during the time she was the subject of sexual trafficking by Jeffrey Epstein."Source
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Quote #1
"Request no. 20 seeks 'All documents showing any payments or remuneration of any kind made by Jeffery Epstein or any of his agents or associates to you from January 1, 1999 through December 31, 2002.'"Source
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Quote #2
"Whether Jeffrey Epstein paid minor children that he sexually trafficked has absolutely nothing to do with the action before this Court"Source
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Quote #3
"Apparently, Defendant believes Jane Doe No. 3 has a book 'deal' in the works."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,204 characters)
Declaration dated February 5, 2015, which were filed with the United States District Court for the
Southern District of Florida, in Jane Doe #1 and Jane Doe #2 v. United States of America, Case
No. 08-80736-CIV-MARRA/JOHNSON, [ECF No. 291-1] (the "Federal Action").” Defendant
should not be using the subpoena power of this Court to issue a non-party subpoena for documents
sought for a federal action.²
Southern District of Florida, in Jane Doe #1 and Jane Doe #2 v. United States of America, Case
No. 08-80736-CIV-MARRA/JOHNSON, [ECF No. 291-1] (the "Federal Action").” Defendant
should not be using the subpoena power of this Court to issue a non-party subpoena for documents
sought for a federal action.²
c. Category 3 – Documents that Contain Personal Financial Information Completely
Irrelevant to this Action
Irrelevant to this Action
Defendant also wrongfully abuses the subpoena power to seek personal financial
information from this non-party. See Woodward v. Berkery, 714 So. 2d 1027, 1034-38 (Fla. 4th
DCA 1998) (quashing lower court’s discovery order and finding irreparable harm to husband in
disclosure of private financial information when wife’s clear purpose was to wrongfully disclose
the financial information to the press) (emphasis added); see also Granville v. Granville, 445 So.
2d 362 (Fla. 1st DCA 1984) (court of appeal overturning denial of protective order and finding that
private financial information should have been protected from disclosure).
information from this non-party. See Woodward v. Berkery, 714 So. 2d 1027, 1034-38 (Fla. 4th
DCA 1998) (quashing lower court’s discovery order and finding irreparable harm to husband in
disclosure of private financial information when wife’s clear purpose was to wrongfully disclose
the financial information to the press) (emphasis added); see also Granville v. Granville, 445 So.
2d 362 (Fla. 1st DCA 1984) (court of appeal overturning denial of protective order and finding that
private financial information should have been protected from disclosure).
The requests are clearly meant to intimidate and harass her by, for example, seeking
information during the time she was the subject of sexual trafficking by Jeffrey Epstein. Request
no. 20 seeks “All documents showing any payments or remuneration of any kind made by Jeffery
Epstein or any of his agents or associates to you from January 1, 1999 through December 31,
2002.” Whether Jeffrey Epstein paid minor children that he sexually trafficked has absolutely
nothing to do with the action before this Court and there is no basis to force a non-party who was
subject to this abuse to comply with a production demand on this topic. The subpoena also
includes request for financial information relating to the media. Apparently, Defendant believes
Jane Doe No. 3 has a book “deal” in the works. For example, Request no. 18 seeks: “All
documents concerning any monetary payments or other consideration received by you from any
information during the time she was the subject of sexual trafficking by Jeffrey Epstein. Request
no. 20 seeks “All documents showing any payments or remuneration of any kind made by Jeffery
Epstein or any of his agents or associates to you from January 1, 1999 through December 31,
2002.” Whether Jeffrey Epstein paid minor children that he sexually trafficked has absolutely
nothing to do with the action before this Court and there is no basis to force a non-party who was
subject to this abuse to comply with a production demand on this topic. The subpoena also
includes request for financial information relating to the media. Apparently, Defendant believes
Jane Doe No. 3 has a book “deal” in the works. For example, Request no. 18 seeks: “All
documents concerning any monetary payments or other consideration received by you from any
² The requests relevant to this category are nos.: 1, 5, 6,7, 8, 9, 12, 13, 14, 22, and 24.
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