diff --git a/marker2/court-jane-doe-43/EFTA02819514/EFTA02819514.md b/marker2/court-jane-doe-43/EFTA02819514/EFTA02819514.md new file mode 100644 index 0000000000000000000000000000000000000000..3275afa6cafd961bb6384208012bb3f985f019fb --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819514/EFTA02819514.md @@ -0,0 +1,219 @@ +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +Plaintiff, + +vs. + +JEFFREY EPSTEIN GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +Defendants. + +# COMPLAINT + +# JURY TRIAL DEMANDED + +CASE NO.: + +Plaintiff Jane Doe 43, by and through her undersigned counsel, for her claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, Lesley Groff, and Natalya alleges upon personal knowledge with respect to her own acts and status and upon information and belief as to all other matters, as follows: + +- 1. This cause of action arises under federal statutes and jurisdiction is proper under 28 U.S.C. § 1331. +- 2. Plaintiff files this Complaint under a pseudonym in order to protect her identity because this Complaint makes allegations of a sensitive sexual nature and disclosure of Plaintiffs name publicly will cause further harm to her. +- 3. At all times material to the events alleged in this cause of action the Plaintiff was a citizen of South Africa residing in New York, New York. + +4. At all times material to this cause of action Defendant Jeffrey Epstein had multiple residences, including in New York, New York and the United States Virgin Islands. He is currently a citizen of the United States and a resident of New York and the U.S. Virgin Islands. + +5. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in 1953. + +6. At all times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York and was a citizen of Great Britain and France. + +7. At all times material to this cause of action was residing in New York, New York, and, on information and belief, was a citizen of the United States. + +8. At all times material to this cause of action Lesley Groff was residing in New York, New York and, on information and belief, was a citizen of the United States. + +9. At all material times, Natalya was residing in New York, New York and, on information and belief, was a citizen of the United States. + +10. Including because a substantial part of the events and omissions giving rise to this cause of action occurred in the Southern District of New York, venue is proper in that District. 28 U.S.C. § 1391(b)(2) + +11. At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, , Lesley Grog and Natalya owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional or tortious illegal acts against her. + +### FACTUAL ALLEGATIONS + +12. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is known as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes and to employ numerous others, including the named Defendants, to conspire and assist in committing those crimes and additional torts as well as to protect and conceal his crimes and torts from being discovered. + +13. Defendant Epstein displays his enormous wealth, power and influence to his employees; to the victims procured for sexual purposes; and to the public in order to advance and carry out his crimes and torts. At all relevant times, Defendant Epstein owned and continues to own, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats and one or more helicopters. He owned and owns numerous properties and homes, including a 51,000-square-foot mansion in Manhattan; a \$30 Million, 7,500-acre ranch in New Mexico; a 70-acre private island formerly known as Little St. James in or near St. , U.S. Virgin Islands; a mansion in London, England; a home + +in Paris, France; and a mansion in Palm Beach County, Florida. The allegations herein primarily concern the defendant's conduct while at his townhouse in New York; on one or more of his private airplanes; and on his private island in the United States Virgin Islands. + +14. Defendant Epstein has a compulsive sexual preference for young females as young as 13 and as "old" as 25. Defendant had sex with young females virtually every day and assisted in the development and execution of a sex trafficking scheme designed to fulfill his sexual desires. + +15. Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking enterprise. She herself recruited young females; oversaw and trained other recruiters on how best to recruit girls for sex; developed and executed schemes designed to recruit young females; and ensured that all participants of the Defendants' sex trafficking scheme acted in certain specific ways in order to advance the purposes of the scheme and conceal it from law enforcement. + +16. Defendant recruited young females and maintained Epstein's sex schedule in order to ensure that he was not without the sexual favors of young females for any extended period of time. Defendant also handled travel arrangements for the various females being exploited for sexual purposes. + +Defendant reported directly up the enterprise's line of authority to Defendant Maxwell. + +17. Defendant Epstein employed many recruiters of young females. The nature of the Defendants' sex trafficking scheme enabled victims themselves, such as Defendant to elevate their status to that of a paid recruiter of other victims. Recruiters were taught by Defendants Epstein and Maxwell to inform targeted victims that Epstein possessed extraordinary wealth, power, resources and influence; that he was a philanthropist who would help female victims advance their careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact, however, these representations were fraudulent The vast majority of girls were required to perform intimate sexual acts at the Defendants' direction and the Defendants did not help or intend to help advance the victims' careers. + +18. Defendant Groff coordinated schedules between Defendant Epstein and the various young females used for sex; made travel arrangements for the girls; tended to their living needs; and communicated with them in order to maintain their compliance with the rules of behavior imposed upon them by the enterprise. + +19. The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein's compulsive need for sex with young females by preying on their personal, psychological, financial, and related vulnerabilities. The Defendants' tactics included promising the victims money, shelter, transportation, employment, admission into educational institutions, educational tuition, and other things of value in exchange for sex. + +20. Defendants' sex trafficking venture and enterprise operated in a hierarchal structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top and underlings below. Underlings included the other named Defendants as well as unnamed co-conspirators such as various housekeepers and butlers; an airplane pilot; and various employees, assistants and associates. Wittingly and unwittingly, such underlings performed their respective roles with the purpose and effect of insuring that the enterprise supplied young females to Defendant Epstein and others for sexual purposes. At all times materials to this complaint, the venture and enterprise was a group of two or more individuals associated in fact and deed. + +21. Defendants Epstein and Maxwell, with help from assistants, associates and underlings, recruited and procured hundreds of girls over the decades of the operation of their scheme. Such recruitment and procurement included fraud, coercion, the threat of coercion, and a combination of these and similar tactics. Following the Defendants' recruitment and procurement of the females to join Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent + +promises, coercion, and threats of coercion in order to entice young females into sex and, once sexual activities ensued, to cause them to remain in the enterprise. The Defendants also transported females in interstate and foreign commerce and in ways that affected interstate and foreign commerce. + +22. Defendants specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females to join the Defendants' enterprise. + +23. It is unknown exactly how long Defendant Epstein and Maxwell's aforementioned criminal and illegal enterprise operated, although it was at least continuously and actively in operation from the mid-1990's through and including the calendar year 2007. + +24. Defendant Epstein has continued the enterprise and conspiracy up to the present time. + +25. In 2005, Defendant Epstein and numerous co-conspirators within the enterprise were the subjects of a Palm Beach, Florida Police Department criminal investigation which revealed that Defendant Epstein had engaged in sexual activities with dozens of young teenage children. Each child was lured into Defendant Epstein's Palm Beach mansion with a promise that she would receive money for providing him with a body massage, although once there, each child was made to engage in a sex act in order to receive the promised compensation. Several were also made to engage in sex with another of Defendant Epstein's female sexual traveling companions. + +26. In 2006, the Palm Beach Police Department investigation was turned over to the FBI and the United States Attorney's Office for the Southern District of Florida. The United States Attorney's Office investigated Defendant Epstein and his co-conspirators for their violations of numerous federal statutes, including 18 U.S.C. §1591, one of the statutory bases for this complaint. + +27. The United States Attorney's investigation continued from 2006 through September 2007, at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office deferring federal prosecution of Defendant Epstein and his numerous co-conspirators for identified federal sex crimes against more than 30 minors. + +28. From late 2006 through September 2007, Epstein's team of lawyers negotiated with the federal government in an effort to avoid the filing of the fiftythree-page draft indictment of Epstein. During these negotiations, Defendant Epstein decamped from Palm Beach to New York and the U.S. Virgin Islands in order to convey an image to prosecutors that he and his co-conspirators had stopped committing sex crimes. + +29. Remarkably, however—as this case will highlight—Defendant Epstein and his co-Defendants, including the other defendants named herein, did not abandon their sex trafficking enterprise even while they were under state and federal investigation for crimes committed in violation of 18 U.S.C. § 1591, among other laws, and even as Defendants and their attorneys were busy arguing Epstein's innocence and publicly defaming his victims as liars. Rather, Defendants merely changed their style. Instead of targeting local Palm Beach Florida high school girls, the Defendants transported young females from other places in the U.S. and abroad and brought them to Defendant Epstein's mansion in New York and his private island in the Virgin Islands. + +30. In June of 2008, Epstein pleaded guilty to Florida state felony sex offenses for procuring a minor for prostitution and soliciting prostitution by minors. + +31. Defendants Epstein and Maxwell developed and implemented a sophisticated system designed to insulate them from criminal and civil liability by protecting them from potential testimony of knowledgeable subordinates. The system included requiring subordinates to sign confidentiality agreements covering civil and criminal activity; requiring subordinates and victims to refrain from speaking with law enforcement officials; requiring them to notify Defendant Epstein's lawyers in the event they (subordinates and victims) were contacted by law enforcement officials; requiring them to accept the representation of attorneys paid for by Defendant Epstein; requiring them to invoke the Fifth Amendment in response to questions they might be asked by investigators and prosecutors; requiring them to invoke the Fifth Amendment in order to refuse to turn over incriminating and non-incriminating evidence to law enforcement officers; requiring them to destroy evidence or refuse to reveal knowledge of destroyed evidence; and requiring them generally to refuse all cooperation with law enforcement officials or investigations. + +32. In 2005, Defendant Epstein and other co-conspirators, aware that law enforcement officials were preparing imminently to execute a search warrant of his home, removed computer systems that logged information about Epstein and his co-conspirators' illegal and criminal conduct; the identities of witnesses; nude photographs of young females; scheduling books; message pads; tangible items such as vibrators and toys; and other incriminating matter. + +33. Commencing in approximately October 2006 and continuing through April 2007, Defendants recruited Plaintiff into their sexual enterprise by fraudulently promising to use their connections and resources to secure her admission to an institution of higher education at the expense of Defendant Epstein. + +34. Defendant was working as one of the enterprise's recruiters of young females when she approached and recruited Plaintiff. + +35. Defendant informed Plaintiff that she would introduce Plaintiff to Defendant Epstein, whom she described as a wealthy philanthropist who regularly used his wealth, influence and connections to help financially poor females like Plaintiff achieve their personal and professional goals and aspirations. + +36. Defendant reported to her superiors, Defendants =, Groff and Maxwell, and was paid for her recruitment of young females, including the recruitment of Plaintiff. + +37. Defendant introduced Plaintiff to Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology, known as "F.I.T.", in New York City, or into a similar institute of higher learning offering a curriculum of fashion industry training. Defendants Maxwell, and Groff each confirmed this promise to Plaintiff many times. + +38. Defendant Maxwell told Plaintiff she would need to provide Defendant Epstein with body massages in order to reap the benefits of his and Maxwell's connections. Maxwell and Epstein also threatened Plaintiff that, while they had the ability to advance her education and career, they also had the ability to make sure that she would obtain no formal education or modeling agency contracts if she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein and Maxwell. + +39. Plaintiff reasonably believed that her compliance with Defendants' demands was crucial to her physical, psychological, financial, and reputational survival. + +40. Defendant Maxwell instructed Plaintiff how to massage Epstein using the techniques that he preferred. During Plaintiff's first massage, Defendant Epstein converted it into a sexual act and made it known to Plaintiff that further sex would be required in order for her to obtain the assistance he promised and to avoid Defendants' threatened retaliation if Plaintiff did not perform as demanded. + +41. Defendants Maxwell and Epstein informed Plaintiff that other young females in Defendant Epstein's company were there not only to provide massages, but also sexual acts. + +42. Plaintiff was instructed dozens of times to provide body massages to Defendant Epstein, both at his townhouse in New York and on his private island in the U.S. Virgin Islands. Each time she was so instructed she was also required to perform a sexual act with Defendant Epstein. The Defendants transported Plaintiff in interstate and foreign commerce, and affecting interstate and foreign commerce, for these sexual purposes. + +43. During many sexual encounters, Defendant Epstein gave Plaintiff no option, opportunity or choice not to participate in the prescribed sexual acts. + +44. Defendant Maxwell frequently controlled the assignment, or "rotation," of Plaintiff and the other young females concerning the time, place and manner of the sex acts they were told to provide to Defendant Epstein. Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with other females. + +45. Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaintiff with serious harm, as well as serious psychological, financial, and reputational harm, with the purpose and effect of compelling Plaintiff to perform and continue performing the demanded commercial sexual activity. + +46. On one occasion, after suffering verbal abuse and threats by Defendants Epstein, Maxwell, and Plaintiff attempted to escape from Defendant Epstein's private island. A search party led by Defendant Epstein located her and physically returned her to the main house on the island. Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind. + +47. Defendant Epstein's wealth, influence, power and connections were used both as an inducement to provide sex (in exchange for promises of support), and as a means of threatening punishment (should Plaintiff refuse to comply with Defendants' instructions). + +48. In addition to Plaintiff's being trafficked on Defendant Epstein's private plane, Defendants Groff, Maxwell and with the knowledge of and instruction by Defendant Epstein, arranged Plaintiffs commercial air travel on numerous occasions for the purpose of causing Plaintiff to commit commercial sex acts. + +49. Defendants provided living quarters for Plaintiff at 301 East 66 Street, New York; a car service for Plaintiff to use as needed; a cell phone; and other valuable consideration in order to maintain Plaintiffs sexual compliance. + +50. The relationship between Plaintiff and Defendants Epstein and Maxwell was defined and characterized by Defendant Epstein's and Defendant Maxwell's frequent and persistent fraudulent representations that they would provide Plaintiff with a formal education and career advancement if she provided sex to Defendant Epstein and others in the times, places and manners demanded by Defendants. Plaintiff reasonably relied on those representations. In fact, however, those representations were knowingly false, were not acted upon, and were made by Defendants Epstein and Maxwell solely for the purpose of maintaining + +Plaintiffs financial dependence on, emotional vulnerability to, and sexual compliance with Defendants Epstein and Maxwell and their demands. The other Defendants intentionally repeated those representations and intentionally attempted to convince Plaintiff that the representations were true and could be relied upon. + +51. In January 2007, Defendants sent Plaintiff from the United States to South Africa in part to recruit, for a promised fee, one or more aspiring female models supposedly for Defendant Epstein to use as an alleged personal assistant. Defendants Epstein and Maxwell continuously and frequently demanded that Plaintiff fulfill this task as a condition of her receiving the education, career and related benefits promised by Defendants Epstein and Maxwell. Based upon Plaintiff's experience with Defendants, however, she did not believe that the requested model would be placed in a legitimate position of employment with Defendant Epstein but would, instead, be forced into sexual servitude. As a result, Plaintiff deliberately refused to perform the recruitment assignment. + +52. As part of their ongoing scheme, Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts. While Plaintiff was in South Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be permitted to return to the United States to receive her promised education unless she underwent a diet and lowered her body weight from 57 kilograms (approximately 125 pounds) to 52 kilograms (approximately 114 pounds). Believing she had no practical choice in the matter, Plaintiff attempted to comply with the order but, given her physical height and structure and her existing low body weight, the diet imposed upon her placed her in serious physical jeopardy, including kidney malfunction and extreme emotional and psychological distress. + +53. Defendants Epstein and Maxwell called Plaintiffs parents in South Africa to tell them that Defendants would take good care of Plaintiff when she returned to the United States and that they would use their connections and influence to have her admitted to F.I.T. or another well-regarded fashion school. + +54. In February of 2007, Plaintiff returned to New York and was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants Maxwell and Epstein fraudulently promised her again that her sexual compliance would be rewarded with admission to F.I.T. or a comparable college, a promise which they knew to be false. Plaintiff knew that if she did not comply, Defendants Maxwell and Epstein would use their power, influence and connections in order to ensure that Plaintiff was unable to gain admission to F.I.T. or a comparable school, and that they would destroy her career as they had destroyed the careers of others who had failed to comply. + +55. Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiffs continued compliance with Epstein's sexual demands; however, they failed and refused to perform their promises to help Plaintiff be admitted to F.I.T. or another school, or to provide financial support for college admission or on-going education, false promises they repeatedly made in order to coerce her into commercial sex acts. + +56. Defendants Epstein and Maxwell's sexual demands on Plaintiff continued while she was in New York or other geographic proximity to the Defendants. In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, Defendants continued to pressure her to lose excessive amounts of body weight and offered her no opportunity to decline or resist their instructions. + +57. In May, 2007, Plaintiff left the United States and did not return. + +58. Defendants' representations and promises were all false and fraudulent. Their threats were considered by Plaintiff to be real and credible. All such representations, promises and threats were made solely for the purpose of coercing and otherwise inducing Plaintiff into prolonged sexual compliance. Defendants knowingly benefitted financially and received things of value as a result of their participating in their illegal enterprise. + +## COUNT I + +## CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C. S1595 + +59. Plaintiff adopts and realleges paragraphs 1 through 58 above. + +60. Defendants individually and together, within the special maritime and territorial jurisdiction of the United States, in interstate and foreign commerce and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, maintained, patronized, solicited, threatened, forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by Defendants were undertaken with knowledge and/or reckless disregard of the fact that their threats of force, fraud, coercion, and combinations of such means would be used, and were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In so doing, Defendants violated 18 U.S.C. §§1591 through 1594 and are subject to civil causes of action under 18 U.S.C. § 1595. + +61. Defendants additionally profited from the sex trafficking of Plaintiff; obstructed investigations of the violations; attempted and conspired to violate, and succeeded in violating, 18 U.S.C. §§ 1591 through 1595, by the commission of the torts and crimes described in this complaint. + +62. Certain property of Defendant Epstein's was essential to the commission of the federal crimes and torts described herein, including the use of multiple private aircraft including a Boeing aircraft (of make and model B-727- 31H with tail number N908JE) and a Gulfstream aircraft (of make and model G-1159B with tail number N909JE). Such aircraft, along with other of Defendants' + +property, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. + +63. Additionally, Defendant Epstein's New York mansion, located at 9 East 71st street, New York, New York, and his private island located in the United States Virgin Islands, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. + +64. As a direct and proximate result of Defendants' commission of the aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 et. seq. and the civil remedies provided in § 1595, Plaintiff has in the past suffered and will continue to suffer injury and pain; emotional distress; psychological and psychiatric trauma; mental anguish; humiliation; confusion; embarrassment: loss of selfesteem; loss of dignity; loss of enjoyment of life; invasion of privacy; and other damages associated with Defendants' actions. Plaintiff will incur medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to these losses, Plaintiff has incurred attorneys' fees and will do so in the future. + +WHEREFORE, Plaintiff demands judgment against Defendants for compensatory damages, attorney's fees, punitive damages and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury. + +Dated: January 26, 2017 + +Respectfully Submitted, + +BOIES, SCHILLER & FLEXNER LLP + +By: /s/ David Boies + +David Boies + +Boies Schiller & Flexner LLP + +333 Main Street + +Armonk, New York 10504 + +T: (914) 749 8200 + +E: dboies@bsfllp.com + +Alex Boies + +Boies Schiller & Flexner LLP + +575 Lexington Ave., 7'h Fl. + +New York, New York 10022 + +T: (212) 446-2300 + +E: aboies@bsfllp.com + +Sigrid McSir + +Meredith + +Boies Schiller & Flexner LLP + +401 East Las Olas Blvd., Ste. 1200 + +Fort Lauderdale, Florida 33301 + +T: (954) 356-0011 + +E: smccawley®bsfllp.com + +E: mschultz@bsfllp.com + +Pro Hac Vice to be filed + +MIJ. , Jaffe, Weissing, , + +Fistos & Lehrman, P.L. 425 North Andrews Ave., Ste. 2 Fort Lauderdale, Florida 33301 T: (954) 524-2820 E: brad@pathtojustice.com Pro Hac Vice to be filed + +J. Stanley Pottinger J. 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This form. approved by the Judicial Conference of the United States in September 1974.\* required for use of the Clerk of Court for the purpose of initiating the civil docket sheet. + +> DEFENDANTS JEFFREY EPSTEIN, GHISLAINE MAXWELL, GROFF AND NATALYA LESLEY + +ATTORNEYS (FIRM NAME. ADDRESS. AND TELEPHONE NUMBER ATTORNEYS (IF KNOWN) DAVID BOLES. BOLES SCHILLER 8 FLEXNER LLP 333 MAIN STREET, ARMONK. NEW YORK 10504 dboies@bsfilp.com, (914) 749 8200 + +CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSgi (DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY) + +Defendants trafficked Plaintiff in Violation of 18 U.S.C. §§ 1591-1595 + +Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? No aYesO Judge Previously Assigned + +If yes. was this case Vol]] Invol. ❑ Dismissed. No O Yes O If yes. give date 8 Case No. + +Is THIS AN INTONATIONAL ARBITRATION CASH No O Yes O + +(PLACE AN 14 IN ONE BOX ONLY) NATURE OF SUIT + +| | | TORTS | | | ACTIONS UNDER STATUTES | | +|---------------|------------------|---------------------------------------------------|-----------------------------|--------------------------|---------------------------|----------------------------| +| CONTRACT | | PERSONAL INJURY | PERSONAL INJURY | FORFEITURFJPENAI_TY | BANKRUPTCY | OTHER STATUTES | +| ( ) 120 | | | | | | | +| ( 1 130 | | | | | | | +| | INSURANCE ACT | ( I 3t0 AJRPLANE | | | | | +| | | | | I )425 DRUG RELATED | ( )422 APPEAL | | +| | | | | SEIZURE OF PROPERTY | 28 USC 158 | | +| | | | | 21 INC 881 | 1423 WITHDRAWAL | | +| | | | | | | I 1376 OUI TAM | +| (1140 | NEGOTIABLE | | | | | | +| | | | 1368 ASBESTOS PERSONAL | 1 690 OTHER | 28 USC 157 | REAPPORTIONMENT | +| () 150 | RECOVERY OF | ( )330 FEDERAL | INJURY PRODUCT | | | ( 1430 BANKS b WRUNG | +| | OVERPAYMENT & | EMPLOYERS | LIABILITY | | PROPERTY RIGHTS | ( )450 COMMERCE | +| | ENFORCEMENT | LIABILITY | | | | ( )480 DEPORTATION | +| | OF JUOGLIENT | ( 1340 MARINE | PERSONAL PROPERTY | | f law COPYRIGHTS | ( 1470 RACKETEER INFLU. | +| ( )151 | MEDICARE ACT | ( 1345 MARINE PRODUCT | | | 1830 PATENT | ENCED 8 CORRUPT | +| ( 1152 | RECOVERY OF | LIABILITY | 370 OTHER FRAUD | | 1840 TRADEMARK | ORGANIZATION ACT | +| | | f 1366 MOTOR VEHICLE | | | | | +| | | | II 371 TRUTH IN LENDING | | | (RICO) | +| | (EFCL VETERANS) | PRODUCT LIABILITY | | | SOCIAL SECURITY | ( 1490 CABLE/SATELLITE TV | +| ( ) 153 | RECOVERY OF | ( 1360 OTHER PERSONAL | | | | | +| | OVERPAYMENT | INJURY | 11300 OTHER PERSONAL | LABOR | ( 1881 HIA 0395() | ( 1850 SECURITIES/ | +| | OF VETERANS | ( 1362 PERSONAL INJURY • | PROPERTY DAMAGE | | ( I 882 &ACK LUNG (923) | COMMODITIES/ | +| | BENEFITS | MED MALPRACTICE | 385 PROPERTY DAMAGE | I ) 710 FAIR LABOR | ( 1883 DING/OM R (40506 | EXCHANGE | +| ( )160 | STOCKHOLDERS | | PRODUCT LIABILITY | STANDARDS ACT | 1864 SSID TITLE XVI | | +| | SUITS | | | 720 LABORMGMT | 11885 R51 1405(9)) | | +| ( ) 190 | OTHER | | PRISONER PETITIONS | RELATIONS | | pQ 890 OTHER STATUTORY | +| | CONTRACT | | I 1 463 AUER DETNNEE | I 1740 RAILWAY LABOR ACT | | ACTIONS | +| ( )195 | CONTRACT | | I 1 SID MOTIONS TO | 751 FAMILY MEDICAL | FEDERAL TAX SUITS | () 891 AGRICULTURAL ACTS | +| | PRODUCT | ACTIONS UNDER STATUTES LEAVE ACT (FULA) LIN3ILITY | VACATE SENTENCE 28 USC 2255 | | 1870 TAXES (U.S. PERIM or | | +| | ( )196 FRANCHISE | CML RIGHTS | 1530 HABEAS CORPUS | 1790 OTHER LABOR | Defendant) | ( 1893 ENVIRONMENT& | +| | | | 515 DEATH PENALTY | LITIGATION | ( )871 IRS.THIRD PARTY | MATTERS | +| | | | I 1540 MANDAMUS & OTHER | 791 EMPL RET INC | USC 7609 | | +| REAL PROPERTY | | | | | | 1 896 ARBITRATION | +| | | 442 EMPLOYMENT it 443 HOUSING/ | | | | | +| | | | I 1 550 ma. RIGHTS | | | | +| | | | | I 1402 NATURALIZATION | | | +| ( )230 | RENT LEASER | ( )FFS AMERICANS WITH | 555 PRISON CONDEMN | 465 OTHER IMMIGRATION | | 1 950 CONSTITUTIONALITY OF | +| | | | CONDITIONS OF CONFINEMENT | | | STATE STATUTES | +| ( 1245 | TORT PRODUCT | ( 1448 AMERICANS WITH | | | | | +| | LIABILITY | DISABILITIES 'OTHER | | | | | +| ( 1290 | ALL OTHER | 1 1448 EDUCATION | | | | | + +REAL PROPERTY + +Chock if demanded in complaint + +❑ CHECK IF THIS IS ACLASS ACTION UNDER F.R.C.P. 23 + +DEMAND \$ OTHER JUDGE DOCKET NUMBER + +DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y. AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 13? IF SO, STATE: + + **1** Original Proceeding **2** Removed from State Court **3** Remanded from Appellate Court **4** Reinstated or Reopened **5** Transferred from (Specify District) **6** Multidistrict Litigation (Transferred) **7** Appeal to District Judge from Magistrate Judge + + **a. all parties represented** **b. At least one party is pro se.** **8** Multidistrict Litigation (Direct File) + +(PLACE AN x 1N ONE BOX ONLY) + +(PLACE AN x IN ONE BOX ONLY) **BASIS OF JURISDICTION** + 1 U.S. PLAINTIFF 2 U.S. DEFENDANT 3 FEDERAL QUESTION 4 DIVERSITY + (U.S. NOT A PARTY) + +## CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY) + +(Place an (XI in one box for Plaintiff and one box for Defendant) + +| | PTF | DEF | | PTF DEF | | PTF | DEF | +|--------------------------|-------|------|---------------------------------|----------|----------------------------------|-----|-----| +| CITIZEN OF THIS STATE | )1 | II | CITIZEN OR SUBJECT OF A | 1 131 33 | INCORPORATED and PRINCIPAL PLACE | ( 5 | 5 | +| | | | FOREIGN COUNTRY | | OF BUSINESS IN ANOTHER STATE | | | +| CITIZEN OF ANOTHER STATE | ( ) 2 | ( )2 | INCORPORATED or PRINCIPAL PLACE | ( )4[14 | FOREIGN NATION | 3 6 | 6 | + +PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES) + +JANE DOE 43 + +C/O BOIES, SCHILLER & FLEXNER LLP + +575 Lexington Avenue, 7th Fl.. + +New York, New York 10022 + +New York County + +DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES) + +Jeffrey Epstein, 9 E. 71st Street, New York, NY 10021 (New York County) + +Ghislaine Maxwell, Orchard End, Fittleton, Salisbury, United Kingdom, SR4 9QA (Wiltshire County, UK) + +, 229 E. 5th Street, Apt. 5, New York, NY 10003 (New York County) + +Lesley Goff 120 Oak Street, New Canaan, CT 06840 (Fairsfield County) + +Natalya 520 N. Croft Avenue, Apt. 222, West Hollywood, CA 90048 (Los Angeles County) + +DEFENDANT(S) ADDRESS UNKNOWN + +REPRESENTATION IS HEREBY MADE THAT. AT THIS TIME. I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS: + +## COURTHOUSE ASSIGNMENT + +I hereby certify that this case should be assigned to the courthouse indicated below pursuant to Local Rule for Division of Business 18, 20 or 21. 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R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: + +> David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, New York 10504 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: + +CLERK OF COURT + +Signature of Clerk or Deputy Clerk + +Civil Action No. + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. 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R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: + +> David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, New York 10504 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: + +CLERK OF COURT + +Signature of Clerk or Deputy Clerk + +Civil Action No. + +## PROOF OF SERVICE + +(This section should not bellied with the court unless required by Fed. R. Civ. 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R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: + +> David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, New York 10504 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: + +CLERK OF COURT + +Signature of Clerk or Deputy Clerk + +(Iva Action No. + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. 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CA 90048 + +A lawsuit has been filed against you. + +Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: + +> David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, New York 10504 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: + +CLERK OF COURT + +Signature of Clerk or Deputy Clerk + +Civil Action No. + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. 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R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: + +> David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, New York 10504 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: + +CLERK OF COURT + +Signature of Clerk or Deputy Clerk + +Civil Action No. + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. 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R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: + +> David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, New York 10504 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +gosssrit + +Date: 1/26/2017 + +CLERK OF COURT + +/S/ R. + +Signature of Clerk or Deputy Clerk + +Civil Action No. + +## PROOF OF SERVICE + +(This section should not bellied with the court unless required by Fed R. Civ. 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R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: + +David Boies +Boies Schiller & Flexner LLP +333 Main Street +Armonk, New York 10504 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: + +1/26/2017 + +![]()CLERK OF COURT + +/s/ R. [REDACTED] + +*Signature of Clerk or Deputy Clerk* + +Civil Action No. + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (1)) + +This summons for (name of individual and title, if an)) was received by me on (date) + +O I personally served the summons on the individual at (place) on (date) ; or O I left the summons at the individual's residence or usual place of abode with (name) , a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual's last known address; or O I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization) on (date) O I returned the summons unexecuted because O Other (specify): ; or , who is ; or + +My fees are \$ for travel and \$ for services, for a total of \$ 0.00 + +I declare under penalty of perjury that this information is true. + +Date: + +Additional information regarding attempted service, etc: + +Server's signature + +Printed name and title + +Server's address \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819549/EFTA02819549.metadata.json b/marker2/court-jane-doe-43/EFTA02819549/EFTA02819549.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dba63dfd35f3db7578208a27fae50b22fc462c0c --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819549/EFTA02819549.metadata.json @@ -0,0 +1,174 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819549.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2323, + "elapsed_seconds": 42.03, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 169.524, + 62.37 + ], + [ + 440.02799999999996, + 62.37 + ], + [ + 440.02799999999996, + 81.0 + ], + [ + 169.524, + 81.0 + ] + ] + }, + { + "title": "SUMMONS IN A CIVIL ACTION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 220.32, + 295.65 + ], + [ + 388.00800000000004, + 295.65 + ], + [ + 388.00800000000004, + 308.61 + ], + [ + 220.32, + 308.61 + ] + ] + }, + { + "title": "PROOF OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 249.08399999999997, + 87.48 + ], + [ + 362.3437194824219, + 87.48 + ], + [ + 362.3437194824219, + 101.34405517578125 + ], + [ + 249.08399999999997, + 101.34405517578125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Text", + 42 + ], + [ + "Line", + 34 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 3 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 30 + ], + [ + "Text", + 14 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819549" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819551/EFTA02819551.md b/marker2/court-jane-doe-43/EFTA02819551/EFTA02819551.md new file mode 100644 index 0000000000000000000000000000000000000000..5b214d370929ceaf7ecbc35dc4cf800924feadde --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819551/EFTA02819551.md @@ -0,0 +1,90 @@ +**UNITED STATES DISTRICT COURT** + +for the + +Southern District of New York + +JANE DOE 43 + +*Plaintiff(s)* + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, +[REDACTED], LESLEY GROFF, +AND NATALYA [REDACTED] + +*Defendant(s)* + +) +) +) +) +) +) +) +) +) +) +) +) +) +) +) + +Civil Action No. 17-cv-616 + +**SUMMONS IN A CIVIL ACTION** + +To: *(Defendant's name and address)* + +[REDACTED] + +229 E. 5th Street +Apt. 5 +New York, New York 10003 + +A lawsuit has been filed against you. + +Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: + +David Boies +Boies Schiller & Flexner LLP +333 Main Street +Armonk, New York 10504 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: + +1/26/2017 + +![]()CLERK OF COURT + +/s/ R. [REDACTED] + +*Signature of Clerk or Deputy Clerk* + +Civil Action No. + +## PROOF OF SERVICE + +(This section should not bellied with the court unless required by Fed. R. Civ. 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CA 90048 + +A lawsuit has been filed against you. + +Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: + +> David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, New York 10504 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: 1/26/2017 + +,,er rytES' + +/s/ R. + +Signature of Clerk or Deputy Clerk + +CM' Action No. + +## PROOF OF SERVICE + +(This section should not bellied with the court unless required by Fed. R. Civ. 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R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: + +David Boies +Boies Schiller & Flexner LLP +333 Main Street +Armonk, New York 10504 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: + +1/26/2017 + +![]()CLERK OF COURT + +/s/ R. [REDACTED] + +--- + +*Signature of Clerk or Deputy Clerk* + +Ova Action No. + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. 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Koeltl. + +All requests for adjournments must be made in bS riting to the Court. + +For any further information, please contact the Court at (212) 805-0107. + +Dated: Ncw York, Ncw York January 31, 2017 + +![](_page_0_Picture_17.jpeg) \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819557/EFTA02819557.metadata.json b/marker2/court-jane-doe-43/EFTA02819557/EFTA02819557.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..86c3784294dfed285863725391f98c7c3067b407 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819557/EFTA02819557.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819557.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 572, + "elapsed_seconds": 0.85, + "image_assets": [ + "_page_0_Picture_17.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "NOTICE OF COURT CONFERENCE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 337.824, + 143.37 + ], + [ + 544.36328125, + 143.37 + ], + [ + 544.36328125, + 158.30352783203125 + ], + [ + 337.824, + 158.30352783203125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 25 + ], + [ + "Text", + 15 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819557" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819557/_page_0_Picture_17.jpeg b/marker2/court-jane-doe-43/EFTA02819557/_page_0_Picture_17.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e6cf8d4dd0b6c085fa69a77a9011762dc4805fc6 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819557/_page_0_Picture_17.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:32a586411fb1656a24ef050e7a982b375fafca767d73fab71b83403056728d48 +size 16813 diff --git a/marker2/court-jane-doe-43/EFTA02819558/EFTA02819558.md b/marker2/court-jane-doe-43/EFTA02819558/EFTA02819558.md new file mode 100644 index 0000000000000000000000000000000000000000..d0c7d9a392fa7a12eb997f7e4bbbebdc897a8206 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819558/EFTA02819558.md @@ -0,0 +1,36 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff: + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +## DECLARATION OF SIGRID S. MCCAWLEY IN SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE + +I, Meredith L. =, hereby declare as follows: + +- I. I have never been convicted of a felony. +- 2. I have never been censured, suspended, disbarred or denied admission or readmission by any court. +- 3. There are no pending disciplinary proceedings against me in any state or federal court. +- 4. I am a member in good standing of the bar of the State of Florida. + +I hereby declare under penalty of perjury that the foregoing statements are true and correct. + +Dated: February 8, 2017 + +Fort Lauderdale, Florida Respectfully submitted, + +BOLES, SCHILLER & FLEXNER LLP + +/s/ Meredith L. + +Meredith L. 401 East Las Olas Blvd., Ste. 1200 Fort Lauderdale, Florida 33301 Tel: (954) 3774204 Fax: (954) 356-0022 Email: mschultz@bsfllp.com + +Attorney for Plaintiff Jane Doe 43 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819558/EFTA02819558.metadata.json b/marker2/court-jane-doe-43/EFTA02819558/EFTA02819558.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a563fba5aae365f1bf4def614421c1b966662f7c --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819558/EFTA02819558.metadata.json @@ -0,0 +1,117 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819558.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1041, + "elapsed_seconds": 0.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 64.25999999999999, + 67.23 + ], + [ + 289.09381103515625, + 67.23 + ], + [ + 289.09381103515625, + 95.60302734375 + ], + [ + 64.25999999999999, + 95.60302734375 + ] + ] + }, + { + "title": "DECLARATION OF SIGRID \nS. 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TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that* + +**MEREDITH LYS** [REDACTED] + +*was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida on October 9, 2006, is presently in good standing, and that the private and professional character of the attorney appear to be good.* + +![](_page_0_Picture_59.jpeg) + +*WITNESS my hand and the Seal of the Supreme Court of Florida at Tallahassee, Capital, this February 6, 2017.* + +![]() + +--- + +*Clerk of the Supreme Court of Florida.* \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819559/EFTA02819559.metadata.json b/marker2/court-jane-doe-43/EFTA02819559/EFTA02819559.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fb0c5603dc61893c9ac3f15a9f5516623a312315 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819559/EFTA02819559.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819559.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 624, + "elapsed_seconds": 3.23, + "image_assets": [ + "_page_0_Picture_59.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Supreme Court of Florida Certificate of Good Standing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 110.77199999999999, + 102.06 + ], + [ + 493.884, + 102.06 + ], + [ + 493.884, + 179.01 + ], + [ + 110.77199999999999, + 179.01 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 12 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819559" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819559/_page_0_Picture_59.jpeg b/marker2/court-jane-doe-43/EFTA02819559/_page_0_Picture_59.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..93b9dc75dc3d66e3189e1ce361437797bf622e1d --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819559/_page_0_Picture_59.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:11f6897f1afd3456372ad2a0dc9140a82acdee3b88ff6bed9f500674b5b2e0f8 +size 16907 diff --git a/marker2/court-jane-doe-43/EFTA02819560/EFTA02819560.md b/marker2/court-jane-doe-43/EFTA02819560/EFTA02819560.md new file mode 100644 index 0000000000000000000000000000000000000000..92ddf84f7995d8545d8e39026fded4021933648d --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819560/EFTA02819560.md @@ -0,0 +1,33 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff, + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +## ORDER FOR ADMISSION PRO HAC VICE + +The motion of Meredith L. to appear Pro Hac Vice in the above-captioned action is granted. + +Applicant has declared that she is a member in good standing of the bar of the State of Florida; and that her contact information is as follows: + +Applicant Name: Meredith L. + +Firm Name: Boies, Schiller & Flexner LLP + +Address: 401 East Las Olas Blvd.. Suite 1200 + +City / State / Zip: Fort Lauderdale. Florida 33301 + +Telephone / Fax: (954) 3774204 / (954) 356-0022 + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff Jane Doe 43 in the above entitled action; + +IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. 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I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. 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MCCAWLEY IN SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE + +I, Sigrid S. McCawley, hereby declare as follows: + +- I. I have never been convicted of a felony. +- 2. I have never been censured, suspended, disbarred or denied admission or readmission by any court. +- 3. There are no pending disciplinary proceedings against me in any state or federal court. +- 4. I am a member in good standing of the bar of the State of Florida. + +I hereby declare under penalty of perjury that the foregoing statements are true and correct. + +Dated: February 9, 2017 + +Fort Lauderdale, Florida Respectfully submitted, + +BOLES, SCHILLER & FLEXNER LLP + +/s/ Sigrid S. McCawley + +Sigrid S. McCawley 401 East Las Olas Blvd., Ste. 1200 Fort Lauderdale, Florida 33301 Tel: (954) 356-0011 Fax: (954) 356-0022 Email: smccawley@bstlIp.com + +Attorney for Plaintiff Jane Doe 43 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819562/EFTA02819562.metadata.json b/marker2/court-jane-doe-43/EFTA02819562/EFTA02819562.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..de7bac8056ccc2fc7bcb01d39f096ddc6ca33643 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819562/EFTA02819562.metadata.json @@ -0,0 +1,117 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819562.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1062, + "elapsed_seconds": 0.82, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 64.25999999999999, + 67.23 + ], + [ + 289.09381103515625, + 67.23 + ], + [ + 289.09381103515625, + 95.60302734375 + ], + [ + 64.25999999999999, + 95.60302734375 + ] + ] + }, + { + "title": "DECLARATION OF SIGRID \nS. 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TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that* + +**SIGRID [REDACTED] MCCAWLEY** + +*was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida on November 6, 1997, is presently in good standing, and that the private and professional character of the attorney appear to be good.* + +![](_page_0_Picture_62.jpeg) + +*WITNESS my hand and the Seal of the Supreme Court of Florida at Tallahassee, the Capital, this February 6, 2017.* + +![]() + +--- + +*Clerk of the Supreme Court of Florida.* \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819563/EFTA02819563.metadata.json b/marker2/court-jane-doe-43/EFTA02819563/EFTA02819563.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6633a19d123c3248766d4f99ae3ae191e9450595 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819563/EFTA02819563.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819563.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 632, + "elapsed_seconds": 3.32, + "image_assets": [ + "_page_0_Picture_62.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Supreme Court of Florida Certificate of Good Standing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 109.548, + 101.25 + ], + [ + 492.04800000000006, + 101.25 + ], + [ + 492.04800000000006, + 177.39000000000001 + ], + [ + 109.548, + 177.39000000000001 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 32 + ], + [ + "Line", + 15 + ], + [ + "Text", + 12 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819563" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819563/_page_0_Picture_62.jpeg b/marker2/court-jane-doe-43/EFTA02819563/_page_0_Picture_62.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..86e7bfbe5c4294cbbd406faa3daab5e53cac7aa0 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819563/_page_0_Picture_62.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b57e8f7315971f7cba5ed140614f0f961531418d3abdbbf87522b354c2259f9a +size 15802 diff --git a/marker2/court-jane-doe-43/EFTA02819564/EFTA02819564.md b/marker2/court-jane-doe-43/EFTA02819564/EFTA02819564.md new file mode 100644 index 0000000000000000000000000000000000000000..757fd911b043c3a46dc00598e0b05d8ddc2c3d28 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819564/EFTA02819564.md @@ -0,0 +1,33 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff, + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL. LESLEY GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +## ORDER FOR ADMISSION PRO HAC VICE + +The motion of Sigrid S. McCawley to appear Pro Hac Vice in the above-captioned action is granted. + +Applicant has declared that she is a member in good standing of the bar of the State of Florida; and that her contact information is as follows: + +Applicant Name: Sigrid S. McCawley + +Firm Name: Boies, Schiller & Flexner LLP + +Address: 401 East Las Olas Blvd., Suite 1200 + +City / State / Zip: Fort Lauderdale. Florida 33301 + +Telephone / Fax: (954) 356-0011 / (954) 356-0022 + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff Jane Doe 43 in the above entitled action; + +IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. 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McCawley hereby moves this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Plaintiff Jane Doe 43 in the abovecaptioned action. + +I am in good standing of the bar of the State of Florida and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3 + +Dated: February 9, 2017 + +Fort Lauderdale, Florida Respectfully submitted, + +BOLES, SCHILLER & FLEXNER LLP + +/s/ Sigrid S. McCawley + +Sigrid S. McCawley 401 East Las Olas Blvd., Ste. 1200 Fort Lauderdale, Florida 33301 Tel: (954) 356-0011 Fax: (954) 356-0022 Email: smccawley@bstlIp.com + +Attorney for Plaintiff Jane Doe 43 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819565/EFTA02819565.metadata.json b/marker2/court-jane-doe-43/EFTA02819565/EFTA02819565.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..221a2cb9985e811f975eaf57534e326fa7a019ba --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819565/EFTA02819565.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819565.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1187, + "elapsed_seconds": 0.8, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 64.25999999999999, + 67.23 + ], + [ + 289.09381103515625, + 67.23 + ], + [ + 289.09381103515625, + 95.60302734375 + ], + [ + 64.25999999999999, + 95.60302734375 + ] + ] + }, + { + "title": "MOTION FOR ADMISSION \nPRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 373.93199999999996, + 178.2 + ], + [ + 533.1781005859375, + 178.2 + ], + [ + 533.1781005859375, + 206.60302734375 + ], + [ + 373.93199999999996, + 206.60302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 33 + ], + [ + "Text", + 14 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819565" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819566/EFTA02819566.md b/marker2/court-jane-doe-43/EFTA02819566/EFTA02819566.md new file mode 100644 index 0000000000000000000000000000000000000000..6f2b7f7ff5cced9d9c9a9f8c32acd9f0245883f1 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819566/EFTA02819566.md @@ -0,0 +1,37 @@ +USDC SONY DOCUMENT DATE FILED. ...71/4• + +## UNITED STATES DISTRICT COURT ELECTROM'CALLv SOUTHERN DISTRICT OF NEW YORK DOC:: + +JANE DOE 43 + +Plaintiff, + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL LESLEY GROW and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JOK) + +## ORDER FOR ADMISSION PRO HAC VICE + +The motion of Sigrid S. McCawley to appear Pro Hac Vice in the above-captioned action is granted. + +Applicant has declared that she is a member in good standing of the bar of the State of Florida: and that her contact information is as follows: + +Applicant Name: Sigrid S. McCawley + +Firm Name: Boies. Schiller & Hexner LLP + +Address: 401 East Las Olas Blvd.. Suite 1200 + +City / State / Zip: port&I !Kiev:late, Florida 33301 + +Telephone / Fax: (954) 356-0011 / (954) 356-0022 + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff Jane Doe 43 in the above entitled action: + +IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court. including the Rules Governing discipline of attorneys. + +Dated: 04677764O tates District/M4itsait4 Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819566/EFTA02819566.metadata.json b/marker2/court-jane-doe-43/EFTA02819566/EFTA02819566.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..27e1cf0bb0a46bc6f7c3d3a3d789ac867f596c83 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819566/EFTA02819566.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819566.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1288, + "elapsed_seconds": 0.97, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT ELECTROM'CALLv \nSOUTHERN DISTRICT OF NEW YORK DOC::", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 80.434, + 72.08999999999999 + ], + [ + 495.8224182128906, + 72.08999999999999 + ], + [ + 495.8224182128906, + 100.60406494140625 + ], + [ + 80.434, + 100.60406494140625 + ] + ] + }, + { + "title": "ORDER FOR ADMISSION \nPRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 370.856, + 179.01 + ], + [ + 513.304, + 179.01 + ], + [ + 513.304, + 205.22406005859375 + ], + [ + 370.856, + 205.22406005859375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 35 + ], + [ + "Text", + 18 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819566" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819567/EFTA02819567.md b/marker2/court-jane-doe-43/EFTA02819567/EFTA02819567.md new file mode 100644 index 0000000000000000000000000000000000000000..0c3f389b268fef96449cc8f0c029d5ddf5be70da --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819567/EFTA02819567.md @@ -0,0 +1,39 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +USDC SDNV DOCUtviENT ELECTRONICALLY FILED DOC.: \_ r\s/ /17 DATE FILED: + +No. 17 Civ. 00616 (IGK) + +## ORDER FOR ADMISSION PRO HAC VICE + +The motion of Meredith L. to appear Pro Hac Vice in the above-captioned action is granted. + +Applicant has declared that she is a member in good standing of the bar of the State of Florida; and that her contact information is as follows: + +Applicant Name: Meredith L. + +Firm Name: \$oies, Schiller & Flcxner I.LP + +Address: 401 East Las Olas Blvd.. Suite 1200 + +City / State I Zip: Fort Lauderdale. Florida 33301 + +Telephone / Fax: (954) 377-4204 / (954) 356-0022 + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff Jane Doe 43 in the above entitled action; + +IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hat Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules Governing discipline of attorney + +Dated: + +United States DistrictRylatsuo Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819567/EFTA02819567.metadata.json b/marker2/court-jane-doe-43/EFTA02819567/EFTA02819567.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eb7536e6f4b2d6b4259d869939fe9012ccac33f3 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819567/EFTA02819567.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819567.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1271, + "elapsed_seconds": 1.04, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 82.276, + 74.52 + ], + [ + 293.6979064941406, + 74.52 + ], + [ + 293.6979064941406, + 102.2005615234375 + ], + [ + 82.276, + 102.2005615234375 + ] + ] + }, + { + "title": "ORDER FOR ADMISSION \nPRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 372.08399999999995, + 181.44 + ], + [ + 515.6800537109375, + 181.44 + ], + [ + 515.6800537109375, + 208.97406005859375 + ], + [ + 372.08399999999995, + 208.97406005859375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 37 + ], + [ + "Text", + 18 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819567" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819568/EFTA02819568.md b/marker2/court-jane-doe-43/EFTA02819568/EFTA02819568.md new file mode 100644 index 0000000000000000000000000000000000000000..0bf124aa2372e9c7cf66776259173d50e50fc723 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819568/EFTA02819568.md @@ -0,0 +1,32 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +No. 17 Civ. 00616 (JGK) + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +J. hereby declare as follows: + +## AFFIRMATION OF + +J. IN SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE + +- I. I have never been convicted of a felony. +- 2. I have never been censured, suspended, disbarred or denied admission or readmission by any court. +- 3. There are no pending disciplinary proceedings against me in any state or federal court. +- 4. I am a member in good standing of the bar of the State of Florida. + +I hereby declare under penalty of perjury that the foregoing statements are true and correct. + +Dated: February 27, 2017 Fort Lauderdale, Florida Respectfully submitted, + +JAFFE, WEISSING, FISTOS & LEHRMAN, P.L. + +/s/ J. + +J. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: brad@pathtojustice.com \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819568/EFTA02819568.metadata.json b/marker2/court-jane-doe-43/EFTA02819568/EFTA02819568.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8cc9760019f9c650e23e1edb08483a17c414697f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819568/EFTA02819568.metadata.json @@ -0,0 +1,117 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819568.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 958, + "elapsed_seconds": 0.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 63.647999999999996, + 62.37 + ], + [ + 289.09381103515625, + 62.37 + ], + [ + 289.09381103515625, + 90.7330322265625 + ], + [ + 63.647999999999996, + 90.7330322265625 + ] + ] + }, + { + "title": "AFFIRMATION OF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 373.32, + 174.14999999999998 + ], + [ + 488.9171142578125, + 174.14999999999998 + ], + [ + 488.9171142578125, + 188.2330322265625 + ], + [ + 373.32, + 188.2330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 37 + ], + [ + "Text", + 15 + ], + [ + "ListItem", + 4 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819568" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819569/EFTA02819569.md b/marker2/court-jane-doe-43/EFTA02819569/EFTA02819569.md new file mode 100644 index 0000000000000000000000000000000000000000..2a1090274f9d1c651fb465b1c444a6d80f3b591b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819569/EFTA02819569.md @@ -0,0 +1,13 @@ +## upreme (Court of Portba Certificate of oob eitanbing + +I JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that + +JAMES + +was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida on March 8, 2002, is presently in good standing, and that the private and professional character of the attorney appear to be good. + +> WITNESS my hand and the Sea! of the reme Court of Florida at Tallahassee, el% PC1apital, this February 21, 2017. + +![](_page_0_Picture_6.jpeg) + +Clerk of the Supreme Court of Florida. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819569/EFTA02819569.metadata.json b/marker2/court-jane-doe-43/EFTA02819569/EFTA02819569.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3c2e6cbf7c844d8970fc50f9d4c66ae4017caf86 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819569/EFTA02819569.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819569.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 585, + "elapsed_seconds": 0.57, + "image_assets": [ + "_page_0_Picture_6.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "upreme (Court of Portba \nCertificate of oob eitanbing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 115.05599999999998, + 99.98809814453125 + ], + [ + 509.503662109375, + 99.98809814453125 + ], + [ + 509.503662109375, + 181.13385009765625 + ], + [ + 115.05599999999998, + 181.13385009765625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819569" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819569/_page_0_Picture_6.jpeg b/marker2/court-jane-doe-43/EFTA02819569/_page_0_Picture_6.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..6e073d6623ba5b15c3e9645fd17488ba70a591ba --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819569/_page_0_Picture_6.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:590c101265caa8934abbb87470c86b7dac97fb50e9896343fd0c4f3bf94fddfd +size 15340 diff --git a/marker2/court-jane-doe-43/EFTA02819570/EFTA02819570.md b/marker2/court-jane-doe-43/EFTA02819570/EFTA02819570.md new file mode 100644 index 0000000000000000000000000000000000000000..3e4b4cea1184d083bc8acc413542c8896c3b0e1c --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819570/EFTA02819570.md @@ -0,0 +1,33 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff, + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +## ORDER FOR ADMISSION PRO HAC VICE + +The motion of J. to appear Pro Hac Vice in the above-captioned action is granted. + +Applicant has declared that he is a member in good standing of the bar of the State of Florida; and that his contact information is as follows: + +Applicant Name: J. + +Firm Name: =, Jaffe. Weissing, Fistos & Lehrman, P.L + +Address: 425 North Andrews Avenue. Suite 2 + +City / State / Zip: Fort Lauderdale. Florida 33301 + +Telephone / Fax: (954) 524-2820/ (954) 524-2822 + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff Jane Doe 43 in the above entitled action; + +IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. 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I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3 + +Dated: February 27, 2017 Fort Lauderdale, Florida Respectfully submitted, + +JAFFE, WEISSING, F1STOS & LEHRMAN, P.L. + +/s/ + +J. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: brad@pathtojustice.com \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819571/EFTA02819571.metadata.json b/marker2/court-jane-doe-43/EFTA02819571/EFTA02819571.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5c59db1ae732431dd4a9fb4c394d0654dd736563 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819571/EFTA02819571.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819571.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1111, + "elapsed_seconds": 0.8, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 64.25999999999999, + 62.37 + ], + [ + 289.09381103515625, + 62.37 + ], + [ + 289.09381103515625, + 90.7330322265625 + ], + [ + 64.25999999999999, + 90.7330322265625 + ] + ] + }, + { + "title": "MOTION FOR ADMISSION \nPRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 373.93199999999996, + 174.14999999999998 + ], + [ + 532.7816772460938, + 174.14999999999998 + ], + [ + 532.7816772460938, + 201.7330322265625 + ], + [ + 373.93199999999996, + 201.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 34 + ], + [ + "Text", + 14 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819571" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819572/EFTA02819572.md b/marker2/court-jane-doe-43/EFTA02819572/EFTA02819572.md new file mode 100644 index 0000000000000000000000000000000000000000..c1991600eecfd77cfac3d83a0413a689fc99f7c2 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819572/EFTA02819572.md @@ -0,0 +1,34 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff: + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +DECLARATION OF PAUL G. CASSELL SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE + +I, Paul G. Cassell, hereby declare as follows: + +- I. I have never been convicted of a felony. +- 2. I have never been censured, suspended, disbarred or denied admission or readmission by any court. +- 3. There are no pending disciplinary proceedings against me in any state or federal court. +- 4. I am a member in good standing of the bar of the State of Utah. + +I hereby declare under penalty of perjury that the foregoing statements are true and correct. + +Dated: February 27, 2017 + +Salt Lake City, Utah Respectfully submitted, + +/s/ Paul G. Cassell + +Paul G. Cassell S.J. Quinney College of Law at the University Of Utah 383 S. University Street Salt Lake City, Utah 84112i Tel: (801) 858-5202 Fax: (801) 585-2750 Email: cassellp@law.utah.edu Attorney for Plaintiff Jane Doe 43 + +1 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819572/EFTA02819572.metadata.json b/marker2/court-jane-doe-43/EFTA02819572/EFTA02819572.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..98a972d1937ac1db509d3535fe8d95981f7e65da --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819572/EFTA02819572.metadata.json @@ -0,0 +1,98 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819572.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1270, + "elapsed_seconds": 0.82, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 64.25999999999999, + 67.23 + ], + [ + 289.5074768066406, + 67.23 + ], + [ + 289.5074768066406, + 95.2330322265625 + ], + [ + 64.25999999999999, + 95.2330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 39 + ], + [ + "Text", + 13 + ], + [ + "ListItem", + 4 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "Footnote", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819572" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819573/EFTA02819573.md b/marker2/court-jane-doe-43/EFTA02819573/EFTA02819573.md new file mode 100644 index 0000000000000000000000000000000000000000..fd80689890b7b194fc49a26d12803e1bd84964a5 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819573/EFTA02819573.md @@ -0,0 +1,21 @@ +![](_page_0_Picture_1.jpeg) + +## STATE OF UTAH + +## 3ubiciat aepartment + +## attoriiep'5 Certificate + +IN THE SUPREME COURT OF THE STATE OF UTAH + +UNITED STATES OF AMERICA J ss. STATE OF UTAH + +I, Lisa MI Interim Clerk of the Supreme Court of the State of Utah, do hereby certify that by an Order of this Court duly made and entered wherein PAUL G. 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Cassell to appear Pro Ike Vice in the above-captioned action is granted. + +Applicant has declared that he is a member in good standing of the bar of the State of Utah; and that his contact information is as follows: + +Applicant Name: Paul G. Cassell + +Firm Name: S.J. Ouinney College of Law at the University Of Utah + +Address: 383 S. University Street + +City / State / Zip: Salt Lake City. Utah 84112 + +Telephone/ Fax: (801) 858-5202 / (801) 585-2750 + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff Jane Doe 43 in the above entitled action; + +IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hoc Vice in the above captioned case in the United States District Court for the Southern District of New York. 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Cassell hereby moves this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Plaintiff Jane Doe 43 in the abovecaptioned action. + +I am in good standing of the bar of the State of Utah and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3 + +Dated: February 27, 2017 + +Salt Lake City, Utah Respectfully submitted, + +/s/ Paul G. Cassell + +Paul G. Cassell S.J. Quinney College of law at the University Of Utah 383 S. University Street Salt Lake City, Utah 84112i Tel: (801) 858-5202 Fax: (801) 585-2750 Email: cassellp@law.utah.edu Attorney for Plaintiff Jane Doe 43 + +1 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819575/EFTA02819575.metadata.json b/marker2/court-jane-doe-43/EFTA02819575/EFTA02819575.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..62d4646812ced0da3dd6040719fe316f067f9d31 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819575/EFTA02819575.metadata.json @@ -0,0 +1,113 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819575.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1404, + "elapsed_seconds": 0.76, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 64.25999999999999, + 57.50999999999999 + ], + [ + 289.5074768066406, + 57.50999999999999 + ], + [ + 289.5074768066406, + 86.60302734375 + ], + [ + 64.25999999999999, + 86.60302734375 + ] + ] + }, + { + "title": "MOTION FOR ADMISSION \nPRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 373.93199999999996, + 169.29 + ], + [ + 532.7816772460938, + 169.29 + ], + [ + 532.7816772460938, + 197.2330322265625 + ], + [ + 373.93199999999996, + 197.2330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 36 + ], + [ + "Text", + 12 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Footnote", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819575" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819576/EFTA02819576.md b/marker2/court-jane-doe-43/EFTA02819576/EFTA02819576.md new file mode 100644 index 0000000000000000000000000000000000000000..cb51cb12cc7db2f443b5cec92c73a9b76d212c84 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819576/EFTA02819576.md @@ -0,0 +1,60 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +CIVIL ACTION NO.: 17-CV-616 + +vs + +Plaintiff + +JEFFREY EPSTEIN, et al., + +Defendant + +AFFIDAVIT OF SERVICE + +State of New York } +County of New York } ss.: + +The undersigned, being duly sworn, deposes and says; + +Deponent is not a party herein, is over 18 years of age and resides in Sunnyside, New York + +That on 2/9/2017 at 9:40 AM at 9 East 71st Street, New York, NY 10021 + +deponent served a(n) Summons in a Civil Action, Complaint Jury Trial Demanded, Electronic Case Filing Rules & Instructions, Individual Practices of Judge John G. Koeltl + +on Jeffrey Epstein, + +by delivering thereat a true copy of each to Merwin "Doe" (Refused to Give Last Name) (Domestic Help) a person of suitable age and discretion. Said premises is defendant's dwelling place/usual place of abode within the state. + +Within 20 days of such delivery, deponent mailed a copy of same by first class mail in a postpaid envelope properly addressed to defendant at defendant's last known residence at 9 East 71st Street, New York, NY 10021. + +Mailed Copy on 02/09/2017 + +Description of Person Served: + +Gender: Male +Skin: Asian - [REDACTED] Skinned +Hair: Black +Age: 36 - 50 Yrs. +Height: 5' 4" - 5' 8" +Weight: 131-160 Lbs. +Other: + +MILITARY SERVICE: Upon information and belief based upon the conversation(s) and observation(s) as aforesaid deponent avers that the defendant is not in the military service of the State of New York or the United States as that term is defined in the statutes of the State of New York or the Federal Soldiers and Sailors Civil Relief Act. + +Sworn to before me this + +10th day of February, 2017 + +![]()NOTARY PUBLIC +JOHN DICANIO +NOTARY PUBLIC STATE OF NEW YORK +WESTCHESTER COUNTY +LIC. # 01DI4977768 +COMM EXP. 2/11/2019 + +![]() \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819576/EFTA02819576.metadata.json b/marker2/court-jane-doe-43/EFTA02819576/EFTA02819576.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7802379447058fecd5b9102136f26c23ea0208f0 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819576/EFTA02819576.metadata.json @@ -0,0 +1,132 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819576.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1810, + "elapsed_seconds": 8.12, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 26.315999999999995, + 42.12 + ], + [ + 208.692, + 42.12 + ], + [ + 208.692, + 65.61 + ], + [ + 26.315999999999995, + 65.61 + ] + ] + }, + { + "title": "AFFIDAVIT OF SERVICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 225.216, + 201.69 + ], + [ + 378.216, + 201.69 + ], + [ + 378.216, + 214.64999999999998 + ], + [ + 225.216, + 214.64999999999998 + ] + ] + }, + { + "title": "Description of Person Served:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 24.48, + 461.69999999999993 + ], + [ + 159.12, + 461.69999999999993 + ], + [ + 159.12, + 473.03999999999996 + ], + [ + 24.48, + 473.03999999999996 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 94 + ], + [ + "Line", + 46 + ], + [ + "Text", + 44 + ], + [ + "SectionHeader", + 6 + ], + [ + "PageFooter", + 3 + ], + [ + "PageHeader", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819576" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819577/EFTA02819577.md b/marker2/court-jane-doe-43/EFTA02819577/EFTA02819577.md new file mode 100644 index 0000000000000000000000000000000000000000..3828fa724ef26604a0b56addb768f2c8e2d812d0 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819577/EFTA02819577.md @@ -0,0 +1,112 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +No. 17 Civ. 00616 (JGK) + +v. + +JEFFREY EPSTEIN, GH1SLA1NE MAXWELL LESLEY GROFF and NATALYA MALYSHEV + +Defendants. + +#### ORDER FOR ADMISSION PRO MAC VICE + +The motion of J. to appear Pro Hac Vice in the above-captioned action is granted. + +Applicant has declared that he is a member in good standing of the bar of the State of Florida; and that his contact information is as follows: + +Applicant Name: J. + +Firm Name: Jaffe. Weissing. Fistos & Lehrman, P.L + +Address: 425 North Andrews Avenue. Suite 2 + +City / State / Zip: Fort Lauderdale. Florida 33301 + +Telephone / Fax: (954) 524-282W (954) 524-2822 + +Applicant having requested admission Pro Mc Vice to appear for all purposes as counsel for Plaintiff Jane Doe 43 in the above entitled action; + +IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules Governing discipline of attorneys. + +Dated: 3/Q4 + +United tates District/Watt\* Judge + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff, + +v. + +JEFFR T , GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (1OK) + +#### MOTION FOR ADMISSION PRO HAC VICE + +Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, J. hereby moves this Cowl for an Order for admission to practice Pro Hac Vice to appear as counsel for Plaintiff Jane Doe 43 in the abovecaptioned action. + +Iam in good standing of the bar of the State of Pi orida and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3 + +Dated: February 27, 2017 Fort Lauderdale, Florida Respectfully submitted, + +, JAFFE, WEISSING, FISTOS & LEHRMAN, P.L. ) + +Is/ + +J. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: brad@pathtojustice.com + +Attorney for Plaintiff Jane Doe 43 + +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff, + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL LESLEY GROFF and NATALYA + +Defendants. + +I, a 1M hereby declare as follows: + +No. 17 Civ. 00616 (JGK) + +## AFFIRMATION OF mipgi';F\*I=MIN APPLICATION FOR ADMISSION PRO HAC VICE + +- I. I have never been convicted of a felony. +- 2. I have never been censured, suspended, disbarred or denied admission or readmission by any court. +- 3. There are no pending disciplinary proceedings against me in any state or federal court. +- 4. I am a member in good standing of the bar of the State of Florida. + +I hereby declare under penalty of perjury that the foregoing statements are true and correct. + +Dated: February 27, 2017 Fort Lauderdale, Florida Respectfully submitted, + +M IAFFE, WEISSING, FISTOS & LEHRMAN, P.L. + +J. Mirth l i rews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: brad@pathtojustice.com + +Attorney for Plaintiff Jane Doe 43 + +# uprente court ofitoribet Certificate of u oob Otatibing + +1 JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do hireby certify that + +JAMES EDWARDS + +was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida. on March 8, 2002, is presently in good standing, and that the priyale and professional character of the attorney appear. to be good. + +![](_page_3_Picture_7.jpeg) + +WITNESS my hand and the Seal of the reme Court of Florida at Tallahassee, apital, this February 21, 2017. + +Clerk of the Supreme Court of Florida. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819577/EFTA02819577.metadata.json b/marker2/court-jane-doe-43/EFTA02819577/EFTA02819577.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..64f109c97426a59056afaf29e9746b1fe6acbd5a --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819577/EFTA02819577.metadata.json @@ -0,0 +1,352 @@ +{ + "source_pdf": 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a/marker2/court-jane-doe-43/EFTA02819581/EFTA02819581.md b/marker2/court-jane-doe-43/EFTA02819581/EFTA02819581.md new file mode 100644 index 0000000000000000000000000000000000000000..88e4e51511b8cbe5b80f5983bc91980d1d638b41 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819581/EFTA02819581.md @@ -0,0 +1,131 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +*Plaintiff,* + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, +[REDACTED], LESLEY GROFF and +NATALYA [REDACTED] + +*Defendants.* + +No. 17 Civ. 00616 (JGK) + +**ORDER FOR ADMISSION +PRO HAC VICE** + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC# \_\_\_\_\_ +DATE FILED: 3/9/2012 + +The motion of Paul G. Cassell to appear *Pro Hac Vice* in the above-captioned action is granted. + +Applicant has declared that he is a member in good standing of the bar of the State of Utah; and that his contact information is as follows: + +Applicant Name: Paul G. Cassell +Firm Name: S.J. Quinney College of Law at the University Of Utah +Address: 383 S. University Street +City / State / Zip: Salt Lake City, Utah 84112 +Telephone / Fax: (801) 858-5202 / (801) 585-2750 + +Applicant having requested admission *Pro Hac Vice* to appear for all purposes as counsel for Plaintiff Jane Doe 43 in the above entitled action; + +**IT IS HEREBY ORDERED** that the Applicant is admitted to practice *Pro Hac Vice* in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules Governing discipline of attorneys. + +Dated: 3/9/17 + +![]() + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff, + +v. + +JEFFRE TEIN, GHISLAINE MAXWELL, LEY GROFF and NATALY + +Defendants. + +No.17 Civ. 00616 (JGK) + +MOTION FOR ADMISSION PRO HAC VICE + +Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, Paul G. Cassell hereby moves this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Plaintiff Jane Doe 43 in the abovecaptioned action. + +Iam in good standing of the bar of the State of Utah and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. Ihave attached the affidavit pursuant to Local Rule 1.3 + +Dated: February 27, 2017 + +Salt Lake City, Utah Respectfully submitted, + +/s/ Paul G. Cassell + +Paul G. Cassell S.J. Quinney College of Law at the University Of Utah 383 S. University Street Salt Lake City, Utah 84112i Tel: (801) 858-5202 Fax: (801) 585-2750 Email: casscllp®law.utah.edu Attorney for Plaintiff Jane Doe 43 + +This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff + +v. + +IREY EPST IN, GHISLAINE MAXWELL, GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +#### DECLARATION OF PAUL G. CASSELL SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE + +I, Paul G. Cassell, hereby declare as follows: + +- 1. I have never been convicted of a felony. +- 2. I have never been censured, suspended, disbarred or denied admission or readmission by any court. +- 3. There are no pending disciplinary proceedings against me in any state or federal court. +- 4. I am amember in good standing of the bar of the State of Utah. + +Ihereby declare under penalty of perjury that the foregoing statements arc true and correct. + +Dated: February 27, 2017 Salt Lake City, Utah Respectfully submitted, + +/s/ Paul G. Cassell + +Paul G. Cassell S.J. Quinney College of Law at the University Of Utah 383 S. University Street Salt Lake City, Utah 84112' Tel: (801) 858-5202 Fax: (801) 585-2750 Email: cassellp@tlaw.utah.edu Attorney for Plaintiff Jane Doe 43 + +This daytime business addles, is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. + +![](_page_3_Picture_92.jpeg) + +# STATE OF UTAH + +## Judicial Department + +### Attorney's Certificate + +IN THE SUPREME COURT OF THE STATE OF UTAH + +--- + +UNITED STATES OF AMERICA } ss. +STATE OF UTAH + +I, Lisa [REDACTED], Interim Clerk of the Supreme Court of the State of Utah, do hereby certify that by an Order of this Court duly made and entered wherein PAUL G. CASSELL was admitted to practice as an Attorney and Counselor at Law in all the courts of the State of Utah on the 27th day of May, 1992. + +I further certify that this attorney is now, and at all time since admission has been, a member of the Bar of this Court in good standing; and that the private and professional character of this attorney appears to be good. + +![](_page_3_Picture_100.jpeg) + +IN TESTIMONY WHEREOF, I have here unto set my hand and affixed the Seal of said court this 17th day of February, A.D. 2017. + +*Lisa A. 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John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +> Re: Jane Doe 43 v. Jeffery Epstein, et al. Civil Action No. 17-ev-616 + +Dear Judge Koeltl: + +AIDJOviti-1 0 4 Nta C, ?On riecat\_rany • 41 4;30/2/4, + +so oil-064 6Q, + +✓ s 0 + +We represent Jeffrey Epstein and are in the process of being engaged by Lesley Groff in the above-referenced matter. We write this letter jointly on behalf of the plaintiff and Mr. Epstein and Ms. Groff to request an adjournment of the initial case management conference currently scheduled for March 9, 2017 at 4:30 p.m. Subject to the Court's approval, the parties request an adjournment of the conference to April 6, 2017, or to any date thereafter which is convenient to the Court. + +The grounds for seeking this adjournment are as follows. First, we have only just been retained by Mr. Epstein and have noV))'pt formalized our engagement with-Ms. Groff. Second, while service on Mr. Epstein and Ms. Groff' has not yet been cc:irrigated; we have agreed today to accept service on their behalf without prejudice to any defense theY, may have in connection with this lawsuit. Third, the plaintiff.has not yet completed service on any other defendant and needs additional time to do so. FOulth, we need time to familiarize Ourselves with the underlying matter. Finally, the parties malcO this application jointly. + +Under these circumstances, ind for, reasons of efficiency, we request an adjournment of the conference to April 6, 2017;i:or to any other date thereafter wich is convenient for the Court. This is the first time aft): . pariy has requested an adjourtupefit f the conference. + +cc.: Brad Edwards, Esq. + +Michael Miller + +. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC# DATE FILED: -V4/ 2 6 7..?" + +![](_page_1_Picture_1.jpeg) + +BEIJING, CHINA FACSIMILE: 011 86 10 5969 8099 MAIN NUMBER: 011 86 50 6834 1000 + +BRUSSELS, BELGIUM FACSIMILE: 011 322 626 0510 VERIFICATION: 011 322 628 0500 + +CHICAGO, ILLINOIS + +FACSIMILE 312 577 1370 VERIFICATION: 312 577 1300 + +LONDON, ENGLAND FACSIMILE: 011 44 207 367 8001 VERIFICATION: 011 44 207 367 8000 + +1114 AVENUE OF THE AMERICAS NEW YORK, NEW YORK 10036-7703 FACSIMILE: 212 506 3950 + +VERIFICATION: 212 506 3900 MAIN NUMBER: 212 506 3900 wvonteptoe.com + +LOS ANGELES, CALIFORNIA FACSIMILE 213 439 9599 VERIFICATION: 213 439 9400 + +PALO ALTO, CALIFORNIA FACSIMILE: 650 687 9499 VERIFICATION: 850 887 9500 + +PHOENIX, ARIZONA + +FACSIMILE: 602 267 5288 VERIFICATION: 802 267 5287 + +WASHINGTON, DC FACSIMILE: 202 429 3902 VERIFICATION: 202 429 3000 + +IMPORTANT: This facsimile Is Intended only for the use of the Individual or entity to which It Is addressed. It may contain Information that Is privileged, confidential, or otherwise protected from disclosure under applicable law. If the reader of this transmission is not the Intended . recipient or the employee or agent responsible for dowering the trensmbsion to the. Intended recipient, you are hereby notified that any dissemination, distribution, copying or use of this transmission or is contents Is strictly prohibited. If you have received this transmission In error, please notify us by telephonitg and return the original transmission to us at the above address. + +## DELIVER TO: + +NAME: Honorable John G. Koeltl + +COMPANY: + +TOTAL PAGES & COVER SHEET: 2 + +S&J OPERATOR'S NAME: + +• + +## FROM: + +NAME: Michael + +TELECOPY PHONE NUMBER: 212.805-7912 + +VERIFICATION NUMB. + +DATE TRANSMITTED: + +TELEPHONE NUMBER: + +REQUEST MADE ON DATE: 3/8/17 + +COMPLETION REOutywo BY DATE: + +## SPECIAL INSTRUCTIONS: + +343/17 + +TIME: 3:42 PM + +TIME: ASAP \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819585/EFTA02819585.metadata.json b/marker2/court-jane-doe-43/EFTA02819585/EFTA02819585.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4db3593b826ec0041bf236270fff9a23dff378e0 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819585/EFTA02819585.metadata.json @@ -0,0 +1,177 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819585.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3826, + "elapsed_seconds": 1.68, + "image_assets": [ + "_page_0_Picture_3.jpeg", + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "DELIVER TO:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 60.58800000000001, + 344.25 + ], + [ + 146.2042999267578, + 344.25 + ], + [ + 146.2042999267578, + 359.5364685058594 + ], + [ + 60.58800000000001, + 359.5364685058594 + ] + ] + }, + { + "title": "FROM:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 60.58800000000001, + 500.5799999999999 + ], + [ + 107.97050476074219, + 500.5799999999999 + ], + [ + 107.97050476074219, + 515.9164733886719 + ], + [ + 60.58800000000001, + 515.9164733886719 + ] + ] + }, + { + "title": "SPECIAL INSTRUCTIONS:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 60.58800000000001, + 604.9461059570312 + ], + [ + 222.66404724121094, + 604.9461059570312 + ], + [ + 222.66404724121094, + 620.5364685058594 + ], + [ + 60.58800000000001, + 620.5364685058594 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 138 + ], + [ + "Line", + 58 + ], + [ + "Text", + 17 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 119 + ], + [ + "Line", + 56 + ], + [ + "Text", + 30 + ], + [ + "SectionHeader", + 3 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819585" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819585/_page_0_Picture_3.jpeg b/marker2/court-jane-doe-43/EFTA02819585/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..edcea0855e9a6a700179e98d0c9b6024f256fafc --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819585/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:09d1567c31ec3934e85749ddb7f3becf4ff8f9a290a09f136ba803c983877d71 +size 18861 diff --git a/marker2/court-jane-doe-43/EFTA02819585/_page_1_Picture_1.jpeg b/marker2/court-jane-doe-43/EFTA02819585/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..acd0bd8795d8699f3d7c3552b4f76d8850ff2323 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819585/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:74a0abc542239eb51fbc0b50bff1c1c29b40faad0c50d4bf663289a1c604fbc9 +size 4844 diff --git a/marker2/court-jane-doe-43/EFTA02819587/EFTA02819587.md b/marker2/court-jane-doe-43/EFTA02819587/EFTA02819587.md new file mode 100644 index 0000000000000000000000000000000000000000..9923a372271d8ff2442c2dc57ed9dec81aef15c0 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819587/EFTA02819587.md @@ -0,0 +1,53 @@ +## UNITED STATES DISTRICT COURT + +for the + +Southern District of New York + +JANE DOE 43. + +Plaintiff + +v. + +JEFFREY EPSTEIN, et al. + +Defendant + +Case No. 17-CV-0616 (JGK) + +## APPEARANCE OF COUNSEL + +To: The clerk of court and all parties of record + +I am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for: + +named herein as + +Date: Q4105/2017 siAlexInder S. Lorenzo + +Attorney's signature + +Alexander S, Lorenzo + +Proud name and bar number + +Alston & Bird LLP + +90 Park Avenue + +New York, NY 10016 + +Address + +alexander.lorenzo@alston.com + +F.-mail address + +(212) 210-9400 + +Telephone number + +(212) 210-9444 + +FAX number \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819587/EFTA02819587.metadata.json b/marker2/court-jane-doe-43/EFTA02819587/EFTA02819587.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..33e27205d919ee9d2909523839f3b7b8a464d83f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819587/EFTA02819587.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819587.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 649, + "elapsed_seconds": 1.5, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 171.36, + 64.46087646484375 + ], + [ + 435.5910949707031, + 64.46087646484375 + ], + [ + 435.5910949707031, + 86.5482177734375 + ], + [ + 171.36, + 86.5482177734375 + ] + ] + }, + { + "title": "APPEARANCE OF COUNSEL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 225.82799999999997, + 212.22000000000003 + ], + [ + 375.9583435058594, + 212.22000000000003 + ], + [ + 375.9583435058594, + 224.714111328125 + ], + [ + 225.82799999999997, + 224.714111328125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "Text", + 31 + ], + [ + "Line", + 30 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819587" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819588/EFTA02819588.md b/marker2/court-jane-doe-43/EFTA02819588/EFTA02819588.md new file mode 100644 index 0000000000000000000000000000000000000000..879752370250207d441f6fc2a0a2e9919828d439 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819588/EFTA02819588.md @@ -0,0 +1,37 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT NEW YORK + +-----x + +JANE DOE 43, + +17-cv-00616 + +Plaintiff, + +-against- + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, [REDACTED] +[REDACTED] LESLEY GROFF, AND NATALYA [REDACTED] + +Defendant. + +-----x + +**AFFIDAVIT OF JOHN E. STEPHENSON, JR.** + +I, John E. Stephenson, Jr., hereby declare as follows: + +1. I am a partner with the law firm of Alston & Bird LLP. I am admitted to practice law in Georgia. I make this declaration in connection with my motion for admission *pro hac vice* in the above-captioned matter. + +2. I have never been convicted of a felony. + +3. I have never been censured, suspended, disbarred, or denied admission or readmission by any court. + +4. There are no disciplinary proceedings pending against me. + +5. Pursuant to 28 U.S.C § 1746, I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. + +Executed on April 5, 2017 + +![]() \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819588/EFTA02819588.metadata.json b/marker2/court-jane-doe-43/EFTA02819588/EFTA02819588.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..837a7fc25142560f13277664fbd1638bb167ba33 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819588/EFTA02819588.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819588.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 944, + "elapsed_seconds": 4.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "AFFIDAVIT OF JOHN E. 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Stephenson Jr., Esq., was admitted on the 20'h day of February, 1985, as a member of the bar of the Supreme Court of Georgia, the highest court of this State; and, since that date he has been and is now a member of this bar in good standing, as appears from the records and files in this office. + +> Witness my signature and the seal of this Court hereto affixed the day and year first above written. + +![](_page_0_Picture_6.jpeg) \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819589/EFTA02819589.metadata.json b/marker2/court-jane-doe-43/EFTA02819589/EFTA02819589.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..775a979b165966d68791b776aaa19a28c9d0470f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819589/EFTA02819589.metadata.json @@ -0,0 +1,93 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819589.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 581, + "elapsed_seconds": 0.49, + "image_assets": [ + "_page_0_Picture_1.jpeg", + "_page_0_Picture_6.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "$uprente (Court \nState of (Sturgis \nSTATE JUDICIAL BUILDING \ncrktIanta 30334", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 241.74, + 83.42999999999999 + ], + [ + 375.2533264160156, + 83.42999999999999 + ], + [ + 375.2533264160156, + 156.66650390625 + ], + [ + 241.74, + 156.66650390625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 14 + ], + [ + "Text", + 4 + ], + [ + "Picture", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819589" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819589/_page_0_Picture_1.jpeg b/marker2/court-jane-doe-43/EFTA02819589/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1c0f961c6900532341a5f06ca974fb85d4ba0328 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819589/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:661ca4c20c01280b9f77b29aefe6c5f11ab4093c286d9062c3a857829e9b481f +size 2923 diff --git a/marker2/court-jane-doe-43/EFTA02819589/_page_0_Picture_6.jpeg b/marker2/court-jane-doe-43/EFTA02819589/_page_0_Picture_6.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..57a2b08d9585b3f97d28fbe40d9285ba02ba3fdd --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819589/_page_0_Picture_6.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:6c13b16fb92045f198276848d55bc5fa45178fdc7e45efdd0cc23cba37722926 +size 35870 diff --git a/marker2/court-jane-doe-43/EFTA02819590/EFTA02819590.md b/marker2/court-jane-doe-43/EFTA02819590/EFTA02819590.md new file mode 100644 index 0000000000000000000000000000000000000000..0ad7f896f8b1c1a7a500d62f46930edfb25ef782 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819590/EFTA02819590.md @@ -0,0 +1,43 @@ +UNITED STATES DISTRICT COURT SOURTHERN DISTRICT NEW YORK + +I 7-cv-006 I 6 + +JANE DOE 43. + +ORDER FOR ADMISSION Plaintiff, PRO HAC VICE + +-against- + +JEFFREY EPSTEIN, GHISLAINE MAXWEL LESLEY GROFF, AND NATALYka, + +Defendant. + +--------------------- —x + +The Motion of John E. Stephenson, Jr. for admission to practice Pro + +Hac Vice in the above captioned action is granted. + +Applicant has declared that he/she is a member in good standing of the bar(s) of the state(s) of Georgia • and that his/her contact information is as follows + +(please print): + +Applicant's Name: John E. Stephenson, Jr. + +Firm Name: Alston & Bird LLP + +Address: 1201 West Peachtree St, N.W. + +City / State / Zip: Atlanta, Georgia 30309 + +Telephone / Fax: (404) 881-7697 / (404) 881-7777 + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for + +in the above entitled action; + +IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Riles of the Court, including the Rules governing discipline of attorneys. + +Dated: + +United States District/Magistrate Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819590/EFTA02819590.metadata.json b/marker2/court-jane-doe-43/EFTA02819590/EFTA02819590.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e795b287cb8d536f0a317dfa5494ce9b53897a43 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819590/EFTA02819590.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819590.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1238, + "elapsed_seconds": 1.1, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 31 + ], + [ + "Text", + 23 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819590" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819591/EFTA02819591.md b/marker2/court-jane-doe-43/EFTA02819591/EFTA02819591.md new file mode 100644 index 0000000000000000000000000000000000000000..a573cfd225edd5bcaf461509355868ac6730833f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819591/EFTA02819591.md @@ -0,0 +1,33 @@ +Districts of New York, I Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern John E. Stephenson, Jr. hereby moves this Court for an Order for admission to practice Pro Flac Vice to appear as counsel for named herein as in the above-captioned action. + +## UNITED STATES DISTRICT COURT SOURTHERN DISTRICT NEW YORK x + +12-cv-00616 + +JANE DOE 43, + +## MOTION FOR ADMISSION Plaintiff PRO HAC VICE + +-against- + +JEFFREY EPSTEIN, GHISLAINE MAXWELL LESLEY GROFF, AND NATALYA + +Defendant. x + +I am in good standing of the bails) of the state(s) of Georgia and there arc no pending disciplinary proceedings against me in any state or federal court. + +Dated: April 5, 2017 + +Applicant Signature: 1 + +Applicant's Name: + +Firm Name: + +Address: + +Atlanta, Georgia 30309 City / State / Zip: + +Telephone / Fax: (404) 88I-7697 / (404) 881.7777 + +E-Mail: john.stephenwo alston.com \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819591/EFTA02819591.metadata.json b/marker2/court-jane-doe-43/EFTA02819591/EFTA02819591.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fdb2a43dc96b13f35de2dd4eae1f678951bfbd5c --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819591/EFTA02819591.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819591.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 891, + "elapsed_seconds": 0.92, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOURTHERN DISTRICT NEW YORK \nx", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 77.724, + 62.37 + ], + [ + 261.60302734375, + 62.37 + ], + [ + 261.60302734375, + 96.60113525390625 + ], + [ + 77.724, + 96.60113525390625 + ] + ] + }, + { + "title": "MOTION FOR ADMISSION \nPlaintiff PRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 184.32000732421875, + 117.44999999999999 + ], + [ + 484.3214111328125, + 117.44999999999999 + ], + [ + 484.3214111328125, + 140.85113525390625 + ], + [ + 184.32000732421875, + 140.85113525390625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 29 + ], + [ + "Text", + 17 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819591" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819592/EFTA02819592.md b/marker2/court-jane-doe-43/EFTA02819592/EFTA02819592.md new file mode 100644 index 0000000000000000000000000000000000000000..9b3510d298ac9749afc5e889c4e641020d83764e --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819592/EFTA02819592.md @@ -0,0 +1,29 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF AND NATALYA a + +Plaintiff, + +Defendants. + +17 Civ. 616 (JGK) + +## NOTICE OF APPEARANCE + +PLEASE TAKE NOTICE that Michael C. Esq., of Steptoe & LLP, 1114 Avenue of the Americas, New York, New York 10036, hereby enters appearance, as counsel for Defendants Jeffrey Epstein and Lesley Groff, in the above-captioned action. + +I certify that I am admitted to practice in this Court. + +Dated: New York, New York STEPTOE & , LLP April 5, 2017 + +By: s/ Michael C. Michael C. 1114 Avenue of the Americas New York, New York 10036 Tel: (212) 506-3955 Fax: (212) 506-3950 E-mail: mmiller®steptoe.com + +> Counsel for Defendants Jeffrey Epstein and Lesley Groff + +## CERTIFICATE OF SERVICE + +I, Pearl =, hereby certify that on this 5th of April, 2017, I caused a copy of the foregoing Notice of Appearance to be served on all counsel of record via the Court's ECF system. + +> s/ Pearl Pearl \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819592/EFTA02819592.metadata.json b/marker2/court-jane-doe-43/EFTA02819592/EFTA02819592.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0d211e5342df42a502492d03ab99de693e7c4a68 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819592/EFTA02819592.metadata.json @@ -0,0 +1,170 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819592.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 990, + "elapsed_seconds": 0.77, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 293.59381103515625, + 71.28 + ], + [ + 293.59381103515625, + 100.10302734375 + ], + [ + 68.544, + 100.10302734375 + ] + ] + }, + { + "title": "NOTICE OF APPEARANCE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 321.91200000000003, + 196.02 + ], + [ + 480.3057861328125, + 196.02 + ], + [ + 480.3057861328125, + 210.7330322265625 + ], + [ + 321.91200000000003, + 210.7330322265625 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 222.768, + 71.28 + ], + [ + 388.520263671875, + 71.28 + ], + [ + 388.520263671875, + 86.2330322265625 + ], + [ + 222.768, + 86.2330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 28 + ], + [ + "Text", + 12 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 9 + ], + [ + "Text", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819592" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819594/EFTA02819594.md b/marker2/court-jane-doe-43/EFTA02819594/EFTA02819594.md new file mode 100644 index 0000000000000000000000000000000000000000..346af5e68fe2a512285a33fc6789dd0992737c52 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819594/EFTA02819594.md @@ -0,0 +1,31 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF AND NATALYA + +Plaintiff, + +Defendants. + +17 Civ. 616 (JGK) + +## NOTICE OF APPEARANCE + +PLEASE TAKE NOTICE that Justin Y.K. MI, Esq., of Steptoe & LLP, 1114 Avenue of the Americas, New York, New York 10036, hereby enters appearance, as counsel for Defendants Jeffrey Epstein and Lesley Groff, in the above-captioned action. + +I certify that I am admitted to practice in this Court. + +Dated: New York, New York STEPTOE & LLP April 5, 2017 + +By: s/ Justin Y.K Justin Y.K. 1114 Avenue of the Americas New York, New York 10036 Tel: (212) 378-7616 Fax: (212) 506-3950 E-mail: jchu@steptoe.com + +> Counsel for Defendants Jeffrey Epstein and Lesley Groff + +## CERTIFICATE OF SERVICE + +I, Pearl =, hereby certify that on this 5th of April, 2017, I caused a copy of the foregoing Notice of Appearance to be served on all counsel of record via the Court's ECF system. + +s/ Pearl + +Pearl \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819594/EFTA02819594.metadata.json b/marker2/court-jane-doe-43/EFTA02819594/EFTA02819594.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2b7380b0cc54f25de18a6957a7aea83f1e5486ca --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819594/EFTA02819594.metadata.json @@ -0,0 +1,193 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819594.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 988, + "elapsed_seconds": 0.76, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 293.59381103515625, + 71.28 + ], + [ + 293.59381103515625, + 100.10302734375 + ], + [ + 68.544, + 100.10302734375 + ] + ] + }, + { + "title": "NOTICE OF APPEARANCE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 321.91200000000003, + 196.02 + ], + [ + 480.3057861328125, + 196.02 + ], + [ + 480.3057861328125, + 210.7330322265625 + ], + [ + 321.91200000000003, + 210.7330322265625 + ] + ] + }, + { + "title": "", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 321.91200000000003, + 444.69000000000005 + ], + [ + 484.092, + 444.69000000000005 + ], + [ + 484.092, + 457.65 + ], + [ + 321.91200000000003, + 457.65 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 222.15599999999998, + 84.24 + ], + [ + 388.520263671875, + 84.24 + ], + [ + 388.520263671875, + 100.10302734375 + ], + [ + 222.15599999999998, + 100.10302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 28 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 3 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 9 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819594" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819596/EFTA02819596.md b/marker2/court-jane-doe-43/EFTA02819596/EFTA02819596.md new file mode 100644 index 0000000000000000000000000000000000000000..3424026eb05c4604a6993b1ce16869ee6593c523 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819596/EFTA02819596.md @@ -0,0 +1,91 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +Plaintiff, vs. + +JEFFREY EPSTEIN, GIIISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +Defendants. + +CASE NO. 17 Civ 616 (JGK) + +JOINT RULE 26(O REPORT + +Complaint filed: January 26, 2017 + +Hon. John G. Koeltl + +Plaintiff, Doe 43, and Defendants, Jeffrey Epstein ("Epstein"), Lesley Groff ("Groff"), and (a') (collectively, "Defendants"), through their respective undersigned counsel, and pursuant to Rule 26(f) and Rule 16(b) of the Federal Rules of Civil Procedure and this Court's Order, have conferred and file their Joint Rule 26(f) Report and Discovery Plan ("Report & Plan"). + +#### 1. Joint rule 26(f) report + +#### a. Rule 26(O(2) - Synopsis, nature and basis of claims/defenses: + +#### Plaintiff's Statement + +Plaintiff alleges that between September 2006 and April 2007, Defendants committed tortious violations of 18 USC §1595, by knowingly recruiting, enticing, harboring, transporting, soliciting, threatening, forcing or coercing Plaintiff to engage in commercial sex acts. Plaintiff contends that Defendants' actions were undertaken with knowledge or reckless disregard for the fact that their threats of force, fraud, coercion, and combinations of such means would be used, and were in fact used, in order to cause Plaintiff to engage in commercial sex acts, in violation of 18 USC §159I through §1594 and are actionable civilly pursuant to 18 USC § 1595. + +### Epstein, Groff, and IMIStatement + +Defendants assert that the Complaint is factually and legally infirm and should be dismissed. Specifically, the claims in the Complaint fail to state a claim on which relief may be granted and are, in any event, barred by the statute of limitations. + +## b. Possibilities for Prompt Settlement: + +The parties have conferred and agree there is not a likelihood for prompt settlement. + +#### c. Timine of Rule 26(a)(1) disclosures: + +Plaintiff states that initial disclosures should be made by April 20, 2017. + +Defendants object to conducting discovery during the pendency of their motions to dismiss. Defendants anticipate moving to dismiss the Complaint on grounds including those discussed above. + +## d. Preservation of Evidence: + +Plaintiff requests Defendants to preserve all documentation or electronically stored or transmitted information that in any way relates to Plaintiff, or to Defendants' properties or aircraft or employees. + +Defendants request Plaintiff to preserve all evidence relevant to the allegations, her claim and the potential subjects of discovery discussed below, and object to the overly broad nature of Plaintiff's preservation request. + +# Rule 260)(3) Discovery Plan & Experts + +(A) Plaintiff's Statement -- Discovery will be taken on at least the following subjects: whether Plaintiff communicated with Defendants and if so the extent and specifics of that communication; whether and to what extent Plaintiff and Defendants interacted as alleged in the complaint; Defendants purpose for communicating or interacting with Plaintiff; the relationship, if any, between Defendants and any others relevant to prove allegations in the + +complaint; motive and common scheme or plan of Defendants and all issues related to compensatory and punitive damages. Discovery should be completed by September 22, 2017. There is no need for discovery to be conducted in phases. + +Eosin Groff Statement Defendants object to conducting discovery during the pendency of their motions to dismiss. Defendants anticipate moving to dismiss the Complaint on grounds including those discussed above In the event that the case proceeds, discovery will be conducted on at least the following additional subjects: whether there is a factual basis for plaintiff's assertion of violation of 18 USC §1591 through §1594; whether Plaintiff, an adult, engaged in consensual sexual relations, and not commercial sexual acts as alleged in her Complaint; Plaintiff's purposes in travelling to the United States of her own volition, her alleged meetings and other interaction with Defendants after she arrived in the United States, and her departure from the United States of her volition; Plaintiff's record of employment, means of support, traveling, whereabouts and living arrangement during the relevant time; Plaintiff's immigration status and her alleged efforts to gain entrance to the Fashion Institute of Technology or any other similar institutions; the alleged coercion, fraud, and threatened harm; all other factual issues pertaining to Plaintiff's Complaint. Discovery may need to be conducted in phases. In particular, discovery concerning punitive damages should not be conducted until there is a verdict of liability. + +(B)The parties shall maintain and not alter or destroy any electronically stored information relevant to this action. (C)Plaintiff states that there are no anticipated accommodations necessary regarding protections of privileged and trial preparation materials. As documents and information are exchanged the parties will discuss any necessary confidential materials in need of protection and attempt to reach agreement before involving the Court. + +(D)Due to the nature of the claim, the Plaintiff has proceeded anonymously through a pseudonym. It is anticipated by Plaintiff that other non-parties will be called to testify about observations made regarding the activities in question; to the extent those anticipated witnesses were themselves alleged to have been victims similarly situated to Plaintiff, Plaintiff requests the identities of those persons be maintained confidentially and not publicly disclosed. Defendants reserve the right to challenge the Plaintiff's efforts to proceed with this matter without disclosing her identity and the identities of others providing evidence on her behalf. + +(E)There are no other requested orders to be issued at this time. + +Dated: April 5, 2017 + +Dated: April 5, 2017 + +Respectfully submitted, + +M AFFE, WEISSING, FISTOS & LEHRMAN, P.L. + +By /s/ Brad Brad Attorney for Plaintiff Jane Doe 43 + +STEPTOE & , LLP + +By /s/ Michael C. Justin Y.K. Attorneys for Defendants JEFFREY EPSTEIN & LESLEY GROFF + +Dated: April 5, 2017 ALSTON & BIRD, LLP + +By /s/ + +Alexander S Lorenzo + +John E. 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LESLEY GROW, AND NATALYA MALYSHEV, + +Defendant. + +The Motion of John E. Stephenson, Jr. for admission to practice Pro + +## ORDER FOR ADMISSION PRO HAC VICE + +USDC SONY DOCUMENT EL, -.:1RONICALLY FILED DOW' DATE FILED: 144-17 + +Hac Vice in the above captioned action is granted. + +Applicant has declared that he/she is a member in good standing of the bar(s) of the state(s) of + +Georgia ; and that his/her contact information is as follows + +(please print): + +Applicant's Name: John E. Stephenson, Jr. + +Firm Name: Alston & Bird LLP + +Address: 1201 West Peachtree St, N.W. + +City / State / Zip: Atlanta, Georgia 30309 + +Telephone / Fax: (404) 881.7697 / (404) 881-7777 + +Applicant having requested admission Pro I lac Vice to appear for all purposes as counsel for + +in the above entitled action; + +IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Souther District of New York All attorneys appearing before this Court are subject to the Local Riles of the Court, including the Rules governing discipline of attorneys. + +Dated: + +U States Z l 'L6 (182t e stnct/fvflpectate Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819601/EFTA02819601.metadata.json b/marker2/court-jane-doe-43/EFTA02819601/EFTA02819601.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b1cd3c29e63bb4bb43d8d9425fd89029515560c6 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819601/EFTA02819601.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819601.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1299, + "elapsed_seconds": 1.14, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "ORDER FOR ADMISSION \nPRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 375.154, + 131.22 + ], + [ + 493.6173400878906, + 131.22 + ], + [ + 493.6173400878906, + 154.8446044921875 + ], + [ + 375.154, + 154.8446044921875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 100 + ], + [ + "Line", + 41 + ], + [ + "Text", + 25 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819601" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819602/EFTA02819602.md b/marker2/court-jane-doe-43/EFTA02819602/EFTA02819602.md new file mode 100644 index 0000000000000000000000000000000000000000..c8e1e48f03b53ee6a97902d8290cae6c3a0f8dff --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819602/EFTA02819602.md @@ -0,0 +1,41 @@ +UNITED STATES DISTRICT COURT SOURTHERN DISTRICT NEW YORK + +JANE DOE 43, + +-against- + +USOC SONY DOCUMENT ELECel:ZON'CALLY FILED DOCU DATE FILED: - 7:1-1 + +17-cv-006I 6 + +ORDER FOR ADMISSION Plaintiff, PRO HAC VICE + +JEFFREY EPSTEIN, GHISLAINE MAXWEL LESLEY GROFF, AND NATALYAla + +Defendant + +The Motion of John E Stephenson, Jr. for admission to practice Pro + +Hac Vice in the above captioned action is granted. + +Applicant has declared that he/she is a member in good standing of the bar(s) of the statc(s) of Georgia ; and that his/her contact information is as follows + +(please print): + +Applicant's Name: John E. Stephenson. Jr. + +Aston & LLP Firm Name: + +Address: 1201 West Peachtree St. N.W. + +City / State / Zip: Atlanta, Georgia 30309 + +Telephone / Fax: (404) 881-7897 / (404) 881.7777 + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for in the above entitled action; + +IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Riles of the Court, including the Rules governing discipline of attorneys. + +Dated: (/ 7/ 1 7 • + +United States District/Mai/Locate...Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819602/EFTA02819602.metadata.json b/marker2/court-jane-doe-43/EFTA02819602/EFTA02819602.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bba09482e5b31888848786fd01e6b4e751933187 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819602/EFTA02819602.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819602.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1283, + "elapsed_seconds": 1.03, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 93 + ], + [ + "Line", + 36 + ], + [ + "Text", + 22 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819602" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819603/EFTA02819603.md b/marker2/court-jane-doe-43/EFTA02819603/EFTA02819603.md new file mode 100644 index 0000000000000000000000000000000000000000..0d94c538f612db33aab1e17f81df21d29b3afa7a --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819603/EFTA02819603.md @@ -0,0 +1,27 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +Plaintiff(s), + +## NOTICE OF COURT CONFERENCE -against- (AMENDED) + +EPSTEIN, 17 civ 616 (,IGK) + +Defendant(s). + +X + +To All Parties, + +You are directed to appear for a pretrial conference, to be held on Monday, May 22, + +2017, in Courtroom 12B, at 4:30pm in front of the Honorable John G. Koeltl. + +MI requests for adjournments must be made in writing to the Court. + +For any further information, please contact the Court at (212) 805-0107. + +Dated: New York, New York April 28, 2017 + +![](_page_0_Picture_18.jpeg) \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819603/EFTA02819603.metadata.json b/marker2/court-jane-doe-43/EFTA02819603/EFTA02819603.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1b07d8e2b0ed1b60aedf1d6405bf61fc7721a03d --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819603/EFTA02819603.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819603.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 577, + "elapsed_seconds": 0.88, + "image_assets": [ + "_page_0_Picture_18.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "NOTICE OF COURT CONFERENCE \n-against- (AMENDED)", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 149.11001586914062, + 144.99 + ], + [ + 547.8702392578125, + 144.99 + ], + [ + 547.8702392578125, + 173.73248291015625 + ], + [ + 149.11001586914062, + 173.73248291015625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 27 + ], + [ + "Text", + 16 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819603" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819603/_page_0_Picture_18.jpeg b/marker2/court-jane-doe-43/EFTA02819603/_page_0_Picture_18.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b45e6abc786239862b82c11f58049c73f25f9ecb --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819603/_page_0_Picture_18.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d9a6832a3b63f0971d0f0fa20b6c972c19bb066a4a101c86e69c65c5da75f245 +size 18627 diff --git a/marker2/court-jane-doe-43/EFTA02819604/EFTA02819604.md b/marker2/court-jane-doe-43/EFTA02819604/EFTA02819604.md new file mode 100644 index 0000000000000000000000000000000000000000..b3272c46db2f151ab267bd7f7c4a62d89961f3be --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819604/EFTA02819604.md @@ -0,0 +1,39 @@ +![](_page_0_Picture_21.jpeg) + +[REDACTED] Jaffe, Weissing, +, Fistos & Lehrman, P.L. + +[REDACTED] J. [REDACTED] +brad@patbtojustice.com + +May 11, 2017 +Via Fax: 212-805-7921 +12 + +Honorable John G. Koeltl +Daniel [REDACTED] Moynihan +United States Courthouse +500 Pearl Street +New York, NY 10007-1312 + +*Delete Docket Entry 32 +as well as CPF. +so ordered. +Sr G/add +WSD.S.* + +RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, et. Al +Case No. No. 17 Civ. 00616 (JGK) + +Dear Judge Koeltl: + +Please accept this correspondence as Plaintiff's request that DE 32 Motion For Extension Of Time To Effectuate Service On Defendant Ghislaine Maxwell, be immediately sealed or in the alternative stricken from the docket as to allow Plaintiff to properly file a redacted version. Plaintiff's counsel inadvertently failed to seal and redact the Motion and Proposed Order prior to filing. As the court is aware the identity of plaintiff is highly confidential, as is the information contained in Plaintiff's Motion for Extension of Time. Plaintiff's counsel apologizes for any inconvenience that this causes the court and appreciates immediate attention to this matter. + +Very Truly Yours, + +[REDACTED], JAFFE, WEISSING, [REDACTED], FISTOS and LEHRMAN, PL + +Bradley J. Edwards +BJE:mwk + +[REDACTED] \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819604/EFTA02819604.metadata.json b/marker2/court-jane-doe-43/EFTA02819604/EFTA02819604.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4b1e0e1a229e1b1b8aadfb3e961c89e8a4ee1cee --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819604/EFTA02819604.metadata.json @@ -0,0 +1,56 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819604.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1295, + "elapsed_seconds": 5.75, + "image_assets": [ + "_page_0_Picture_21.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": 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undersigned counsel, stipulate to the following schedule: + +Civil Action No. 17 Civ. 616 (JGK) + +## STIPULATION AND IPROPOSEDI ORDER + +- 1. May 15, 2017 Defendants serve letters on Plaintiff setting forth their view on the insufficiency of the complaint; +- 2. June 5, 2017 Plaintiff files an amended complaint or stands on her complaint; +- 3. If Plaintiff stands on her complaint: + - a. June 19, 2017 Defendants move to dismiss; + - b. July 19, 2017 Plaintiff responds to motion to dismiss; and + - c. August 2, 2017 Defendants reply to Plaintiff's response. +- 4. If Plaintiff files an amended complaint: + - a. June 26, 2017 Defendants move to dismiss; + - b. July 26, 2017 Plaintiff response to motion to dismiss; and + - c. August 9, 2017 Defendants reply to Plaintiff's response. + +RESPECTFULLY SUBMITTED, + +Dated: May 12, 2017 G + +AFFE, WEISSING, FIS'FOS & LEHRMAN, P.L. + +By: gad elat 64 /PP Brad wards + +BOLES, SCHILLER & FLEXNER LLP + +By: Sigrid cCawley + +Attorneys for Plaintiff Jane Doe 43 + +Dated: May 12, 2017 STEPTOE & LLP + +Dated: May 12, 2017 + +SO ORDERED: + +U.S.D.J. + +By: Michael C. Justin Y.K. d X111,O7 + +> Attorneys for Defendants JEFFREY EPSTEIN & LESLEY GROFF + +ALSTON & BIRD, LLP + +By: "doeit.414.. d ieurver Alexander S Lorenzo John E. Stephenson, Jr. (Application for admission pro hac vice pending) + +Attorneys for Defendant \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819610/EFTA02819610.metadata.json b/marker2/court-jane-doe-43/EFTA02819610/EFTA02819610.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fc60b12f440e40463acd78b7814f368fa929aa40 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819610/EFTA02819610.metadata.json @@ -0,0 +1,208 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819610.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 1668, + "elapsed_seconds": 0.97, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "EXHIBIT A", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 170.13600000000002, + 281.3393249511719 + ], + [ + 451.1135559082031, + 281.3393249511719 + ], + [ + 451.1135559082031, + 334.1731262207031 + ], + [ + 170.13600000000002, + 334.1731262207031 + ] + ] + }, + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 68.544, + 73.71000000000001 + ], + [ + 294.2764892578125, + 73.71000000000001 + ], + [ + 294.2764892578125, + 101.9830322265625 + ], + [ + 68.544, + 101.9830322265625 + ] + ] + }, + { + "title": "STIPULATION AND \nIPROPOSEDI ORDER", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 334.764, + 183.06 + ], + [ + 461.6178894042969, + 183.06 + ], + [ + 461.6178894042969, + 210.7330322265625 + ], + [ + 334.764, + 210.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 3 + ], + [ + "Line", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 29 + ], + [ + "ListItem", + 10 + ], + [ + "Text", + 7 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 30 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819610" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819613/EFTA02819613.md b/marker2/court-jane-doe-43/EFTA02819613/EFTA02819613.md new file mode 100644 index 0000000000000000000000000000000000000000..a5a8f6359d37dbf4e5a9f9edc4fa817e21371abd --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819613/EFTA02819613.md @@ -0,0 +1,21 @@ +Michael C. MI 212 506 3955 mmiller@steptoe.com + +1114 Avenue of the Americas New York, NY 10036 212 506 3900 main www.steptoe.com + +May 12. 2017 + +## VIA ECF + +Honorable John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +Re: Jane Doe 43 v. Jeffery Epstein, et al.; Civil Action No. 17 Civ. 616 (JGK) + +![](_page_0_Picture_3.jpeg) + +Dear Judge Koeltl: + +In accordance with your directives set forth at the initial case management conference on April 6, 2017, the Plaintiff and Defendants Epstein, Groff and have stipulated to the following schedule concerning letters and potential motion practice directed at the Complaint. The parties respectfully request Your Honor to So-Order the Stipulation and [Proposed] Order annexed hereto as Exhibit A. + +Respectfully submitted, ..4.1c a/ Michael C. + +Counsel for Defendants Jeffrey Epstein and Lesley Groff \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819613/EFTA02819613.metadata.json b/marker2/court-jane-doe-43/EFTA02819613/EFTA02819613.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..171125a6ad1ca393621f64e5c3e845b4fd21955a --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819613/EFTA02819613.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819613.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 901, 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[REDACTED] + +*Defendants.* + +PROPOSED ORDER GRANTING MOTION FOR EXTENSION OF TIME TO +EFFECTUATE SERVICE ON DEFENDANT GHISLAINE MAXWELL + +Plaintiff's Motion for Extension of Time to Effectuate Service on Defendant Ghislaine Maxwell is granted. + +IT IS HEREBY ORDERED that Plaintiff shall have an additional pincty (90) days to serve Defendant Maxwell. + +Dated: 5/12/17 + +[Signature] +United States District/Magistrate Judge + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC# \_\_\_\_\_ +DATE FILED: 5/15/17 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819614/EFTA02819614.metadata.json b/marker2/court-jane-doe-43/EFTA02819614/EFTA02819614.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..153bc2fadb930c33139532dd44068efc390df66b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819614/EFTA02819614.metadata.json @@ -0,0 +1,101 @@ +{ + "source_pdf": 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EPSTEIN GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +and Plaintiff, Doe 43, and Defendants, Jeffrey Epstein ("Epstein"), Lesley Groff ("Groff), ("=") (collectively, "Defendants"), through their respective undersigned counsel, stipulate to the following schedule: + +USDC SDNY DOCUMENT ELEC TRONICALLv FILED DOC# DATE FILED: Ai:152i + +Civil Action No. 17 Civ. 616 (JGK) + +STIPULATION AND [PROPOSED] ORDER + +- I. May 15, 20I7 Defendants serve letters on Plaintiff setting forth their view on the insufficiency of the complaint; +- 2. June 5, 2017 Plaintiff files an amended complaint or stands on her complaint; +- 3. If Plaintiff stands on her complaint: + - a. June 19, 2017 Defendants move to dismiss; + - b. July 19, 2017 Plaintiff responds to motion to dismiss; and + - c. August 2, 2017 Defendants reply to Plaintiff's response. +- 4. If Plaintiff files an amended complaint: + - a. June 26, 2017 Defendants move to dismiss; + - b. July 26, 2017 Plaintiff response to motion to dismiss; and + - c. August 9, 2017 Defendants reply to Plaintiff's response. + +RESPECTFULLY SUBMITTED, + +Dated: May 12, 2017 + +[REDACTED] JAFFE, WEISSING, +[REDACTED], FISTOS & LEHRMAN, P.L. + +By: Brad Edwards / PP +Brad Edwards + +BOIES, SCHILLER & FLEXNER LLP + +By: Signed S. McCawley / PP +Signed S. McCawley + +*Attorneys for Plaintiff Jane Doe 43* + +Dated: May 12, 2017 + +STEPTOE & [REDACTED], LLP + +By: Michael C. Philler / PP +Michael C. +Justin Y.K. + +*Attorneys for Defendants +JEFFREY EPSTEIN & LESLEY GROFF* + +Dated: May 12, 2017 + +ALSTON & BIRD, LLP + +By: Alexander S Lorenzo / PP +Alexander S Lorenzo +John E. Stephenson, Jr. +(Application for admission +pro hac vice pending) + +*Attorneys for Defendant* [REDACTED] + +SO ORDERED: + +Jr 6/6/17 +U.S.D.J. +5/15/17 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819615/EFTA02819615.metadata.json b/marker2/court-jane-doe-43/EFTA02819615/EFTA02819615.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f0452a451632121cb94ce3f22914dc8b77c16589 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819615/EFTA02819615.metadata.json @@ -0,0 +1,128 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819615.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1812, + "elapsed_seconds": 4.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 85.96000000000001, + 72.9 + ], + [ + 297.78999999999996, + 72.9 + ], + [ + 297.78999999999996, + 101.478515625 + ], + [ + 85.96000000000001, + 101.478515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 30 + ], + [ + "ListItem", + 10 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Text", + 34 + ], + [ + "Line", + 23 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819615" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819617/EFTA02819617.md b/marker2/court-jane-doe-43/EFTA02819617/EFTA02819617.md new file mode 100644 index 0000000000000000000000000000000000000000..8e54a6ac7bfc0cd8f1ccf10ad48d55e88173e88e --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819617/EFTA02819617.md @@ -0,0 +1,33 @@ +![](_page_0_Picture_1.jpeg) + +u nal Injryu + +Sex Abuse + +Yemeni Death + +WhIstletiower Crates + +WWW.PATHTOJUSTICE.COM + +Staffe, Weissing, Fistos a Lehrman, P.L. + +> J. brad@pathtojustice.com + +May 17, 2017 + +Honorable John G. Koeltl Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, et. Al Case No. No. 17 Civ. 00616 (JGK) + +Dear Judge Koeltl: + +This is a letter motion requesting permission for Plaintiff to telephonically appear for the pretrial conference, currently scheduled for Monday, May 22, 2017, at 4:30pm. Thank you very much for your time and consideration. + +1.111d JYours, + +A WEISSING, FISTOS and LEHRMAN, PL + +J. BJE:mwk + +J. 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[REDACTED] +brad@pathtojustice.com + +May 17, 2017 + +Honorable John G. Koeltl +Daniel [REDACTED] Moynuhan +United States Courthouse +500 Pearl Street +New York, NY 10007-1312 + +RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, et. Al +Case No. No. 17 Civ. 00616 (JGK) + +Dear Judge Koeltl: + +This is a letter motion requesting permission for Plaintiff to telephonically appear for the pretrial conference, currently scheduled for Monday, May 22, 2017, at 4:30pm. Thank you very much for your time and consideration. + +Very Truly Yours, +[REDACTED] JAFFE, WEISSING, [REDACTED], FISTOS and LEHRMAN, PL + +[REDACTED] J. Edwards + +[REDACTED] J. [REDACTED] +BJE:mwk + +CONFERENCE ADJOURNED TO +FRIDAY, JUNE 2, 2017, AT 11:30AM. +THE PANFILES CAN APPEAR TELEPHONICALLY. + +SO ORDERED. +[Signature] +5/17/17 VSOJ + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC# +DATE FILED: 5/18/17 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819618/EFTA02819618.metadata.json b/marker2/court-jane-doe-43/EFTA02819618/EFTA02819618.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4cc6a48b2745e2b2bb005b9a4f90946b7c2ff465 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819618/EFTA02819618.metadata.json @@ -0,0 +1,56 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819618.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 991, + "elapsed_seconds": 5.19, + "image_assets": [ + "_page_0_Picture_18.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 27 + ], + [ + "PageFooter", + 3 + ], + [ + "PageHeader", + 2 + ], + [ + "Picture", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819618" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819618/_page_0_Picture_18.jpeg b/marker2/court-jane-doe-43/EFTA02819618/_page_0_Picture_18.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..94c7cfbdfb8c08488fae04c0df43b79eea3a7bab --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819618/_page_0_Picture_18.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:62f4d98d7a84a7596452a3281720df41bdf5cc4d1fe8f70c58961b38d70a804f +size 19616 diff --git a/marker2/court-jane-doe-43/EFTA02819619/EFTA02819619.md b/marker2/court-jane-doe-43/EFTA02819619/EFTA02819619.md new file mode 100644 index 0000000000000000000000000000000000000000..0d487973cb397b526d6095df2af4d624ee480ea3 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819619/EFTA02819619.md @@ -0,0 +1,31 @@ +Michael C 212 506 3955 mmiller©steptoe.com + +1114 Avenue of the Americas New York, NY 10036 212 506 3900 main www.steptoe.com + +May 18, 2017 + +## VIA ECF + +Hon. John G. Koehl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 + +Dear Judge Koeltl: + +![](_page_0_Picture_3.jpeg) + +We are counsel to Defendants Jeffrey Epstein ("Epstein") and Lesley Groff ("Groff') in the above-referenced matter. We write to request that the conference with the Court currently scheduled for June 2, 2017 be ad\* m for the reasons set forth below. We have been advised by counsel for Defendant that she joins in this application. + +By way of background, on May 15, 2017, Defendants Epstein and Groff served a letter on counsel for the Plaintiff identifying the many fundamental bases which exist for dismissing the Plaintiff's Complaint. On the same day, Defendant served a letter on counsel for the Plaintiff identifying additional grounds for dismissing the Complaint. These letters were served pursuant to the schedule set forth in the Court's May 15, 2017 Stipulation and Order ("Scheduling Order"). + +After receiving these letters, counsel for Plaintiff advised the undersigned that Plaintiff is likely to amend her Complaint, instead of standing on the Complaint. Pursuant to the Scheduling Order, Plaintiff will have until June 5, 2017 to file an amended complaint. Defendants will have until June 19, 2017 to move to dismiss the amended complaint, and briefing on the motions to dismiss will be completed by August 2, 2017. + +In light of the Court's issuance of the Scheduling Order and Plaintiff's obligation to serve an amended complaint on or before June 5, 2017, we respectfully request that the conference Hon. John G. Koeltl May 18, 2017 Page 2 + +![](_page_1_Picture_2.jpeg) + +scheduled for June 2, 2017 be adjourned until after Plaintiff has served her amended complaint and preferably until briefing on the motions to dismiss has been completed. We respectfully believe that adjourning the conference until such time would make practical sense. + +Respectfully submitted, + +Michael C. 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Koeltl Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, et. Al Case No. No. 17 Civ. 00616 (JGK) + +Dear Judge Koeltl: + +We are counsel for Jane Doe 43 in the above referenced matter and we write in response to the letter submitted by Defendants on May 18, 2017 requesting an adjournment of the June 2, 2017 hearing. Defendants ignored your individual practice rules and failed to set forth Plaintiffs position that she objects to any further delay of this hearing. + +From the initial Rule 26(f) conferral, Plaintiff and Defendants have had one fundamental disagreement in need of immediate resolution. Plaintiff desires to exchange Rule 26 disclosures immediately and begin discovery, while Defendant refuses to do so and insists on doing nothing until the Motion to Dismiss is fully briefed and the Court rules on it. Plaintiff recently communicated with Defendants' counsel on May 16, 2017, her desire to proceed with the scheduled hearing and raise with the Court that both parties should be required to submit their Rule 26 disclosures without further delay and proceed with discovery. + +Defendants are taking the position that the hearing should be adjourned and Defendants should not be required to exchange their Rule 26 disclosures or otherwise participate in discovery until the Court has resolved the Motion to Dismiss, which according to the briefing schedule will delay even basic disclosures in this case for months. Defendants cannot unilaterally decide against + +May 19, 2017 + +Page 2 + +exchanging Rule 26 disclosures and effectively grant themselves a stay by seeking to adjourn the June 2, 2017 hearing; however, that is exactly what they have done. + +Plaintiff respectfully requests that the Court proceed with the June 2, 2017 hearing at which time Defendants' efforts at delay can be properly addressed. + +Ve Trul Yours, + +JAFFE, WEISSING, , FISTOS and LEHRMAN, PL + +J. 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[REDACTED] +212 506 3955 +mmillar@steptoe.com + +1114 Avenue of the Americas +New York, NY 10036 +212 506 3900 main +www.steptoe.com + +Steptoe + +| USDS SONY | +|------------------------------| +| DOCUMENT | +| ELECTRONICALLY FILED | +| DOC #: _____ | +| DATE FILED: 5/19/2017 | + +May 18, 2017 + +ADJOURNED TO FINAL DATE, +JULY 6, 2017, AT 4:30PM, +SO UNDERLINED. + +**VIA ECF** +Hon. John G. [REDACTED] +United States District Court +United States Courthouse +500 Pearl Street +New York, NY 10007-1312 + +5/18/17 [Signature] 6/6/2008 +USOJ + +Re: **Jane Doe 43 v. Jeffrey Epstein, et al.** +**Civil Action No. 17-cv-616** + +Dear Judge Koeltl: + +We are counsel to Defendants Jeffrey Epstein ("Epstein") and Lesley Groff ("Groff") in the above-referenced matter. We write to request that the conference with the Court currently scheduled for June 2, 2017 be adjourned for the reasons set forth below. We have been advised by counsel for Defendant [REDACTED] that she joins in this application. + +By way of background, on May 15, 2017, Defendants Epstein and Groff served a letter on counsel for the Plaintiff identifying the many fundamental bases which exist for dismissing the Plaintiff's Complaint. On the same day, Defendant [REDACTED] served a letter on counsel for the Plaintiff identifying additional grounds for dismissing the Complaint. These letters were served pursuant to the schedule set forth in the Court's May 15, 2017 Stipulation and Order ("Scheduling Order"). + +After receiving these letters, counsel for Plaintiff advised the undersigned that Plaintiff is likely to amend her Complaint, instead of standing on the Complaint. Pursuant to the Scheduling Order, Plaintiff will have until June 5, 2017 to file an amended complaint. Defendants will have until June 19, 2017 to move to dismiss the amended complaint, and briefing on the motions to dismiss will be completed by August 2, 2017. + +In light of the Court's issuance of the Scheduling Order and Plaintiff's obligation to serve an amended complaint on or before June 5, 2017, we respectfully request that the conference + +Hon. John G. Kochi May 18, 2017 Page 2 + +![](_page_1_Picture_2.jpeg) + +scheduled for June 2, 2017 be adjourned until after Plaintiff has served her amended complaint and preferably until briefing on the motions to dismiss has been completed. We respectfully believe that adjourning the conference until such time would make practical sense. + +Respectfully submittal. + +Michael C. 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MI 212 506 3955 mmillenasteptoe.com + +1114 Avenue of the Americas New York, NY 10036 212 506 3900 main www.steptoe.com + +May 22, 2017 + +## VIA ECF + +Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 + +Dear Judge Koeltl: + +![](_page_0_Picture_2.jpeg) + +We are counsel to defendants Jeffrey Epstein and Lesley Groff in the above-referenced matter. We write in response to Plaintiff's May 19, 2017 letter to the Court, in which Plaintiff contends that discovery should proceed now, i.e., before the Plaintiff files her amended complaint and the Court resolves the inevitable motions to dismiss. We respectfully submit that, for the reasons set forth below, the Court should stay discovery pending the resolution of Defendants' motions to dismiss the Plaintiff's amended complaint. We are advised that Defendant joins in this request. + +Plaintiff's counsel recently advised us that Plaintiff is likely to file an amended complaint and will do on or before June 5, 2017. Plaintiff arrived at this conclusion after receiving letters on Ma 15 2017 from this firm (on behalf of Defendants Epstein and Groff) and counsel for which outlined the many deficiencies in the current complaint that warrant its dismissal ("May 15 Letters"). Pursuant to this Court's May 15, 2017 Stipulation and Order, Defendants will have until June 19, 2017 to move to dismiss the Plaintiff's amended complaint, and briefing will be completed by August 2, 2017. + +We respectfully submit that discovery should be stayed until the Court resolves the inevitable motions to dismiss the amended complaint, for the following reasons: + +First, and in any event, the Plaintiff has not yet served her amended complaint. It is not possible to properly assess the propriety of any discovery propounded by the Plaintiff until her amended complaint has been served on and reviewed by the Defendants. Rogen v. Scheer, 1991 Hon. John G. Koeltl May 22, 2017 Page 2 + +![](_page_1_Picture_2.jpeg) + +WL 33294 (S.D.N.Y., Feb. 22, 1991) ("before the plaintiff can avail himself of the process of this Court to build his case, he must state an adequate claim on the information in his hands. The stay on discovery is therefore continued until a final amended complaint and answer thereto are filed with this Court"); American Fed of Musicians and Employers' Pension Fund v. Atlantic Recording Corp., 2016 WL 2641122 (S.D.N.Y., Jan. 8, 2016) (staying discovery pending motion to dismiss amended complaint). + +Second, we do not believe that Plaintiff can cure the many defects in her current complaint with an amended complaint. As outlined in the May 15 Letters, the current complaint is fatally deficient because it: (a) fails to state a claim; (b) is barred by the applicable statutes of limitations; (c) fails to allege jurisdiction; and (d) fails to establish that venue is properly laid in the Southern District of New York. We respectfully request that the Court waive its page limitation on letter motions to permit us to provide the Court with a copy of the May 15 Letters. + +Third, Plaintiff's purported urgent need to press forward with discovery cannot be reconciled with the fact that she waited over ten years to bring this action. There is no need to commence discovery immediately in a case that the Plaintiff has neglected to commence for such a long period of time. + +Fourth, while there will be no prejudice to the Plaintiff if discovery in connection with her more than 10-year old claim is stayed by the Court, the Defendants will undoubtedly expend time, energy and resources in responding to discovery demands that may prove to be unjustified and completely irrelevant if the motions to dismiss even an amended complaint by Plaintiff bring the Plaintiffs claims to an appropriate and immediate end. + +Lastly, there is a pending action in Florida where Plaintiff's lead counsel, Brad is the counter-claim plaintiff against Jeffrey Epstein. Given the pending Florida litigation, the timing of Plaintiff's request to proceed with discovery for this case at this time, before the Court's determination as to whether Plaintiff's has sufficiently stated a claim and whether her claim is time-barred, raises questions as to the purpose and propriety of the request. + +For all of the above reasons, we respectfully submit that there is good cause to stay discovery until the Court has resolved the motions to dismiss the g4nded complaint. + +tfully;4bm + +Michael C. 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[REDACTED] +212 506 3955 +mmiller@steptoe.com + +1114 Avenue of the Americas +New York, NY 10036 +212 506 3900 main +www.steptoe.com + +![](_page_0_Picture_179.jpeg) + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DO # 512417 +DATE FILED: 5/24/17 + +*Discovery is stayed +pending the conference scheduled +for 7/6/17 at 4:30 p.m.* +May 22, 2017 + +VIA ECF +Hon. John G. Koeltl +United States District Court +United States Courthouse +500 Pearl Street +New York, NY 10007-1312 + +*so ordered. +for 6/16/17 +n.s.d.s +5/24/17* + +Re: Jane Doe 43 v. Jeffrey Epstein, et al. +Civil Action No. 17-cv-616 + +Dear Judge Koeltl: + +We are counsel to defendants Jeffrey Epstein and Lesley Groff in the above-referenced matter. We write in response to Plaintiff's May 19, 2017 letter to the Court, in which Plaintiff contends that discovery should proceed now, i.e., before the Plaintiff files her amended complaint and the Court resolves the inevitable motions to dismiss. We respectfully submit that, for the reasons set forth below, the Court should stay discovery pending the resolution of Defendants' motions to dismiss the Plaintiff's amended complaint. We are advised that Defendant [REDACTED] joins in this request. + +Plaintiff's counsel recently advised us that Plaintiff is likely to file an amended complaint and will do on or before June 5, 2017. Plaintiff arrived at this conclusion after receiving letters on May 15, 2017 from this firm (on behalf of Defendants Epstein and Groff) and counsel for [REDACTED], which outlined the many deficiencies in the current complaint that warrant its dismissal ("May 15 Letters"). Pursuant to this Court's May 15, 2017 Stipulation and Order, Defendants will have until June 19, 2017 to move to dismiss the Plaintiff's amended complaint, and briefing will be completed by August 2, 2017. + +We respectfully submit that discovery should be stayed until the Court resolves the inevitable motions to dismiss the amended complaint, for the following reasons: + +First, and in any event, the Plaintiff has not yet served her amended complaint. It is not possible to properly assess the propriety of any discovery propounded by the Plaintiff until her amended complaint has been served on and reviewed by the Defendants. *Rogen v. Scheer*, 1991 + +Hon. John G. Koeltl May 22, 2017 Page 2 + +![](_page_1_Picture_2.jpeg) + +WL 33294 (S.D.N.Y., Feb. 22, 1991) ("before the plaintiff can avail himself of the process of this Court to build his case, he must state an adequate claim on the information in his bands. The stay on discovery is therefore continued until a final amended complaint and answer thereto are filed with this Court"); American Fed of Musicians and Employers' Pension Fund v. Atlantic Recording Corp., 2016 WL 2641122 (S.D.N.Y., Jan. 8, 2016) (staying discovery pending motion to dismiss amended complaint). + +Second, we do not believe that Plaintiff can cure the many defects in her current complaint with an amended complaint. As outlined in the May 15 Letters, the current complaint is fatally deficient because it: (a) fails to state a claim; (b) is barred by the applicable statutes of limitations; (c) fails to allege jurisdiction; and (d) fails to establish that venue is properly laid in the Southern District of New York. We respectfully request that the Court waive its page limitation on letter motions to permit us to provide the Court with a copy of the May 15 Letters. + +Third, Plaintiff's purported urgent need to press forward with discovery cannot be reconciled with the fact that she waited over ten years to bring this action. There is no need to commence discovery immediately in a case that the Plaintiff has neglected to commence for such a long period of time. + +Fourth, while there will be no prejudice to the Plaintiff if discovery in connection with her more than 10-year old claim is stayed by the Court, the Defendants will undoubtedly expend time, energy and resources in responding to discovery demands that may prove to be unjustified and completely irrelevant if the motions to dismiss even an amended complaint by Plaintiff bring the Plaintiffs claims to an appropriate and immediate end. + +Lastly, there is a pending action in Florida where Plaintiff's lead counsel, Brad is the counter-claim plaintiff against Jeffrey Epstein. Given the pending Florida litigation, timing of Plaintiff's request to proceed with discovery for this case at this time, before the Court's determination as to whether Plaintiff's has sufficiently stated a claim and whether her claim is time-barred, raises questions as to the purpose and propriety of the request. + +For all of the above reasons, we respectfully submit that there is good cause to stay discovery until the Court has resolved the motions to dismiss the nded complaint. + +lly subm' Michael C. + +Counsel for De Jeffrey Epstein and Lesley Groff \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819627/EFTA02819627.metadata.json b/marker2/court-jane-doe-43/EFTA02819627/EFTA02819627.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e82cbc6df7d84d5ae3b26a9bca82b4e658c69fe5 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819627/EFTA02819627.metadata.json @@ -0,0 +1,107 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819627.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 4864, + "elapsed_seconds": 8.14, + "image_assets": [ + "_page_0_Picture_179.jpeg", + "_page_1_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 109 + ], + [ + "Line", + 50 + ], + [ + "Text", + 26 + ], + [ + "PageHeader", + 2 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 86 + ], + [ + "Line", + 41 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "Caption", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819627" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819627/_page_0_Picture_179.jpeg b/marker2/court-jane-doe-43/EFTA02819627/_page_0_Picture_179.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9e5a65ded02292de8fd6b200b282ceae76f39632 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819627/_page_0_Picture_179.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:36d0689732c2642caa35d094edad952b00c2652ada44746922b2f24dcd9a2be3 +size 5159 diff --git a/marker2/court-jane-doe-43/EFTA02819627/_page_1_Picture_2.jpeg b/marker2/court-jane-doe-43/EFTA02819627/_page_1_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e2b34d68ca7afb67dfd5b8f50b1876a3c7eb1ad1 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819627/_page_1_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d758cfb5a23e4670efd6f98b31a9dea39aeb1f449e39576437039a9b42f0d05b +size 3468 diff --git a/marker2/court-jane-doe-43/EFTA02819629/EFTA02819629.md b/marker2/court-jane-doe-43/EFTA02819629/EFTA02819629.md new file mode 100644 index 0000000000000000000000000000000000000000..87b9daedbb09cadffed3aa55dea7ced244695ff0 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819629/EFTA02819629.md @@ -0,0 +1,232 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +CASE NO.: 1:17-CV-00616 + +JANE DOE 43, + +Plaintiff, + +VS. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL LESLEY GROFF, AND NATALYA + +Defendants. + +# FIRST AMENDED COMPLAINT + +Plaintiff JANE DOE 43, by and through her undersigned counsel, for her claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, Lesley Groff, and Natalya , alleges upon personal knowledge with respect to her own acts and status, and upon personal knowledge, information and belief as to all other matters, as follows: + +- 1. This cause of action arises under federal statutes and jurisdiction is proper under 28 U.S.C. section 1331. +- 2. Plaintiff files this Complaint under a pseudonym in order to protect her identity because this Complaint makes allegations of a sensitive sexual nature the disclosure of which, in association with her name, would cause further harm to her. + +3. At all times material to the events alleged in this cause of action the Plaintiff was a citizen of South Africa residing in New York, New York. + +4. At all times material to this cause of action Defendant Jeffrey Epstein had multiple residences, including in New York, New York (within the Southern District of New York) and the United States Virgin Islands. He is currently a citizen of the United States and claims to be a resident of the U.S. Virgin Islands. + +5. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in 1953. + +6. At all times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York and was a citizen of Great Britain and France. + +7. At all times material to this cause of action was a United States citizen, residing in New York, New York (within the Southern District of New York). + +8. At all times material to this cause of action Lesley Groff was a United States citizen, employed by New York based company and regularly conducting business in New York, New York (within the Southern District of New York). + +9. A substantial part of the acts, events, and omissions giving rise to this cause of action occurred in the Southern District of New York; venue is proper in that District. 28 U.S.C. section 1391(b)(2) + +10. At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, and Lesley Groff owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional, criminal, fraudulent, or tortious acts against her, including any acts in violation of 18 U.S.C. §1595. + +# FACTUAL ALLEGATIONS + +11. At all times material to this cause of action, Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is widely recognized as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes and to employ and conspire with a group of numerous others, including each of the named Defendants, to assist in committing those crimes and additional torts as well as to conceal the crimes and torts of the Epstein sex trafficking group from being discovered. + +12. Defendant Epstein displays his enormous wealth, power and influence to his employees; to the victims procured for sexual purposes; and to the public in order to advance and carry out his crimes and torts. At all relevant times, Defendant Epstein owned and continues to own, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats and one or more helicopters. For example, he owned (directly or indirectly) a Boeing aircraft (of make and model B-727-31H with tail number N908JE) and a Gulfstream aircraft (of make and model G-1159B with tail number N909JE). He also owned numerous properties and homes, including a 51,000-square-foot mansion in Manhattan; a \$30 Million, 7,500-acre ranch in New Mexico; a 70-acre private island formerly known as Little St. James in or near St. U.S. Virgin Islands; a home in Paris, France; and a mansion in Palm Beach County, Florida. The allegations herein primarily concern the defendant's conduct while at his townhouse in New York; on one or more of his private airplanes; and on his private island in the United States Virgin Islands. Epstein used all of the real and personal property described in this paragraph to facilitate the illegal sex trafficking venture and enterprise described in this Complaint and in furtherance of that venture and enterprise. + +13. Defendant Epstein has a compulsive sexual preference for young females as young as 13 and as "old" as 25. Through information and belief Defendant Epstein engages in sexual acts with this age range every day and developed, through the employment of and conspiracy with the other Defendants, a sex trafficking venture and enterprise designed to fulfill his sexual desires and conceal the operation of the venture and enterprise and conduct of its participants. As part of the venture and enterprise, Epstein also provided young females for sexual purposes to his friends in order to secure social, business, and other contacts as well as other things of value. + +14. Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise. She herself recruited young, including underage, females; oversaw and trained other recruiters on how best to recruit girls for sex; developed and executed schemes designed to recruit young females; and ensured that all participants of the Defendants' sex trafficking scheme acted in certain specific ways in order to advance the purposes of the scheme, including providing young females to Epstein for sexual purposes on a daily basis, and concealing these activities from law enforcement. + +15. Defendant recruited young females for Epstein for sexual purposes, brought gifts to females in order to entice those females to commit sex acts with Epstein and to assist in concealing the illegal sexual conduct of the venture and enterprise, and maintained Epstein's sex schedule in order to ensure that he was not without young females for any extended period of time. Defendant also handled travel arrangements for various females being exploited for sexual purposes. Defendant was an integral part of the sex trafficking venture and enterprise and reported directly up the enterprise's line of authority to Defendants Maxwell and Epstein. + +16. Defendant Epstein employed many recruiters of young females. The nature of the Defendants' sex trafficking venture and enterprise enabled victims themselves to elevate their status to that of a paid recruiter of other victims. Recruiters were taught by Defendants Epstein, Maxwell and to inform targeted victims that Epstein possessed extraordinary wealth, power, resources and influence; that he was a philanthropist who would help female victims advance their careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact, however, these representations were fraudulent. The young females were actually required to perform intimate sexual acts at the Defendants' direction and the Defendants did not help nor intend to help advance the victims' careers. Victims were also paid to bring Epstein other young females for sex and were told by Defendants Epstein, Maxwell, and that those young females who brought other females would further benefit from bringing other girls. + +17. Defendant Groff was an integral part of the illegal venture and enterprise. Groff coordinated schedules between Defendant Epstein and the various young females used for sex; made travel arrangements for the young females; tended to the living needs of those females; communicated and coordinated with Defendants Epstein, Maxwell and to assist in facilitating young females being available in locations where the other Defendants were traveling; and she carried messages to the young females from the other Defendants including false representations in order to maintain the young females' compliance with the rules of sexual compliance imposed by this structured sex-trafficking group. Groff was aware of + +the activities of the venture and enterprise, including the fraudulent representations and other coercion that was being applied to secure the females' compliance with demands of sex. + +18. The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein's compulsive need for sex with young females by preying on their personal, psychological, financial, and related vulnerabilities. The Defendants' tactics included promising the victims money, shelter, transportation, gifts, employment, admission into educational institutions, educational tuition, protection, and other things of value in exchange for sex. Defendants also took possession of the victims' passports to coerce compliance with their demands. Defendants also trafficked young females to Epstein's friends and acquaintances in order to secure financial and other benefits as well as social, educational, and business connections. + +19. Defendants' sex trafficking venture and enterprise operated in a hierarchal structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top. Defendants Epstein and Maxwell operated the sex trafficking scheme dating back to at least the mid-nineties, and over the years perfected their roles and the roles of others, both in terms of the ability to increase the volume of young females recruited for sex and in insulating the enterprise from criminal investigation or prosecution. Defendant Groff conspired with Defendant Epstein and Maxwell since at least 2002 and continues to work for Defendant Epstein today. Defendant began working with the Epstein-run sex trafficking venture and enterprise as early as 2001 and her role in their venture and enterprise was well-defined and primarily consisted of conspiring in the commission and cover-up of sex crimes. Underlings included the other named Defendants as well as unnamed coconspirators such as various housekeepers and butlers; an airplane pilot; and various employees, assistants and associates. Wittingly and unwittingly, such underlings performed their respective roles with the purpose and effect of insuring that the enterprise supplied young females to Defendant Epstein and others for sexual purposes. At all times materials to this complaint, the venture and enterprise was a group of two or more individuals associated in fact and deed. + +20. Defendants Epstein and Maxwell, with help from assistants, associates and underlings, recruited and procured hundreds of girls over the decades of the operation of their scheme. Such recruitment and procurement included fraud, coercion, threats, intimidation, fear, the threat of coercion, and a combination of these and similar tactics. Following the Defendants' recruitment and procurement of the young females to join Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent promises, coercion, and threats of coercion in order to entice and coerce the females into sex and, once sexual activities ensued, to cause them to remain in the enterprise. The Defendants also transported females in + +interstate and foreign commerce and in ways that affected interstate and foreign commerce. The sex acts were commercial in nature, because the Defendants promised to provide financial and other compensation to the females in exchange for providing sex acts to Epstein. + +21. Defendants specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females to provide sex for Epstein. + +22. Additionally, Defendants always made clear to every young female that they were wealthy, well-connected and could either help or hurt the females depending on their degree of cooperation. In fact, Defendants Epstein and Maxwell have been known to threaten young females with physical harm. It is unknown exactly how long the Defendants' criminal and illegal venture and enterprise operated, although it was at least continuously and actively in operation from the mid-1990's through and including the calendar year 2007. + +23. Defendant Epstein has continued the venture and enterprise up to the present time in some form or another and with additional co-conspirators and participants. + +24. In 2005, Defendant Epstein and numerous co-conspirators within the venture and enterprise were the subjects of a Palm Beach, Florida Police Department criminal investigation which revealed that Defendant Epstein had engaged in sexual activities with dozens of young teenage school children. Each child identified in that particular investigation was lured into Defendant Epstein's Palm Beach mansion with a promise that she would receive money for providing him with a body massage, although once there, each young female was made to engage in sexual acts in order to receive the promised compensation. Several were also made to engage in sex with another of Defendant Epstein's female traveling sex companions who Epstein referred to as his lesbian sex slave and bragged about purchasing her from her family when she herself was underage. + +25. In 2006, the Palm Beach Police Department investigation was turned over to the FBI and the United States Attorney's Office for the Southern District of Florida. The United States Attorney's Office investigated Defendant Epstein and his co-conspirators for their violations of numerous federal statutes, including 18 U.S.C. Section 1591, one of the statutory bases for this complaint. + +26. The United States Attorney's investigation continued from 2006 through September 2007, at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office deferring federal prosecution of Defendant Epstein and his numerous co-conspirators, including Defendants and Groff, each named by the Federal Government as coconspirators, for identified federal sex crimes against more than 30 minors. + +27. From late 2006 through September 2007, Epstein's team of lawyers negotiated with the federal government in an effort to avoid a fifty-three-page Federal felony indictment from being filed against Epstein. During these negotiations, Defendant Epstein decamped from Palm Beach to New York and the U.S. Virgin Islands in order to convey an image to prosecutors that he and his coconspirators had stopped committing sex crimes. + +28. Remarkably, however—as this case will highlight—Defendant Epstein and his co-Defendants, including the other defendants named herein, did not abandon their sex trafficking venture and enterprise even while they were under state and federal investigation for crimes committed in violation of 18 U.S.C. section 1591, among other laws, and even as Defendants and their attorneys were busy arguing Epstein's innocence and publicly defaming his victims as liars. Rather, Defendants merely changed their location. Instead of targeting local Palm Beach Florida school girls, the Defendants transported young females from other places in the U.S. (including the Southern District of New York) and abroad and brought them to Defendant Epstein's mansion in New York City and his private island in the Virgin Islands. + +29. In June of 2008, Epstein pleaded guilty to Florida state felony sex offenses for procuring a minor for prostitution and soliciting prostitution by minors and registered as a Sex Offender for Life. + +30. Defendants Epstein and Maxwell developed and implemented a sophisticated system designed to insulate them from criminal and civil liability by protecting them from potential testimony of knowledgeable subordinates. Defendants and Groff adapted to the system and also carried it out for years in exchange for significant pay, benefits, and protection from prosecution. The system included requiring subordinates to sign confidentiality agreements barring disclosure of criminal activity; maintaining records of underage females who were abused by Epstein; requiring subordinates and victims to refrain from speaking with law enforcement officials; requiring them to notify Defendant Epstein's lawyers in the event they (subordinates and victims) were contacted by law enforcement officials; requiring them to accept the representation of attorneys paid for by Defendant Epstein; requiring them to invoke the Fifth Amendment in response to questions they might be asked by investigators and prosecutors; requiring them to invoke the Fifth Amendment in order to refuse to turn over incriminating and non-incriminating evidence to law enforcement officers; requiring them to destroy evidence or refuse to reveal knowledge of destroyed evidence; and requiring them generally to refuse all cooperation with law enforcement officials or investigations. + +31. In 2005, Defendant Epstein and other co-conspirators, aware that law enforcement officials were preparing imminently to execute a search warrant for his home, removed computer systems that logged information about Epstein and his co-conspirators' illegal and criminal conduct; the identities of witnesses; nude photographs of young females; scheduling books; message pads; tangible items such as vibrators and toys; and other incriminating matter. + +32. The sex recruiting and trafficking venture and enterprise designed to procure young females for sexual purposes and to conceal those activities was developed and fine-tuned over time, and each of the named Defendants had a well-defined role and improved in his/her role over time, with practice and experience. By the time Plaintiff was recruited into victimization, each Defendant had years of experience perfecting methods of coercion, understanding Epstein's requirements, and becoming more loyal to the continuance and survival of the venture and enterprise. All of the Defendant's knew about the activities of the venture and enterprise and worked in concert for the goals of the venture and knowingly benefitted, financially and by receiving things of value, from their participation in the venture and enterprise. + +33. A typical way the Defendants procured young females for sex with Defendant Epstein was to make false promises of a modeling opportunity, offer a better life, offer payment for a formal education, or offer other money or consideration. + +34. Beginning in approximately October 2006 and continuing through April 2007, Defendants recruited Plaintiff into their sexual enterprise by fraudulently promising to use their connections and resources to secure her admission to an institution of higher education at the expense of Defendant Epstein. + +35. One of the enterprise's many recruiters, Natalya , was working to recruit young females for Epstein for sex when she approached and recruited Plaintiff. + +36. informed Plaintiff that she would introduce Plaintiff to Defendant Epstein, whom she described as a wealthy philanthropist who regularly used his wealth, influence and connections to help financially poor females like Plaintiff achieve their personal and professional goals and aspirations. + +37. reported to her superiors, Defendants , Groff and Maxwell, and was paid for her recruitment of young females, including Plaintiff. + +38. introduced Plaintiff to Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology (known as "F.I.T.") in New York City or into a similar institute of higher learning offering a curriculum of fashion industry training. Between October 2006 and May 2007, Defendants Maxwell, , and Groff each also confirmed and reiterated this promise to Plaintiff many times, each telling Plaintiff that Epstein would use his wealth and connections to advance Plaintiff's education. More specifically, each of the Defendants last verified this information that Epstein was using his connections to ensure Plaintiff was admitted + +into F.I.T. in exchange for Plaintiff's continued sexual cooperation with Epstein in March or April of 2007. + +39. Defendant Maxwell told Plaintiff she would need to provide Defendant Epstein with body massages in order to reap the benefits of his and Maxwell's connections. + +40. All Defendants. including Maxwell, Epstein, Groff and , knew that Plaintiff was actually being recruited for sexual purposes, and each knowingly and deliberately made false representations to ensure that Plaintiff would cooperate in fulfilling Epstein's sexual desires. These false and fraudulent representations included Defendants' telling Plaintiff that Epstein would use his connections to have her admitted into F.I.T. or a similar institute, college, university or school of higher learning and provide her with employment opportunities. Plaintiff reasonably relied on these representations and had a credible basis for such reliance, including the credible representations of Epstein and the other Defendants that they possessed extensive political, business, financial, social, and educational influence and connections. Epstein and the other Defendants represented to Plaintiff in manners that were persuasive, credible, and reasonable to Plaintiff, as they would have been to any other person similarly situated, that they had the political, business, financial, social, educational, and other influence and + +connections sufficient to arrange for and insure her admission into F.I.T. or a similar school of higher learning. + +41. Maxwell and Epstein also threatened Plaintiff that, while they had the ability to advance her education and career, they also had the ability to make sure that Plaintiff would not obtain formal education or modeling agency contracts if she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein, Groff, and Maxwell. + +42. Plaintiff reasonably believed that her compliance with Defendants' demands was crucial to her physical, psychological, financial. and reputational well-being and survival. + +43. Defendant Maxwell instructed Plaintiff how to massage Epstein using the techniques that Maxwell knew that Epstein preferred. During Plaintiff's first massage, Defendant Epstein converted it into a sexual act and made it known to Plaintiff that further sex would be required in order for her to obtain the assistance he promised her and to avoid Defendants' threatened retaliation against her if Plaintiff did not perform as demanded. + +44. Maxwell and Epstein informed Plaintiff that other young females in Epstein's company were there also to perform sexual acts for Epstein and his friends. Groff and helped to secure the presence of the other young females for these purposes. + +45. Plaintiff was instructed dozens of times to provide body massages to Epstein, both at his townhouse in New York and on his private island in the U.S. Virgin Islands. Each time she was so instructed she was also required to perform a sexual act with Epstein. The Defendants all participated in arranging for Plaintiff to be transported in interstate and foreign commerce, and affecting interstate and foreign commerce, for these sexual purposes. The Defendants Epstein, Maxwell, and used possession and control of Plaintiff's passport to induce and coerce Plaintiff into performing sexual acts with Epstein and others. + +46. During many sexual encounters, Defendant Epstein gave Plaintiff no option, opportunity, or choice not to participate in the prescribed sexual acts. + +47. Defendant Maxwell frequently controlled the assignment, or "rotation," of Plaintiff and the other young females concerning the time, place and manner of the sex acts they were told to provide to Defendant Epstein. Defendant Maxwell also gave instructions on how to perform certain sexual techniques on Epstein. Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with other females. + +48. Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaintiff with serious harm, as well as serious psychological, financial, and reputational harm, compelling Plaintiff to perform and continue performing the commercial sexual activity demanded by Defendants. + +49. On one occasion, after suffering verbal abuse and threats by Defendants Epstein, Maxwell, and IIIM, Plaintiff attempted to escape from Defendant Epstein's private island. A search party led by Defendants Epstein and Maxwell located her and physically returned her to the main house on the island. Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind. Defendants further used possession and control of Plaintiff's passport, without lawful consent or authority, to restrict Plaintiff's liberty and thereby force her to provide sex to Epstein. + +50. Defendant Epstein's wealth, influence, power and connections were used by Defendants Maxwell, =, and Groff, both as an inducement to provide sex (in exchange for promises of support to Plaintiff) and as a means of threatening punishment (in the event Plaintiff refused to comply with Defendants' instructions to provide sex to Epstein and others). + +51. In addition to Plaintiff's being trafficked on Epstein's private airplane, Defendants Groff, Maxwell and , with the knowledge of and instruction by Defendant Epstein, arranged Plaintiffs living accommodations, private car travel, and commercial air travel on numerous occasions for the purpose of causing Plaintiff to commit commercial sex acts. These Defendants worked in concert with one another to recruit, procure, entice, and otherwise cause many other females to engage in commercial sex acts, through their use of threats, fraud, and coercion. Among these means of coercion were the Defendant's possession and control of the females' passports and other immigration documents. This coercion was most salient, and especially effective, while the females, including Plaintiff, were on Epstein's island. + +52. In furtherance of their venture and enterprise, Defendants provided living quarters for Plaintiff at 301 East 66th Street, New York, in the Southern District of New York; a car service for Plaintiff to use as needed; a cell phone; and other valuable consideration in order to maintain Plaintiffs sexual compliance. Each of the Defendants told Plaintiff she would obtain the benefits of a place to live and phone and transportation as long as she remained compliant with their demands that she service Epstein sexually. Each of the Defendants also told her that if she was not compliant, these benefits would be taken from Plaintiff. + +53. The relationship between Plaintiff and Defendants Epstein and Maxwell was defined and characterized by Defendant Epstein's and Defendant Maxwell's frequent and persistent fraudulent representations that they would provide Plaintiff with a formal education and career advancement if she provided sex to Defendant Epstein and others in the times, places and manners demanded by Defendants. Defendants Groff and each also told Plaintiff that Defendant Epstein would advance Plaintiffs education and career in order to coerce Plaintiff into sex. Defendant told Plaintiff that Epstein had done the same for her career. As a result of these and other representations by Defendants, Plaintiff reasonably relied on these representations. In fact, however, these representations were knowingly false, were not acted upon by Defendants, and were made by Defendants Epstein, Groff, , and Maxwell solely for the purpose of maintaining Plaintiffs financial dependence on, emotional vulnerability to, and sexual compliance with Defendant Epstein's demands. The other Defendants intentionally repeated these representations and intentionally made statements designed to convince Plaintiff that the representations were true and could be relied upon. These representations and statements were made to Plaintiff in furtherance of the sex trafficking venture and enterprise for which they were each employed. + +54. As part of the venture and enterprise, Defendants Epstein, Maxwell, and took possession of Plaintiff's passport when she was being trafficked by them, including when she travelled to Epstein's island in the U.S. Virgin Islands. The Defendants took possession of Plaintiff's passport in the course of sexually trafficking Plaintiff and with the intent to violate laws against sex trafficking, including 18 U.S.C. 1591 et. seq. The Defendants used their control of Plaintiff's passport in order to coerce compliance with their demands, including their demands that Plaintiff have sex with Epstein and others. + +55. In January 2007, as part of their illegal venture and enterprise, Defendants sent Plaintiff from New York City, in the Southern District of New York, to South Africa to recruit, for a promised fee, one or more aspiring female models supposedly for Epstein to use as a personal assistant. The Defendants did not care whether the prospective female was qualified to work as a personal assistant because each knew that the female recruit would be immediately placed into the same sexually vulnerable position as Plaintiff (and the dozens of other victims of the sex trafficking enterprise) and would be induced and coerced into being used for sex through fraudulent representations and other means. + +56. Defendants Epstein and Maxwell continuously and frequently demanded that Plaintiff fulfill this task of bringing another female back to the United States and Defendants' control as a condition of Plaintiff's receiving the education, career and related benefits promised by Defendants Epstein and Maxwell. Based upon Plaintiff's experience with Defendants, however, she knew that the requested female model would not be placed in a legitimate position of employment with Defendant Epstein but would, instead, be forced into sexual servitude. Plaintiff also knew that this objective was the only purpose of Defendants , Groff, Maxwell and Epstein's demand for Plaintiff's recruitment efforts. As a result, Plaintiff deliberately refused to perform the recruitment assignment. + +57. As part of their ongoing scheme, Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts with Epstein and others. While Plaintiff was in South Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be permitted to return to the United States to receive her promised education unless she underwent a diet and lowered her body weight from 57 kilograms (approximately 125 pounds) to 52 kilograms (approximately 114 pounds). Epstein and Maxwell promised Plaintiff that, if she complied, she would receive her promised education. Defendant Groff monitored Plaintiffs progress in losing weight and continued to communicate with Plaintiff about Plaintiff's application to be admitted into F.I.T. as part of the Defendants' ruse to coerce Plaintiff to return to the United States for sex. Defendant Groff was aware of the coercion Epstein and Maxwell were applying to Plaintiff and acted to help further that coercion. Believing she had no practical choice in the matter, Plaintiff attempted to comply with the order but, given her physical height and body structure and her already existing body weight, the diet imposed upon her placed her in serious physical jeopardy, including kidney malfunction and extreme emotional and psychological distress. + +58. As part of their scheme, Defendants Epstein and Maxwell called Plaintiffs parents in South Africa to tell them that Defendant Epstein would take good care of Plaintiff when she returned to the United States, and that Defendants Maxwell and Epstein would use their connections and influence to have her admitted to F.I.T. or another well-regarded fashion school or school of higher learning. + +59. As part of their scheme, Epstein and Groff told Plaintiff that she should fill out an application for admission to F.I.T., and supporting essay, and send it to Epstein for his review. Pursuant to these instructions, Plaintiff completed an application, and supporting essay, and sent it to Epstein. As part of his scheme, Epstein told Plaintiff that he had reviewed these materials. His statements were intended to convince Plaintiff, and had the effect of convincing plaintiff (as they would have convinced any reasonable person), that her admission to F.I.T. was a "done deal" if she would comply with his instructions. Groff also made the same representations to plaintiff on Epstein's behalf. Plaintiff reasonably relied on these representations by Epstein and Groff. + +60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had contacts at F.I.T. and at modeling agencies who could ensure her admission to F.I.T. and advance Plaintiff's career. As part of their scheme, Epstein and Maxwell told Plaintiff about Epstein's vast wealth and specifically identified him as a billionaire. Epstein and Maxwell told Plaintiff that they had extensive + +contacts, in addition to those identified above, throughout New York City and elsewhere. + +61. In February of 2007, in reliance on promises made by the Defendants, Plaintiff returned to New York City, in the Southern District of New York, and was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants Maxwell, Groff, and Epstein each fraudulently promised Plaintiff again that her sexual compliance would be rewarded with admission to F.I.T. or a comparable college, a promise which they each knew to be false. In fact all four Defendants had for years worked solely to recruit females for sex and to conceal the operation of the sex scheme, and in 2007 were under Federal investigation for their conspiracy to engage in Federal sexual crimes like those committed against Plaintiff. Plaintiff knew that if she did not comply, Defendants Maxwell and Epstein would use their power, influence and connections in order to ensure that Plaintiff was unable to gain admission to F.I.T. or a comparable school, and that they would destroy her career, just as they had destroyed the careers of others who had failed to comply with their demands. + +62. Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiff's continued compliance with Epstein's sexual demands; however, they failed and refused to perform their promises to help Plaintiff be admitted to F.I.T. or another school, or to provide financial support for college admission or on-going education, false promises they repeatedly made in order to coerce her into commercial sex acts. + +63. Defendants' sexual demands on Plaintiff continued while she was in New York City, in the Southern District of New York, or in other locations in close proximity to the Defendants. In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, each of the Defendants continued to pressure her to lose excessive amounts of body weight and offered her no opportunity to decline or resist their instructions. + +64. In May, 2007, Plaintiff left the United States and did not return. Between returning from South Africa in February 2007 and leaving in May 2007, Defendants =, Groff, and Maxwell each continued to repeatedly make false representations to Plaintiff, including false and fraudulent representations that she would be admitted to F.I.T. if she continued to engage in sex with Epstein. Defendant Epstein continued to make similar false and fraudulent promises in order to have sex with Plaintiff. + +65. In and after May 2007, Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's coverup included efforts to intimidate witnesses who might provide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done. + +66. Unknown to Plaintiff, Defendants' representations and promises to Plaintiff were all false and fraudulent. Plaintiff reasonably relied on the representations and promises of the Defendants. Plaintiff also considered the Defendants' threats against the current and future well-being and safety of Plaintiff to be real and credible. All such representations, promises, and threats were made solely for the purpose of coercing and otherwise inducing Plaintiff into prolonged sexual compliance. Defendants knowingly benefitted financially and received things of value as a result of coercing and inducing Plaintiff into sexual compliance and otherwise participating in their illegal venture and enterprise. + +### COUNT I CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C. \* 1595 + +67. Plaintiff adopts and realleges paragraphs 1 through 66 above. + +68. Defendants individually and together, within the special maritime and territorial jurisdiction of the United States, in interstate and foreign commerce, and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, maintained, patronized, solicited, threatened, forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by Defendants were undertaken with knowledge and/or reckless disregard of the fact that their threats of force, fraud, coercion, and combinations of such means would be used, and were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In so doing, Defendants violated 18 U.S.C. §1591. + +69. Additionally, Defendants Epstein, Maxwell, and individually and together, knowingly concealed, removed, confiscated, and possessed Plaintiff's passport and associated immigration documents, in the course of violating 18 U.S.C. § 1591, and with the intent of violating 18 U.S.C. § 1591, and to prevent, restrict, attempt to restrict, without lawful authority, Plaintiff's liberty to move or travel, in order to maintain the sexual services of Plaintiff, while Plaintiff was a victim of a severe form of sex trafficking, as defined in section 103 of the Trafficking Victims Protection Act of 2000, enacted in 22 U.S.C. § 7102. In so doing, Defendants violated 18 U.S.C. § 1592. These Defendants also obstructed, and attempted to obstruct and to interfere with the enforcement of 18 U.S.C. § 1592. + +70. Additionally, Defendants knowingly benefitted, financially and by receiving things of value, from participating in a venture (the Epstein sex trafficking venture enterprise) which had engaged in acts in violation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in such violations. In so doing, Defendants violated 18 U.S.C. § 1593A. + +71. Additionally, Defendants attempted to violate 18 U.S.C. § 1591. In so doing, Defendants violated 18 U.S.C. § 1594(a). + +72. Additionally, Defendants conspired with each other, and with other persons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants violated 18 U.S.C. § 1594(6). + +73. Additionally, Defendants conspired with each other, and with other persons known and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendants violated 18 U.S.C. § 1594(c). + +74. By virtue of their violations of 18 U.S.C. §§ 1591, 1592, 1593A, and 1594, Defendants are subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their violations. + +75. Certain property of Defendant Epstein's was essential to the commission of the federal crimes and torts described herein, including the use of multiple private aircraft including a Boeing aircraft (of make and model B-727-31H with tail number N908JE) and a Gulfstream aircraft (of make and model G-1159B with tail number N909JE). Such aircraft, along with other of Defendants' property, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. + +76. Additionally, Defendant Epstein's New York mansion, located at 9 East 71st Street, New York, New York, in the Southern District of New York, and his private island located in the United States Virgin Islands, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. + +77. As a direct and proximate result of Defendants' commission of the aforementioned criminal offenses enumerated in 18 U.S.C. § 1591, 1592, 1593A, and 1594, and the associated civil remedies provided in § 1595, Plaintiff has in the past suffered and will continue to suffer injury and pain; emotional distress; psychological and psychiatric trauma; mental anguish; humiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of enjoyment of life; invasion of privacy; and other damages associated with Defendants' actions. Plaintiff will incur further medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to these losses, Plaintiff has incurred attorneys' fees and will be required do so in the future. + +WHEREFORE, Plaintiff demands judgment against Defendants for compensatory and general damages, attorney's fees, punitive damages and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury. + +Dated: June 5, 2017. + +Respectfully Submitted, + +JAFFE, WEISSING. FISTOS, LEHRMAN, P.L. + +B : /s/ J. J. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954)-524-2820 Fax: (954)-524-2822 Email: brad@pathtojustice.com PRO HAC VICE + +BOLES, SCHILLER & FLEXNER LLP David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 (919) 749-8200 Fax: (914) 749-8300 Email: dboies@bsfllp.com + +Sigrid McCtile Meredith Boies Schiller & Flexner LLP 401 East Las Olas Blvd., Ste. 1200 Fort Lauderdale, Florida 33301 (954) 356-0011 Fax: Email: smccawley@bsfllp.com Email: mschultz@bsfllp.com PRO HAC VICE + +Paul G Cassell S.J. Quinney College of Law at the University of Utah 383 S. University Street Salt Lake City, UT 84112-0730 (801)-585-5202 Fax: (801)-585-2750 Email: cassellp@law.utah.edu. PRO HAC VICE + +This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation + +#### CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on the 5th day of June, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. + +STEPTOE & LLP + +Michael C. + +Justin Y.K. + +mmiller@steptoe.com, cjenkins@steptoe.com, pparker@steptoe.com + +jchu@steptoe.com cjenkins@steptoe.com pparker@steptoe.com psafirstein@steptoc.com + +Attorneys for Defendants + +Jeffrey Epstein & Lesley Groff + +ALSTON & BIRD, LLP + +John E. Stephenson, Jr. + +Alexander S. Lorenzo + +alexMlorenzo@alston.com, autodocket-nyc@alston.com, managingclerksoffice-nyc@alston.com, john.stephenson@alston.com + +Attorneys for Defendant + +By: /s/ J. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819629/EFTA02819629.metadata.json b/marker2/court-jane-doe-43/EFTA02819629/EFTA02819629.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2d6282c4c4a988b564baf4e6fd796e6a79d53b7c --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819629/EFTA02819629.metadata.json @@ -0,0 +1,1222 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819629.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 31, + "chars": 43428, + "elapsed_seconds": 3.61, + "image_assets": [], + 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IM 212 506 3955 nuniller@steptoe.com + +1114 Avenue of the Americas New York, NY 10036 212 506 3900 main wvAitsteptoe.com + +June 14, 2017 + +## VIA ECF + +Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 + +Dear Judge Koeltl: + +![](_page_0_Picture_3.jpeg) + +I am counsel to Defendants Jeffrey Epstein ("Epstein") and Lesley Groff ("Groff") in the above-referenced matter. I write to request that the briefing schedule for defendants' motion to dismiss be extended because I am presently engaged in a trial before Judge J. Paul Oetken in a matter captioned United States v. Block, 16 cr. 595 (JPO). The trial is scheduled through July 7, 2017. + +Pursuant to the Stipulation and Order of May 15, 2017, plaintiff filed the First Amended Complaint on June 5, 2017, and defendants have until June 26, 2017 to move to dismiss. We respectfully request that the date for filing of the motion to dismiss be extended to two weeks after the completion of my trial, and that the briefing schedule be adjusted as follows: + +| | current schedule | requested schedule | +|-------------------------------|------------------|--------------------| +| Date for filing of motion | June 26, 2017 | July 17, 2017 | +| Date for filing of opposition | July 26, 2017 | August 17, 2017 | +| Date for filing of reply | August 9, 2017 | August 31, 2017 | + +We also respectfully request on account of my trial schedule that the conference scheduled for July 6, 2017 be adjourned. + +lion. John G. Koeltl June 14, 2017 Page 2 + +We are advised that defendant joins in this request. After calling counsel for Plaintiff on June 12 and 13, we email im on June 13 with the above request and explanation for the request to see if Plaintiff would consent. Plaintiff has not responded to our request. Given the fast approaching deadline, we are writing to the court at this time with our request. + +This is the first request for an extension of this briefing schedule. We previously made one request to adjourn the conference from May 22, 2017 because, as we explained in our May 18, 2017 letter to the court, it made practical sense to have the conference after Plaintiff has filed the amended complaint. + +Respectfully submitted, + +" (2. 1 4 Michael C. 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NY 10036 212 506 3900 main www.sleptoe.com + +June 14, 2017 + +## VIA ECF + +Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 + +Dear Judge Koeltl: + +![](_page_0_Picture_3.jpeg) + +Supplementing my letter of earlier today requesting an adjournment of the briefing schedule and the conference on account of my trial schedule ("Letter Request"), we received an email from counsel for Plaintiff consenting to our request after the Letter Request was filed with the court. + +fully sub fit had C. filler + +Counsel for Defendants Jeffrey Epstein and Lesley Groff \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819662/EFTA02819662.metadata.json b/marker2/court-jane-doe-43/EFTA02819662/EFTA02819662.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ba8985cad7c44352710b94cb863bb7e540289e73 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819662/EFTA02819662.metadata.json @@ -0,0 +1,96 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819662.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 762, + "elapsed_seconds": 0.7, + "image_assets": [ + "_page_0_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 64.25999999999999, + 244.61999999999998 + ], + [ + 123.00138854980469, + 244.61999999999998 + ], + [ + 123.00138854980469, + 260.60302734375 + ], + [ + 64.25999999999999, + 260.60302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 29 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Caption", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819662" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819662/_page_0_Picture_3.jpeg b/marker2/court-jane-doe-43/EFTA02819662/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..12a94789bcf04bd4dbf5f9a383674a5b0bd7e35e --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819662/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:f2fed15ad5500f46dccf5f09d4c9de0ae7501c74f582ce110f7a0eacabdad611 +size 4933 diff --git a/marker2/court-jane-doe-43/EFTA02819663/EFTA02819663.md b/marker2/court-jane-doe-43/EFTA02819663/EFTA02819663.md new file mode 100644 index 0000000000000000000000000000000000000000..152b145b50f72a966e607c6785680614dfe5902b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819663/EFTA02819663.md @@ -0,0 +1,43 @@ +Michael C 212 506 3955 nvirleresteploe.cem + +1111 Avenue of the Americas New Yost NY 10036 212 506 3900 main wenysteploe.can + +VIA ECF + +Hon. John a Kochi United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +Dear Judge Kochi: + +![](_page_0_Picture_4.jpeg) + +June 14, 2017 + +firf fret t peA-4-W O Re, 7 Se9 bidet," + +Re: Jane Doc 43 v..leffrey Epstein, et al. + +Civil Action No. 17-ev-616 ifieht 14/ /2 .=S + +am counsel to Defendants Jeffrey Epstein ("Epstein") and Lesley Groff ("Groff') in the above-referenced matter. I write to request that the briefing schedule for deRndants' motion to dismiss be extended because I am presently engaged in a trial before Judge J. Paul Oetken in a matter captioned United States v. Block, 16 cr. 595 (JPO). The trial is scheduled through July 7, 2017. + +Pursuant to the Stipulation and Order of May 15, 2017, plaintiff filed the First Amended Complaint on June 5. 2017, and defendants have until June 26. 2017 to move to dismiss. We respectfully request that the date for filing of the motion to dismiss be extended to two weeks after the completion of my trial, and that the briefing schedule be adjusted as follows: + +| | current schedule | requested schedule | +|-----------------------------|------------------|--------------------| +| Date for filing of motion | June 26.2017 | July 17, 2017 | +| Date for filinug opposition | July 26, 2017 | August 17, 2017 | +| Date for filing of reply | August 9, 2017 | August 31, 2017 | + +We also respectfully request on account of my trial schedule that the conference scheduled for July 6, 2017 be adjourned. + +Hon. John G. Koeltl June 14, 2017 Page 2 + +Steptoe rim( . .a.ano• Lir + +We are advised that defendant joins in this request. After calling counsel for Plaintiff on June 12 and 13, we mailed him on June 13 with the above request and explanation for the request to see it Plaintiff would consent. Plaintiff has not responded to our request. Given the fast approaching deadline, we are writing to the court at this time with our request. + +This is the first request for an extension of this briefing schedule. We previously made one request to adjourn the conference from May 22. 2017 because, as we explained in our May 18, 2017 letter to the court, it made practical sense to have the conference after Plaintiff has filed the amended complaint. + +Respectfully submitted, + +e 14 Michael C. 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R. Fed. in described States United the of employee or officer an or agency, States United a or States United the are of 12 Rule under motion a or complaint attached the to answer an plaintiff the on serve must you — (3) or (aX2) 12 P. attorney, plaintiff's or plaintiff the on served be must motion or answer The Procedure. Civil of Rules Federal the are: address and name whose + +J. Suite e. Lehrman & RiliFistos Weissing e Ja Lu Avenue. Andrews . 33301 FL Lauderdale, Fort + +complaint. the in demanded relief the for you against entered be will default by judgment respond, to fail you If court. the with motion or answer your file must also You + +COURT OF CLERK + +Civil Action No. 17-cv-616 + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. 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R. Fed. in described States United the of employee or officer an or agency, States United a or States United the are of 12 Rule under motion a or complaint attached the to answer an plaintiff the on serve must you — (3) or (aX2) 12 P. attorney, plaintiff's or plaintiff the on served be must motion or answer The Procedure. Civil of Rules Federal the + +are: address and name whose + +PP + +J. + +Lehrman & l.Fistos liling Jaffe + +Lute Avenue, Andrews . + +33301 FL Lauderdale, Fort + +complaint. the in demanded relief the for you against entered be will default by judgment respond, to fail you If + +court. the with motion or answer your file must also You + +Date: + +COURT OF CLERK + +Clerk Deputy or Clerk of Signature + +Civil Action No. 17-cv-616 + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. 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R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: + +[REDACTED] J. [REDACTED] +[REDACTED] Jaffe Weissing [REDACTED] Fistos & Lehrman +425 N. Andrews Avenue, Suite 2 +Fort Lauderdale, FL 33301 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: 6/5/2017 + +![]()CLERK OF COURT + +/s/ L. Aquino + +*Signature of Clerk or Deputy Clerk* + +Civil Action No. 17-cv-616 + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. 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1 [REDACTED] Jaffe Weissing [REDACTED] Fistos & Lehrman, P.
425 North Andrews Avenue Suite 2
Fort Lauderdale FL 33301
ATTORNEY FOR Plaintiff | | (954) 524-2820

Ref. No. or File No.
17-00827 | | | +| SOUTHERN DISTRICT, NEW YORK
500 Pearl Street
New York, NY 10007 | | | | | +| SHORT TITLE OF CASE:
Doe, Jane v. Epstein, Jeffrey | | | | | +| INVOICE NO.
1685653 | DATE: | TIME: | DEP/DIV. | CASE NUMBER:
17-cv-616 | + +Declaration of Reasonable Diligence + +Person to Serve: Ghislaine Maxwell + +Documents Received: + +Amended Summons in a Civil Action; First Amended Complaint; + +I declare the following attempts were made to effect personal service, no other residence or business address is known to me: + +**Aug 01 2017 02:59PM** 326 East 65th Street , New York, NY 10065; The address given is not valid for subject. Location is a UPS store. Per New York rules of service, UPS Store location is not valid service. Could not verify if the individual has a personal mailbox at this location + +Person attempting service: + +- a. Name: Manny Bayo +- b. Address: 15345 Fairfield Ranch Rd Suite 200, Chino Hills, CA 91709 +- c. Telephone number: 909-664-9577 +- d. The fee for this service was: 170.00 +- e. I am an independent contractor: + +I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. + +8/8/2017 + +Manny Bayo + +![]()Declaration of Reasonable Diligence + +Billing Code: 17-00827 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819671/EFTA02819671.metadata.json b/marker2/court-jane-doe-43/EFTA02819671/EFTA02819671.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d9961a3e61e653ea3d10ba6a162f135012b1b6b9 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819671/EFTA02819671.metadata.json @@ -0,0 +1,117 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819671.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 2779, + "elapsed_seconds": 42.13, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Declaration of Reasonable Diligence", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 230.34699999999998, + 268.92 + ], + [ + 372.71, + 268.92 + ], + [ + 372.71, + 281.07 + ], + [ + 230.34699999999998, + 281.07 + ] + ] + }, + { + "title": "Declaration of Reasonable Diligence", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 233.402, + 697.41 + ], + [ + 381.875, + 697.41 + ], + [ + 381.875, + 708.75 + ], + [ + 233.402, + 708.75 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 85 + ], + [ + "Line", + 42 + ], + [ + "Text", + 22 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "Form", + 2 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819671" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819672/EFTA02819672.md b/marker2/court-jane-doe-43/EFTA02819672/EFTA02819672.md new file mode 100644 index 0000000000000000000000000000000000000000..0368f7779c05e1b983b4a251d057218860c6946a --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819672/EFTA02819672.md @@ -0,0 +1,58 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff, + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +## MOTION TO APPROVE ALTERNATIVE SERVICE PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 4(e)(1) + +Plaintiff, Jane Doe 43, by and through the undersigned counsel and pursuant to Federal Rule of Civil Procedure 4(e)(1) and New York Civil Practice Law and Rules Section 308(5), files this Motion to Approve Alternative Service, and for grounds therefore states: + +- 1. Plaintiff filed this action on January 26, 2017, and previously obtained service of process on Defendants Jeffrey Epstein, and Lesley Groff. However, Plaintiff has been unable to effectuate service on Defendant Ghislaine Maxwell. +- 2. Defendant Maxwell has been represented by counsel in another action, and continues to be represented by that counsel in that other action presently; however, that Counsel will not accept service for Maxwell nor provide any address at which to serve their client. It is clear that Defendant Maxwell is aware of this action yet is purposely and intentionally evading service, making it impossible thus far for Plaintiff to effectuate service. +- 3. As this Court is aware, Defendant Maxwell has been represented by the Law Firm of Haddon, and a, P.C. in the Southern District of New York case titled + - v. Ghislaine Maxwell, case number I:15-cv-07433. Her attorneys have made clear that + +they are not authorized to accept service and do not know of an address where Maxwell resides or can be served. + +4. On May 11, 2017, Plaintiff filed her Motion for Extension of Time to Effectuate Service on Defendant Ghislaine Maxwell. [DE 34]. In her Motion, Plaintiff specifically stated, "[i]f unsuccessful, Plaintiff reserves the right to request additional time and permission to effectuate substitute service in light of the fact that Defendant Maxwell has known about this lawsuit since its filing, has instructed her counsel not to accept service, and has also instructed her counsel not to disclose her whereabouts in response to inquiries related to effectuating service in this case." + +5. On May 12, 2017, this Court granted Plaintiffs Motion ordering that Plaintiff shall have an additional ninety (90) days to serve Defendant Maxwell. [DE 36]. + +6. Plaintiff has engaged in extensive intemet inquiries in an effort to locate Defendant to no avail. Plaintiff was only able to identify a company apparently run by Defendant Maxwell called the Terra Mar Project with a purported location at 236 East 65th Street, New York, NY 10065. + +7. Most recently, on August 1, 2017, Plaintiff attempted to effectuate service upon Defendant Maxwell at the aforementioned location, but was informed that said location is in fact a UPS store not suitable for service. + +8. On August 10, 2017, the ninety (90) additional days to effectuate service will expire. + +9. Given that Plaintiff has engaged in diligent effort to effectuate service upon Defendant without success, Plaintiff now requests that this Court allow service by alternative methods such as service upon Defendant's prior counsel or service by publication. + +## MEMORANDUM OF LAW + +Based on the exhaustion of the other methods of service delineated above, Plaintiff hereby invokes Federal Rule of Civil Procedure 4(eX I) to request an order permitting service by an alternative method. Federal Rule of Civil Procedure 4(e)( I) authorizes that service upon a party may be effected by "following state law for serving a summons in an action brought in courts of general jurisdiction in the state where the district court is located or where service is made." As such, Defendant Maxwell may be served pursuant to CPLR § 308, which provides several methods by which service upon a natural person may be effectuated, including personal service; service by "delivering the summons ... to a person of suitable age and discretion at the actual place of business, dwelling place or usual place of abode of the person to be served" and then mailing the summons to the individual's "last know residence;" or service by "affixing the summons to the door of either the actual place of business, dwelling place or usual place of abode within the state of the person to be served" and then "mailing the summons to such person at his or her last known residence" or to his or her place of business - so called "nail and mail" service. CPLR §§ 308(1), (2) & (4). + +If service under CPLR §§ 308(1), (2) & (4) is impracticable, CPLR § 308(5) permits service "in such manner as the court, upon motion without notice, directs." The determination of whether service is impracticable "depends upon the facts and circumstances of a particular case." Securities & Exch. Comm'n v. HGI, Inc., No. 99 Civ. 3866 (DLC), 1999 WL 1021087, at \*1 (S.D.N.Y. Nov. 8, 1999). Although the Plaintiff must show impracticability of service, there is no requirement of "proof of due diligence or of actual prior attempts to serve a party under the other provisions of the statute." Id. "When usual methods of service prove impracticable, service that is reasonably calculated, under all the circumstances, to apprise the interested party of the + +pendency of the action will suffice." D.R.I., Inc. v. Dennis, No. 03 Civ. 10026 (PKL), 2004 WL 1237511, at •1 (S.D.N.Y. June 3, 2004). + +New York Courts consistently affirm their right to direct or approve alternative methods of service where regular service has been deemed "impracticable." For example, in Dobkin v. Chapman, 21 N.Y.2d 490, 498, 289 N.Y.S.2d 161, 168 (1968), the New York Court of Appeals held that where a Plaintiff could not follow the prescribed methods of service as set forth in § 308, Courts are "given the discretion to fashion other means adapted to the particular facts of the case before it" pursuant to § 308(5) (referred to in Dobkin as § 308(4), the predecessor to § 308(5)). Moreover, the Court of Appeals held that a Court's discretion to fashion such methods of service "must be broad" if the statute is to be "meaningful." Id. at 499, 289 N.Y.S.2d at 168. + +There is no doubt that Defendant Maxwell has had actual notice and knowledge of the claims asserted in this Complaint. In fact, Defendant specifically instructed her counsel to conceal her whereabouts in an effort to evade service. Therefore, is no doubt that service upon Defendant Maxwell pursuant to CPLR § 308(1), (2) and (4) is impracticable. As a result, this Court should allow service upon Defendant Maxwell by publication or by service upon her last known counsel. See Rampenad v. Deutsche Bank Secs., Inc., No. 02 Civ. 7311 (LTS), 2003 WL 21073951, at •1 (S.D.N.Y. May 9, 2003) (authorizing alternative service under § 308(5) when Plaintiff was unable to determine Defendant's residence or place of business after "extensive Internet searches" and inquires with Defendant's former clients); Javier H. v. Botello, 217 F.R.D. 308, 309 (W.D.N.Y. 2003) (service by publication authorized when individual Defendant was a fugitive from the criminal justice system; was likely aware of the pending civil action through his relatives, who were co-Defendants; and when the Court determined that Defendant would likely read a newspaper that was circulated in the region of his last known residence); see also HGI, Inc., 1999 WL 1021087, at \*1 (service by publication in USA Today authorized when Defendant's whereabouts were unknown, efforts to locate his home or business address by searching computer databases failed, and there existed no record that he designated an agent for service); D.R.I.. Inc., 2004 WL 1237511, at •2 (after Plaintiff unsuccessfully attempted to serve Defendant through a process server and searched databases for his address, Court authorized service by sending process by certified mail to Defendant's last known address; by publishing the action in a local newspaper; and by emailing it to Plaintiffs last known email address). + +WHEREFORE, Plaintiff, Jane Doe 43, prays for this Court to enter an Order granting Plaintiff's Motion to Approve Alternative Service Pursuant to Federal Rule of Civil Procedure 4(E)( I ) and New York Civil Practice Law and Rules Section 308(5) upon Defendant GHISLAINE MAXWELL authorizing service by publication, by delivering copies of the summons and complaint to counsel for Defendant in another case, or in any other manner that this Court see fit within the parameters of due process. + +Dated: August 10, 2017 Respectfully submitted, + +M AFFE, WEISSING, FISTOS&LEHRMAN, P.L. + +/s/ + +J. 425 North Andrews Avenue, Suite 2 Fort 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+ ], + "debug_data_path": "debug_data/EFTA02819672" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819677/EFTA02819677.md b/marker2/court-jane-doe-43/EFTA02819677/EFTA02819677.md new file mode 100644 index 0000000000000000000000000000000000000000..22ed4bfd0d27c590c419dc2df84c9b606e60239e --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819677/EFTA02819677.md @@ -0,0 +1,23 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, Plaintiff(s), + +## NOTICE OF COURT CONFERENCE + +-against- + +EPSTEIN, 17 civ 616 (JGK) Delendanus). + +To All Parties, + +You arc directed to appear for a pretrial conference, to be held on Tuesday, October 10, 2017, in Courtroom 1213. at 10:30am in front of the Honorable John G. Kochi. + +All requests for adjournments must be made in writing to the Court. + +For any further information, please contact the Court at (212) 805-0107 + +D Flepai Council( se Manager + +Dated: New York, New York September 26, 2017 + +![](_page_0_Picture_13.jpeg) \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819677/EFTA02819677.metadata.json b/marker2/court-jane-doe-43/EFTA02819677/EFTA02819677.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d4cdfcfcf552447a4cbff4c373fdda102f646074 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819677/EFTA02819677.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819677.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 600, + "elapsed_seconds": 0.69, + "image_assets": [ + "_page_0_Picture_13.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "NOTICE OF COURT CONFERENCE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 334.764, + 144.99 + ], + [ + 542.598876953125, + 144.99 + ], + [ + 542.598876953125, + 161.35247802734375 + ], + [ + 334.764, + 161.35247802734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Line", + 23 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819677" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819677/_page_0_Picture_13.jpeg b/marker2/court-jane-doe-43/EFTA02819677/_page_0_Picture_13.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..403eb0db5867097c9e93046b76a4c1767b4b0d12 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819677/_page_0_Picture_13.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a6170ea075e6c8028c6b83b3dd2953a8781af0a3a18a36dae96b8b3ec7cfe33a +size 17952 diff --git a/marker2/court-jane-doe-43/EFTA02819678/EFTA02819678.md b/marker2/court-jane-doe-43/EFTA02819678/EFTA02819678.md new file mode 100644 index 0000000000000000000000000000000000000000..66644e167e181516c3d9fbff8417816a17626b01 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819678/EFTA02819678.md @@ -0,0 +1,84 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff, + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, +[REDACTED], LESLEY GROFF and +NATALYA [REDACTED] + +Defendants. + +*Application granted. +Plaintiff may revel the nummers +and complaint in this action, +for defendant Mafwell by +serving counsel for +No. 17 Civ. 00616 (JGK) +Mafwell vi 15-cv-7433 +(S.P.N.Y.) with the +nummers and complaint in +this action, so ordered. +In 6/1/2017 +u.s.d.* + +MOTION TO APPROVE ALTERNATIVE SERVICE PURSUANT TO +FEDERAL RULE OF CIVIL PROCEDURE 4(e)(1) + +9/28/17 + +Plaintiff, Jane Doe 43, by and through the undersigned counsel and pursuant to Federal Rule of Civil Procedure 4(e)(1) and New York Civil Practice Law and Rules Section 308(5), files this Motion to Approve Alternative Service, and for grounds therefore states: + +1. Plaintiff filed this action on January 26, 2017, and previously obtained service of process on Defendants Jeffrey Epstein, [REDACTED], and Lesley Groff. However, Plaintiff has been unable to effectuate service on Defendant Ghislaine Maxwell. + +2. Defendant Maxwell has been represented by counsel in another action, and continues to be represented by that counsel in that other action presently; however, that Counsel will not accept service for Maxwell nor provide any address at which to serve their client. It is clear that Defendant Maxwell is aware of this action yet is purposely and intentionally evading service, making it impossible thus far for Plaintiff to effectuate service. + +3. As this Court is aware, Defendant Maxwell has been represented by the Law Firm of Haddon, [REDACTED] and [REDACTED], P.C. in the Southern District of New York case titled [REDACTED] + +[REDACTED] v. Ghislaine Maxwell, case number 1:15-cv-07433. Her attorneys have made clear that + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC# \_\_\_\_\_ +DATE FILED: 9/29/17 + +they are not authorized to accept service and do not know of an address where Maxwell resides or can be served. + +4. On May 11, 2017, Plaintiff filed her Motion for Extension of Time to Effectuate Service on Defendant Ghislaine Maxwell. [DE 34]. In her Motion, Plaintiff specifically stated, "[i]f unsuccessful, Plaintiff reserves the right to request additional time and permission to effectuate substitute service in light of the fact that Defendant Maxwell has known about this lawsuit since its filing, has instructed her counsel not to accept service, and bas also instructed her counsel not to disclose her whereabouts in response to inquiries related to effectuating service in this case." + +5. On May 12, 2017, this Court granted Plaintiff's Motion ordering that Plaintiff shall have an additional ninety (90) days to serve Defendant Maxwell. PE 36]. + +6. Plaintiff has engaged in extensive internet inquiries in an effort to locate Defendant to no avail. Plaintiff was only able to identify a company apparently run by Defendant Maxwell called the Terra Mar Project with a purported location at 236 East 65th Street, New York, NY 10065. + +7. Most recently, on August I, 2017, Plaintiff attempted to effectuate service upon Defendant Maxwell at the aforementioned location, but was informed that said location is in fact a UPS store not suitable for service. + +8. On August 10, 2017, the ninety (90) additional days to effectuate service will expire. + +9. Given that Plaintiff has engaged in diligent effort to effectuate service upon Defendant without success, Plaintiff now requests that this Court allow service by alternative methods such as service upon Defendant's prior counsel or service by publication. + +## MEMORANDUM OF LAW + +Based on the exhaustion of the other methods of service delineated above, Plaintiff hereby invokes Federal Rule of Civil Procedure 4(eX1) to request an order permitting service by an alternative method. Federal Rule of Civil Procedure 4(e)(1) authorizes that service upon a party may be effected by "following state law for serving a summons in an action brought in courts of general jurisdiction in the state where the district court is located or where service is made." As such, Defendant Maxwell may be served pursuant to CPLR § 308, which provides several methods by which service upon a natural person may be effectuated, including personal service; service by "delivering the summons ... to a person of suitable age and discretion at the actual place of business, dwelling place or usual place of abode of the person to be served" and then mailing the summons to the individual's "last know residence;" or service by "affixing the summons to the door of either the actual place of business, dwelling place or usual place of abode within the state of the person to be served" and then "mailing the summons to such person at his or her last known residence" or to his or her place of business - so called "nail and mail" service. CPLR §§ 308(1), (2) & (4). + +If service under CPLR §§ 308(1), (2) & (4) is impracticable, CPLR § 308(5) permits service "in such manner as the court, upon motion without notice, directs." The determination of whether service is impracticable "depends upon the facts and circumstances of a particular case." Securities & Exch. Comm'n v. HGI, Inc., No. 99 Civ. 3866 (DLC), 1999 WL 1021087, at •I (S.D.N.Y. Nov. 8, 1999). Although the Plaintiff must show impracticability of service, there is no requirement of "proof of due diligence or of actual prior attempts to serve a party under the other provisions of the statute." Id. "When usual methods of service prove impracticable, service that is reasonably calculated, under all the circumstances, to apprise the interested party of the + +pendency of the action will suffice." D.R.I., Inc. v. Dennis, No. 03 Civ. 10026 (PKL), 2004 WL 1237511, at \*1 (S.D.N.Y. June 3, 2004). + +Ncw York Courts consistently affirm their right to direct or approve alternative methods of service where regular service has been deemed "impracticable." For example, in Dobkin v. Chapman, 21 N.Y.2d 490, 498, 289 N.Y.S.2d 161, 168 (1968), the New York Court of Appeals held that where a Plaintiff could not follow the prescribed methods of service as set forth in § 308, Courts are "given the discretion to fashion other means adapted to the particular facts of the case before it" pursuant to § 308(5) (referred to in Dobkin as § 308(4), the predecessor to § 308(5)). Moreover, the Court of Appeals held that a Court's discretion to fashion such methods of service "must be broad" if the statute is to be "meaningful." Id. at 499, 289 N.Y.S.2d at 168. + +There is no doubt that Defendant Maxwell has had actual notice and knowledge of the claims asserted in this Complaint. In fact, Defendant specifically instructed her counsel to conceal her whereabouts in an effort to evade service. Therefore, is no doubt that service upon Defendant Maxwell pursuant to CPLR § 308(1), (2) and (4) is impracticable. As a result, this Court should allow service upon Defendant Maxwell by publication or by service upon her last known counsel. See Rampersad v. Deutsche Bank Secs., Inc., No. 02 Civ. 7311 (LTS), 2003 WL 21073951, at •1 (S.D.N.Y. May 9, 2003) (authorizing alternative service under § 308(5) when Plaintiff was unable to determine Defendant's residence or place of business after "extensive Internet searches" and inquires with Defendant's former clients); Javier IL v. M-Botello, 217 F.R.D. 308, 309 (W.D.N.Y. 2003) (service by publication authorized when individual Defendant was a fugitive from the criminal justice system; was likely aware of the pending civil action through his relatives, who were co-Defendants; and when the Court determined that Defendant would likely read a newspaper that was circulated in the region of his last known + +residence); see also HGI, Inc., 1999 WL 1021087, at \*1 (service by publication in USA Today authorized when Defendant's whereabouts were unknown, efforts to locate his home or business address by searching computer databases failed, and there existed no record that he designated an agent for service); Inc., 2004 WL 1237511, at '2 (after Plaintiff unsuccessfully attempted to serve Defendant through a process server and searched databases for his address, Court authorized service by sending process by certified mail to Defendant's last known address; by publishing the action in a local newspaper; and by entailing it to Plaintiffs last known email address). + +WHEREFORE, Plaintiff, Jane Doc 43, prays for this Court to enter an Order granting Plaintiff's Motion to Approve Alternative Service Pursuant to Federal Rule of Civil Procedure 4(E)(1) and New York Civil Practice Law and Rules Section 308(5) upon Defendant CHJSLAINE MAXWELL authorizing service by publication, by delivering copies of the summons and complaint to counsel for Defendant in another case, or in any other manner that this Court see fit within the parameters of due process. + +Dated: August 10, 2017 Respectfully submitted, + +M AFFE, WEISSING, , FISTOS&LEIIRMAN, P.L. + +J. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524- 2820 Fax: (954) 524-2822 Email: brad@pathtojustice.com Attorney for Plaintiff Jane Doe 43 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819678/EFTA02819678.metadata.json b/marker2/court-jane-doe-43/EFTA02819678/EFTA02819678.metadata.json new file mode 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+## UNITED STATES DISTRICT COURT + +for the + +Southern District of New York + +JANE DOE 43 + +Plainttifis) + +v. + +JEFFREY EP 11 .CHISLAINE MAXWELL, SARA ,LESLEY GROFF + +Defendant(s) + +Civil Action No. 17-cv-616 + +## AMENDED SUMMONS IN A CIVIL ACTION + +To: (Defendant's name and address) GHISLAINE MAXWELL Go Jeffreas eo.dluogs ragat Haddon, and P.C. 150 East 10th Avenue Denver, CO 80203 + +A lawsuit has been filed against you. + +Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: El J. + +Jaffe Weissing Fistos & Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale. FL 33301 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: + +CLERK OF COURT + +Signature of Clerk or Deputy Clerk + +Civil Action No. 17-cv-616 + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (1)) + +This summons for (name of individual and title, if any) was received by me on (date) + +O I personally served the summons on the individual at (place) on (date) ; or + +O I left the summons at the individual's residence or usual place of abode with (name) , a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual's last known address; or + +O I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization) on (date) ; or , who is + +O I returned the summons unexecuted because ; or + +O Other ape + +My fees are \$ for travel and for services, for a total of 0.00 + +I declare under penalty of perjury that this information is true. + +Date: + +Server's signature + +Printed name and title + +Server's address + +Additional information regarding attempted service, etc: \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819683/EFTA02819683.metadata.json b/marker2/court-jane-doe-43/EFTA02819683/EFTA02819683.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1d3c5a8ccbf05a6f7af083cf9381b96573e71d23 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819683/EFTA02819683.metadata.json @@ -0,0 +1,170 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819683.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2240, + "elapsed_seconds": 0.98, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 170.13600000000002, + 61.3743896484375 + ], + [ + 443.9737854003906, + 61.3743896484375 + ], + [ + 443.9737854003906, + 83.67779541015625 + ], + [ + 170.13600000000002, + 83.67779541015625 + ] + ] + }, + { + "title": "AMENDED SUMMONS IN A CIVIL ACTION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 135.252, + 294.03 + ], + [ + 390.41302490234375, + 294.03 + ], + [ + 390.41302490234375, + 309.10406494140625 + ], + [ + 135.252, + 309.10406494140625 + ] + ] + }, + { + "title": "PROOF OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 249.08399999999997, + 88.28999999999999 + ], + [ + 362.765869140625, + 88.28999999999999 + ], + [ + 362.765869140625, + 101.34405517578125 + ], + [ + 249.08399999999997, + 101.34405517578125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 78 + ], + [ + "Line", + 33 + ], + [ + "Text", + 16 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 29 + ], + [ + "Text", + 15 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819683" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819685/EFTA02819685.md b/marker2/court-jane-doe-43/EFTA02819685/EFTA02819685.md new file mode 100644 index 0000000000000000000000000000000000000000..8e109cd78af55bf355cc9ae9b9bd590c07cd6e15 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819685/EFTA02819685.md @@ -0,0 +1,23 @@ +![](_page_0_Picture_1.jpeg) + +• Initsy Duel ' oars WV/Vi.PATHTOJUSTICE.COM Staffe, Weissing, Fistos Et Lehrman, P.L. + +> J. brad@pathtojustice.com + +October 3, 2017 + +Honorable John G. Koeld Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, et. Al Case No. No. 17 Civ. 00616 (JGK) + +Dear Judge Koeltl: + +This is a letter motion requesting permission for Plaintiff to telephonically appear for the pretrial conference, currently scheduled for Tuesday, October 10, 2017, at 10:30 am. Thank you very much for your time and consideration. + +Ve Trul Yours, + +JAFFE, WEISSING, , FISTOS and LEHRMAN, PL + +J. BJE:mwk + +J. 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Panliuca. Esauire Haddon, and P.C. 150 East 10th Avenue Denver, CO 80203 + +A lawsuit has been filed against you. + +Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, IN whose name and address are: J. + +Jaffe Weissing Fistos & Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale. FL 33301 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: + +CLERK OF COURT + +Signature of Clerk or Deputy Clerk + +Civil Action No. 17-cv-616 + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. 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John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 + +Dear Judge Koeltl: + +We are counsel for Defendants Jeffrey E stein and Lesley Groff in the above-referenced matter. We write jointly with Defendant (together, the "Defendants") to request an adjournment of the conference scheduled for Octo 10, 2017. This is our first request for adjournment of this conference. + +As Your Honor may recall, the Court issued an Order on July 17, 2017 concerning the de ion and documents Plaintiff produced as a non-party witness in an action captioned v. Maxwell, 15 Civ. 7433 (RWS), pending before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the Jane Doe Evidence, but with only limited success. + +Jane Doe Evidence. I informed Mr. that we would like to make an to Judge Specifically, on July 24, I spoke with Plaintiff's counsel Brad concerning the Sweet for relief from the Protective Order as it applies to the Jane Doe Evidence. On August 8, I wrote to Mr. reiterating our request. On August 10, Mr. infonned me that he would consent to the use of Plaintiff's deposition she gave in the matter, but that he would need an itemized list of the documents we want to use, even thou e documents totaled only 557 pages. On August 17, I wrote to Mr. reiterating our belief that all of the Jane Doe Evidence is relevant to the Motions to Dismiss, ut that I would nonetheless provide him with a list of the documents. On September 1, I wrote to Mr. and reiterated that we want to use all of the Jane Doe Evidence and provided him with copies o the documents that we want to use. We also detailed the reasons as to why the documents are relevant to the Hon. John G. Koeltl October 4, 2017 Page 2 + +Defendants' contemplated Motions to Dismiss. On September 18, Plaintiff's counsel (whose response was delayed due to hurricane damages in Florida) agreed to allow Defendants to use Plaintiff's deposition and only some of the documents she produced, but Plaintiff would not, however, consent to the use of all of the Jane Doe Evidence. + +On October 3, 2017, we submitted a letter motion to Judge Sweet seeking permission to file under seal a motion to modify the Protective Order entered in the matter before him. On October 4, 2017, Judge Sweet granted the letter motion to file unBet eal. As a result, we will be filing tomorrow the motion seeking a modification of the Protective Order so as to permit the use of all of the Jane Doe Evidence to support Defendants' contemplated Motions to Dismiss ("Motion to Modify"),I + +In view of the above, we believe that it would make sense to adjourn the conference Your Honor scheduled for October 10, 2017 pending a decision by Judge Sweet on the Motion to Modify. Once Judge Sweet issues his ruling, Defendants will submit their Motions to Dismiss within seven days of the ruling as provided for in the July 17 Order. + +Even if the Court were not inclined to adjourn the conference pending Judge Sweet's ruling, Defendants request that the conference be scheduled for a date other than October 10. Counsel for both sets of Defendants have scheduling conflicts on that date. + +Plaintiff has not agreed to an adjournment. + +Respectfully submitted, + +6/4i6LIC\_ + +Michael C. Counsel for eendants Jefrey Epstein and Lesley Groff + +Once the motion to modify the Protective Order is submitted to Judge Sweet, we will provide Your Honor with a courtesy copy. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819688/EFTA02819688.metadata.json b/marker2/court-jane-doe-43/EFTA02819688/EFTA02819688.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..557503741423fc05ae2092c2076b93aca87a7e1d --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819688/EFTA02819688.metadata.json @@ -0,0 +1,134 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819688.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3802, + "elapsed_seconds": 0.81, + "image_assets": [ + "_page_0_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 63.036, + 228.41999999999996 + ], + [ + 121.28465270996094, + 228.41999999999996 + ], + [ + 121.28465270996094, + 244.4730224609375 + ], + [ + 63.036, + 244.4730224609375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 85 + ], + [ + "Line", + 41 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 31 + ], + [ + "Text", + 8 + ], + [ + "PageHeader", + 2 + ], + [ + "Caption", + 1 + ], + [ + "Footnote", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819688" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819688/_page_0_Picture_3.jpeg b/marker2/court-jane-doe-43/EFTA02819688/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..4ca17b0d9c9888eaf7e40eb746fe401315a0a9e2 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819688/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d8d792899349bea946ebb7d93a38eb01ea71f82a77feaaab56ebab377dd85682 +size 5155 diff --git a/marker2/court-jane-doe-43/EFTA02819690/EFTA02819690.md b/marker2/court-jane-doe-43/EFTA02819690/EFTA02819690.md new file mode 100644 index 0000000000000000000000000000000000000000..15fc12d8e8934b527178dbd45b090b447dcf8d0f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819690/EFTA02819690.md @@ -0,0 +1,29 @@ +![](_page_0_Picture_1.jpeg) + +![](_page_0_Picture_2.jpeg) + +affe, Weissing, Fistos Et Lehrman, P.L. + +> J. brad @pathtojustice.com + +Honorable John G. Koeltl Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 October 5, 2017 + +RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, et. Al Case No. No. 17 Civ. 00616 (JGK) + +Dear Judge Koeltl: + +We are counsel for the plaintiff in this action, Jane Doe 43. We write to request that the Court continue to plan to hold in the near future a status conference in this matter, although we have no objection to rescheduling the currently-set October 10, 2017, conference to a date that is convenient for defense counsel. + +As the Court is aware, on July 17, 2017, the Court entered an order allowing the defendants to seek release of certain documents from Judge Sweet after the Defendants claimed the materials were necessary for an argument they intended to make in their motion to dismiss to support a claim against jurisdiction and statute of limitations. While the Court appears to have envisioned that the defendants would make that request rapidly, the defendants in fact engaged in protracted negotiations before actually making the request. Plaintiff, Jane Doe 43, simply asked for an inventory of the items Defendants wanted for their stated reason of contesting jurisdiction and statute of limitations at this dismissal stage. It took months for Defendant to provide that inventory and Plaintiffs went through each document consenting to those which could even potentially bear on the two issues for which the Defendant claims to need them. The defendants only filed their request with Judge Sweet on October 4, and has asked for all documents related to Jane Doe 43, most of which have no relation to the current issues. We continue to believe that Defendants are really motivated to delay this action. + +We believe a short status conference would be useful to move this case forward. In particular, at the status conference, given that the Court is allowing Defendants to obtain documents and testimony outside the four corners of the complaint at this stage, we would intend to raise the issue of being allowed a short (one hour) deposition of defendant Epstein, which would shed light on the alleged "jurisdictional" defects in this case. We believe that, just as the defendants are gathering factual information in support of their case (alleged to be contained in Judge Sweet's docket), Jane Doe 43 should be permitted to collected information in support of her case. We believe that a short deposition of Epstein would prove, beyond any doubt, that jurisdiction is proper before the Court and, more broadly, that Jane Doe 43's claims are entirely meritorious. + +In any event, we believe that a short status conference discussing such issues might be productive in moving this case forward. And, accordingly, we ask that the Court hold such a conference at a time that is convenient for the court and counsel in the near future. + +Ve Trul Yours, + +JAFFE, WEISSING, , FISTOS and LEHRMAN, PL + +J. Edwards + +J. 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[REDACTED] +brad@pathtojustice.com + +October 3, 2017 + +APPLICATION GRANTED +SO ORDERED + +Honorable John G. Koeltl +Daniel [REDACTED] Moynihan +United States Courthouse +500 Pearl Street +New York, NY 10007-1312 + +![]()RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, et Al +Case No. No. 17 Civ. 00616 (JGK) + +Dear Judge Koeltl: + +This is a letter motion requesting permission for Plaintiff to telephonically appear for the pretrial conference, currently scheduled for Tuesday, October 10, 2017, at 10:30 am. Thank you very much for your time and consideration. + +Very Truly Yours, +[REDACTED], JAFFE, WEISSING, [REDACTED], FISTOS and LEHRMAN, PL + +Bradley J. [REDACTED] + +[REDACTED] J. 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R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: l J. + +E Jaffe Weissing Fistos & Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale. FL 33301 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: October 4, 2017 + +CLERK OF COURT + +/S/ Symia James + +Signature of Clerk or Deputy Clerk + +![](_page_0_Picture_21.jpeg) + +Civil Action No. 17-cv-616 + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. 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Miller +212 506 3955 +mmiller@steptoe.com + +1114 Avenue of the Americas +New York, NY 10036 +212 506 3900 main +www.steptoe.com + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC# +DATE FILED. 10-6-17 + +![](_page_0_Picture_21.jpeg) + +October 4, 2017 + +**VIA ECF** + +Hon. John G. Koeltl +United States District Court +United States Courthouse +500 Pearl Street +New York, NY 10007-1312 + +Re: **Jane Doe 43 v. Jeffrey Epstein, et al.** +**Civil Action No. 17-cv-616** + +Dear Judge Koeltl: + +We are counsel for Defendants Jeffrey Epstein and Lesley Groff in the above-referenced matter. We write jointly with Defendant [REDACTED] (together, the "Defendants") to request an adjournment of the conference scheduled for October 10, 2017. This is our first request for adjournment of this conference. + +As Your Honor may recall, the Court issued an Order on July 17, 2017 concerning the deposition and documents Plaintiff produced as a non-party witness in an action captioned [REDACTED] v. *Maxwell*, 15 Civ. 7433 (RWS), pending before Judge Robert Sweet ("July 17 Order" and "Jane Doe Evidence", respectively). Pursuant to the July 17 Order, we have sought consent from Plaintiff's counsel to use the Jane Doe Evidence, but with only limited success. + +Specifically, on July 24, I spoke with Plaintiff's counsel Brad [REDACTED] concerning the Jane Doe Evidence. I informed Mr. [REDACTED] that we would like to make an application to Judge Sweet for relief from the Protective Order as it applies to the Jane Doe Evidence. On August 8, I wrote to Mr. [REDACTED] reiterating our request. On August 10, Mr. [REDACTED] informed me that he would consent to the use of Plaintiff's deposition she gave in the [REDACTED] matter, but that he would need an itemized list of the documents we want to use, even though the documents totaled only 557 pages. On August 17, I wrote to Mr. [REDACTED] reiterating our belief that all of the Jane Doe Evidence is relevant to the Motions to Dismiss, but that I would nonetheless provide him with a list of the documents. On September 1, I wrote to Mr. [REDACTED] and reiterated that we want to use all of the Jane Doe Evidence and provided him with copies of the documents that we want to use. We also detailed the reasons as to why the documents are relevant to the + +ADJOURNED SO WEDNESDAY, +OCTOBER 18, 2017, AT 10:30AM. + +SO ORDERED, + +10/5/17 + +*[Signature]* +C S O J + +Hon. John G. Koeltl +October 4, 2017 +Page 2 + +**Steptoe** +STEPTOE & JOHNSON LLP + +Defendants' contemplated Motions to Dismiss. On September 18, Plaintiff's counsel (whose response was delayed due to hurricane damages in Florida) agreed to allow Defendants to use Plaintiff's deposition and only some of the documents she produced, but Plaintiff would not, however, consent to the use of all of the Jane Doe Evidence. + +On October 3, 2017, we submitted a letter motion to Judge Sweet seeking permission to file under seal a motion to modify the Protective Order entered in the [REDACTED] matter before him. On October 4, 2017, Judge Sweet granted the letter motion to file under seal. As a result, we will be filing tomorrow the motion seeking a modification of the Protective Order so as to permit the use of all of the Jane Doe Evidence to support Defendants' contemplated Motions to Dismiss ("Motion to Modify").1 + +In view of the above, we believe that it would make sense to adjourn the conference Your Honor scheduled for October 10, 2017 pending a decision by Judge Sweet on the Motion to Modify. Once Judge Sweet issues his ruling, Defendants will submit their Motions to Dismiss within seven days of the ruling as provided for in the July 17 Order. + +Even if the Court were not inclined to adjourn the conference pending Judge Sweet's ruling, Defendants request that the conference be scheduled for a date other than October 10. Counsel for both sets of Defendants have scheduling conflicts on that date. + +Plaintiff has not agreed to an adjournment. + +Respectfully submitted, + +![]()Michael C. [REDACTED] +*Counsel for Defendants Jeffrey +Epstein and Lesley Groff* + +--- + +1 Once the motion to modify the Protective Order is submitted to Judge Sweet, we will provide Your Honor with a courtesy copy. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819695/EFTA02819695.metadata.json b/marker2/court-jane-doe-43/EFTA02819695/EFTA02819695.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d357411168862198d9d00b08ea71955e8251c68c --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819695/EFTA02819695.metadata.json @@ -0,0 +1,130 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819695.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 4236, + "elapsed_seconds": 9.07, + "image_assets": [ + "_page_0_Picture_21.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 77.36399999999999, + 213.03000000000003 + ], + [ + 125.25599999999999, + 213.03000000000003 + ], + [ + 125.25599999999999, + 224.37 + ], + [ + 77.36399999999999, + 224.37 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 27 + ], + [ + "PageHeader", + 2 + ], + [ + "Picture", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 30 + ], + [ + "Text", + 17 + ], + [ + "PageHeader", + 2 + ], + [ + "Caption", + 2 + ], + [ + "Footnote", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819695" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819695/_page_0_Picture_21.jpeg b/marker2/court-jane-doe-43/EFTA02819695/_page_0_Picture_21.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..90827e941ba6ff4d2868fb280f93fda5b72c2410 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819695/_page_0_Picture_21.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a998490fe8a4b10de1ca8ebbfe4137ac65dc69c279e8c69c24efb87c2b4072c4 +size 4638 diff --git a/marker2/court-jane-doe-43/EFTA02819697/EFTA02819697.md b/marker2/court-jane-doe-43/EFTA02819697/EFTA02819697.md new file mode 100644 index 0000000000000000000000000000000000000000..c80b457d20668993b5555fb4fca2dfd2bcf73263 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819697/EFTA02819697.md @@ -0,0 +1,49 @@ +Michael C. [REDACTED] +212 506 3955 +mmiller@steptoe.com + +1114 Avenue of the Americas +New York, NY 10036 +212 506 3900 main +www.steptoe.com + +![](_page_0_Picture_15.jpeg) + +October 12, 2017 + +**SUBMITTED UNDER SEAL** + +Hon. John G. Koeltl +United States District Court +United States Courthouse +500 Pearl Street +New York, NY 10007-1312 + +**Re: Jane Doe 43 v. Jeffrey Epstein, et al. +Civil Action No. 17-cv-616** + +Dear Judge Koeltl: + +We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") in the above-referenced matter (the "Jane Doe Matter") and write to respond to Plaintiff's October 5, 2017 letter to the Court ("October 5 Letter"). In the October 5 Letter, Plaintiff claims (without merit) that Defendants are engaging in discovery in the Jane Doe Matter and asserts that Plaintiff should be permitted to engage in reciprocal discovery. In fact, Defendants are not engaging in any discovery in the Jane Doe Matter, and Plaintiff should not be permitted to launch one-sided and premature discovery in the Jane Doe Matter. Defendants respectfully submit that the Court should deny Jane Doe's application to engage in discovery. + +Far from engaging in any discovery in the Jane Doe Matter, Defendants are seeking permission to use documents they already possess. As we previously advised the Court, Plaintiff voluntarily gave deposition testimony and produced documents relating to the allegations in the Jane Doe Matter in a matter captioned [REDACTED] v. Maxwell, No. 15 Civ. 7433 (RWS) (the "[REDACTED] Matter") (the "Jane Doe Evidence"). The Jane Doe Evidence, given by Plaintiff shortly after she filed the Jane Doe Matter, was designated as Confidential pursuant to the Protective Order in the [REDACTED] Matter. Mr. Epstein, as a non-party witness in the [REDACTED] Matter, was provided with a copy of the Jane Doe Evidence. The Jane Doe Evidence, as it turns out, is dispositive of the motion to dismiss that Defendants plan to file in the Jane Doe Matter ("Motion to Dismiss"). In particular, the Jane Doe Evidence demonstrates that Plaintiff's claim in the Jane Doe Matter is barred by the longest potentially applicable ten-year statute of limitations, the Court in the Jane Doe Matter lacks personal jurisdiction over Defendants, and Plaintiff cannot plead a legally sufficient amended complaint. In short, the Jane Doe Evidence establishes that the Jane Doe Matter should be dismissed with prejudice. + +Hon. John G. Koeltl October 12, 2017 Page 2 + +On July 14, 2017, we wrote to this Court seekingL(2Larmission to file amotion requesting relief from the Protective Order issued in the Matter to permit Defendants to use the Jane Doe Evidence in support of the Motion to Dismiss; and (b) abrief stay of the schedule for the Motion to Dismiss. On July 17, 2017, Plaintiff submitted aletter to the Court opposing Defendants' request. In particular, Plaintiff contended that Defendants may obtain the information contained in the Jane Doe Evidence by deposing Plaintiff and that Plaintiff "can obtain her own information relevant to jurisdiction by deposing Epstein and other Defendants in this case" (letter at p. 2). On July 17, 2017, the Court granted Defendants' request, and issued an Order under seal, directing (a) Defendants to make their application for relief from the Protective Order to Judge Sweet and (b) file their Motion to Dismiss within seven (7) days after Judge Sweet's decision (the "July 17 Order"). + +In accordance with the 17Order, we attempted to reach agreement with Plaintiff that the Protective Order in the Matter should be modified to permit Defendants to use the Jane Doe Evidence in support of the Motion to Dismiss. After several rounds of negotiation, Plaintiff has agreed to support a piecemeal modification of the Protective Order, permitting Defendants only to use Plaintiff's deposition transcript and ahandful of her 557 page document production in the Matter. As a result, Defendants filed amotion before Judge Robert W. Sweet on October 5, 2017, seeking permission to use all of the Jane Doe Evidence in support of the Motion to Dismiss the Jane Doe Matter. All of this, of course, would have been avoided had Plaintiff simply consented to a logical modification of the Protective Order to permit the use of the Jane Doe Evidence in its entirety; the Motion to Dismiss would have been submitted to Your Honor long ago. + +Contrary to laintiff's contention, and as noted above, Defendants have not engaged in discovery from the Matter. Rather, the Defendants already possess the Jane Doe Evidence. The Court's consideration of the Jane Doe Evidence would promote judicial economy, as that evidence allows the Court to dispose of the Jane Doe Matter at the motion to dismiss stage. In its July 17 Order, the Court granted Defendants' request to seek leave to use the Jane Doe Evidence in the Motion to Dismiss and stayed the schedule for the Motion to Dismiss pending adecision by Judge Sweet. Accordingly, the July 17 Order provides that: "The time to make amotion to dismiss in this case is stayed until seven (7) days after the decision in the other case I Matter] as to whether to grant an exception to the Protective Order." July 7 Order, p. 1. + +Plaintiff's request for the deposition of Mr. Epstein is merely arehash of the argument previously made to the Court and essentially an attempt for re-argument to modify the July 17 Order. The Court has already heard that argument and ruled in Defendants' favor. Moreover, Plaintiff has not provided any reason that the July 17 Order should be modified. The Jane Doe Evidence is dispositive of the Motion to Dismiss and there is no need for any deposition of Mr. Epstein or any other discovery to dispose of this matter in its entirety. + +Hon. John G. Koeltl October 12, 2017 Page 3 + +We respectfully submit that there is no reason to deviate from the July 17 Order. The motion for relief from the Protective Order has been submitted to Judge Sweet. A courtesy copy of the motion was provided to Your Honor on October 6, 2017. As Your Honor will note, adraft of Defendants' Motion to Dismiss, which discusses the Jane Doe Evidence in detail, is attached to the motion submitted to Judge Sweet. Once Judge Sweet rules on the motion, Defendants will submit their Motion to Dismiss within seven (7) days as provided for in the July 17 Order, so that the Motion to Dismiss can be filed in amanner consistent with Judge Sweet's ruling. The Court then can dispose of this matter in its entirety. + +Respectfully submitted, + +4' Mt - ( 64 Michael C. Mil e Counsel for Defendants Jet , Epstein and Lesley Groff + +cc: All counsel of record (via email) \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819697/EFTA02819697.metadata.json b/marker2/court-jane-doe-43/EFTA02819697/EFTA02819697.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..287ac483c7302f76841d8a1c857afe8e16560736 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819697/EFTA02819697.metadata.json @@ -0,0 +1,152 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819697.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 6702, + "elapsed_seconds": 8.04, + "image_assets": [ + "_page_0_Picture_15.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "SUBMITTED UNDER SEAL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 64.872, + 216.27 + ], + [ + 222.768, + 216.27 + ], + [ + 222.768, + 229.23 + ], + [ + 64.872, + 229.23 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 16 + ], + [ + "PageHeader", + 2 + ], + [ + "Picture", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 658 + ], + [ + "Line", + 45 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 205 + ], + [ + "Line", + 21 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819697" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819697/_page_0_Picture_15.jpeg b/marker2/court-jane-doe-43/EFTA02819697/_page_0_Picture_15.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..472f40ce82e604d74aa6cebdbc1a396f966e21da --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819697/_page_0_Picture_15.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d051f2b372ed3c3b409970bf586280645d9486a9c0e9931c96d4b7280b86d5cc +size 4646 diff --git a/marker2/court-jane-doe-43/EFTA02819700/EFTA02819700.md b/marker2/court-jane-doe-43/EFTA02819700/EFTA02819700.md new file mode 100644 index 0000000000000000000000000000000000000000..77d876415226694b3f89dadbb8a811ce7f504d7d --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819700/EFTA02819700.md @@ -0,0 +1,29 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +Plaintiff, + +- against - + +JEFFREY EPSTEIN, ET AL., + +Defendants. + +USDC SONY DOCUMENT ELECTRONICALLY FILED DCC:: DATE FILED: /0/131(7 + +17 Civ. 616 (JGK) + +ORDER + +JOHN G. KOELTL, District Judge: + +The deadline for the defendants to file their motion to dismiss is seven days after Judge Sweet issues a decision on the defendants' motion to intervene and modify the protective order. + +The stay of discovery remains in effect. + +SO ORDERED. + +Dated: New York, New York October 18, 2017 + +Si l ? John G. Koeltl Um. d States District Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819700/EFTA02819700.metadata.json b/marker2/court-jane-doe-43/EFTA02819700/EFTA02819700.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0679de60e693a6b983c8b49b806ec1b6ec5912ca --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819700/EFTA02819700.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819700.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 600, + "elapsed_seconds": 0.76, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 27 + ], + [ + "Text", + 15 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819700" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819701/EFTA02819701.md b/marker2/court-jane-doe-43/EFTA02819701/EFTA02819701.md new file mode 100644 index 0000000000000000000000000000000000000000..0319d8eeb1cfffc6f7cb4b9e244e9fa4a46e48e3 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819701/EFTA02819701.md @@ -0,0 +1,49 @@ +![](_page_0_Picture_1.jpeg) + +Haddon. and v c Laura A. Menninger + +150 Eost 10th Avenue Denver, Colorado 80203 PH 303.831.7364 DC 303.832.2628 www.hrnflaw.com Imenningerthmflaw.com + +October 30, 2017 + +## Via Email + +Hon. John G. Koeld United States District Judge United States District Court Daniel Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 + +Re: Jane Doe 43 v. Jeffrey Epstein, et at, 17-cv-00616 (JGK) + +Dear Judge Koeltl: + +As you know. I ananySw partners, Jeffrey Pagliuca and Ty Gee, of the law firm Haddon, & P.C., represented Ms. Ghislaine Maxwell in Case No. 15-cv-7433 (RWS) (S.D.N.Y.), which was dismissed with prejudice on May 25, 2017. v. Maxwell, Case No. 15-cv-7433 (RWS) (S.D.N.Y. May 25,2017), ECF No. 919. Our firm has retained Sher Tremonte LLP with regard to this Court's Order, ECF No. 57, authorizing substitute service on "counsel for Maxwell in 15-cv-7433 (S.D.N.Y)," in the matter pending in this Court. + +On today's date, Sher Tremonte has filed a letter motion seeking an opportunity on our behalf to oppose Plaintiffs motion for alternative service, or to seek reconsideration of the Court's Order granting that motion. ECF No. 68. On behalf of, but not having consulted with, Ms. Maxwell we join in that motion. + +In an abundance of caution on behalf of Ms. Maxwell, and without consulting with Ms. Maxwell, we request that the Court extend the time to respond, if necessary, to the Complaint in this matter until 21 days after the Court rules on our counsel's letter motion. + +Hon. John G. Koeltl October 30, 2017 Page 2 + +Respectfully submitted, + +HADDON, AND~, P.C. + +Is/ Laura A. Menninger + +Laura A. Menninger + +## CERTIFICATE OF SERVICE + +I certify that on October 30, 2017, 1 served the accompanying Letter Motion on the following counsel of record: + +Sigrid S. McCawley Meredith BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com + +, JAFFE, WEISSING, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com + +John E. Stephenson, Jr. Alexander S. Lorenzo ALSTON & BIRD, LLP 90 Park Avenue New York, NY 10016 john.stephenson@alston.com alexander.lorenzo@alston.com + +Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu + +Michael C. Justin Y.K. STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoe.com jchu@steptoe.com + +Is! Nicole + +Nicole \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819701/EFTA02819701.metadata.json b/marker2/court-jane-doe-43/EFTA02819701/EFTA02819701.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..638c5aa3082c62649dea07568e42415d90af40d5 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819701/EFTA02819701.metadata.json @@ -0,0 +1,153 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819701.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2508, + "elapsed_seconds": 0.84, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Via Email", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 123.62400000000002, + 212.22000000000003 + ], + [ + 180.92218017578125, + 212.22000000000003 + ], + [ + 180.92218017578125, + 227.60302734375 + ], + [ + 123.62400000000002, + 227.60302734375 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 250.308, + 226.8 + ], + [ + 415.94989013671875, + 226.8 + ], + [ + 415.94989013671875, + 242.2330322265625 + ], + [ + 250.308, + 242.2330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 82 + ], + [ + "Line", + 38 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 88 + ], + [ + "Line", + 44 + ], + [ + "Text", + 13 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819701" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819701/_page_0_Picture_1.jpeg b/marker2/court-jane-doe-43/EFTA02819701/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3fb4dfb595bd5e4df9a603b59eb51da9d74e8a48 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819701/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4347872d0ef8578d3b1bb9dc5d9d2abdb3e7f67ee28ecb108163f8ee914180c7 +size 6400 diff --git a/marker2/court-jane-doe-43/EFTA02819703/EFTA02819703.md b/marker2/court-jane-doe-43/EFTA02819703/EFTA02819703.md new file mode 100644 index 0000000000000000000000000000000000000000..ff59f0a630c8a745e15151e49d68339949a667cf --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819703/EFTA02819703.md @@ -0,0 +1,65 @@ +VIA ECF October 30, 2017 + +The Honorable John G. Koeltl United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 + +> Re: Jane Doe 43 v. Epstein et al., No. 17 Civ. 616 (JGK) + +Dear Judge Koeltl: + +We represent non-party Haddon, and M, P.C. "Haddon MD, which represented Defendant Ghislane Maxwell ("Maxwell") in v Maxwell, Case No. 15-cv-7433 (RWS) (S.D.N.Y.) (the `M Action"). + +We write to respectfully request an opportunity to oppose Plaintiff's motion for alternative service on Maxwell through Haddon or to seek reconsideration of the Court's order granting that motion, to which Haddon was not provided notice or any opportunity to respond. + +### Procedural Background + +As the Court knows counsel for Plaintiff in this action were also counsel for another plaintiff in the Action, filed in 2015. Haddon represented Maxwell as a defendant in that case. Maxwell and the plaintiff in that case reached a settlement, and the claims against her were dismissed with prejudice on May 25, 2017, see So Ordered Joint Stipulation for Dismissal, v Maxwell, Case No. 15 Civ. 7433 (RWS) (S.D.N.Y. May 25, 2017), ECF No. 919. + +This action before Your Honor has been pending since January 26, 2017. See Complaint, Dkt. No. 1. On May 11, 2017, Plaintiff filed a motion seeking an additional 90 days to serve Maxwell (Dkt. No. 34), which the Court granted on May 12, 2017 (Dkt. No. 36). On August 10, 2017, Plaintiff's last day to serve Maxwell, Plaintiff filed a motion for alternative service pursuant to Federal Rule of Civil Procedure 4(e)(1) and New York Civil Practice Law and Rules ("CPLR") § 308(5) (Dkt. No. 55) (the "Alternative Service Motion"). The Court issued an order granting the Alternative Service Motion on September 29, 2017 (the "Order"). Thereafter, Plaintiff handdelivered a copy of the Summons and Amended Complaint in this matter to Haddon offices in Denver, Colorado on October 9, 2017. + +Haddon [REDACTED] had not been served with the Alternative Service Motion when originally filed, and had no notice of it until after the Court entered the Order. Because the Order places Haddon [REDACTED] in the unusual position of being compelled to accept service beyond the scope of its engagement or the client's authorization, and because certain relevant information was omitted from the Alternative Service Motion, Haddon [REDACTED] engaged my firm to submit this application for relief from the Order. + +### **Plaintiff's Factual Assertions Were Incomplete and Misleading** + +Plaintiff made numerous factual assertions that Haddon [REDACTED] would have challenged had it been served with a copy of the Alternative Service Motion when filed. + +First, Plaintiff's counsel neglected to inform the Court that Maxwell – described throughout the press as a “British Socialite” – owns a residence in London. Indeed, Maxwell's London home was the subject of motion practice in the [REDACTED] Action, in which the same counsel who represent Plaintiff here sought disclosure as to what they called “Maxwell's . . . home.”1 Maxwell's residence in London has also been discussed in publicly available documents in yet another lawsuit.2 We respectfully submit that the existence of a known residence on which service had not been attempted would have been fatal to the Alternative Service Motion. + +Second, Plaintiff's counsel asserted “[i]t is clear” that Maxwell was purposefully and intentionally evading service,” Alt. Serv. Mot. ¶ 2, even though Plaintiff admits not attempting any service that could have been evaded. Plaintiff's counsel only describes one “attempt” at service at a Manhattan address nine days before their extended deadline expired. Plaintiff and her counsel abandoned the attempt when they realized the business address, supposedly affiliated with Maxwell, turned out to be a UPS store. *See* Alt. Serv. Mot. ¶¶ 6, 7. Nothing in Plaintiff's submission, however, evidences that Maxwell was actually evading service, as there was no attempt at service to evade. + +Third, Plaintiff's counsel not only imagined that Maxwell was evading service, they baselessly attempted to link Haddon [REDACTED] to such efforts. Plaintiff's counsel submitted that Maxwell “has instructed her counsel not to accept service, and has also instructed her counsel not to disclose her whereabouts in response to inquiries related to effectuating service in this case.” Alt. Serv. Mot. ¶ 4. Plaintiff's counsel had no conceivable basis to make such assertions about communications between Haddon [REDACTED] and Maxwell; certainly, Haddon [REDACTED] never informed Plaintiff's counsel of + +--- + +1 *See* Plaintiff [REDACTED] Motion to Compel the Production of Documents Subject to Improper Objections at 22, [REDACTED] v. *Maxwell*, No. 15 Civ. 7433 (RWS) (S.D.N.Y. Feb. 26, 2016), ECF No. 404. + +2 *See also* Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in Action at 5, *Jane Doe #1 and Jane Doe #2 v. United States*, No. 9:08-cv-80736 (KAM) (S.D. Fla. Dec. 30, 2014), ECF No. 279 (referencing “Ghislaine Maxwell's apartment” in London). *See also*, e.g., Guy [REDACTED] & Tom Leonard, *Why ARE the Rich and Powerful So in Thrall to Ghislaine Maxwell?*, The Daily Mail.com (Jan. 9, 2015; 8:44 PM), . + +an such instructions. Moreover, although still counsel of record for Maxwell in the Action, and attending to post-termination matters (i.e., confidentiality issues), Haddon has no occasion to know Maxwell's current whereabouts. + +## The Alternative Service Motion was Not Well Founded as a Matter of Law + +Plaintiff's Alternative Service Motion was based on Fed. R. Civ. P. 4(e) and CPLR § 308(5), neither of which supported alternative service in light of the facts noted above. Rule 4(e)(I) provides for service on an individual by "following state law for serving a summons in an action brought in courts of general jurisdiction in the state where the district court is located or where service is made." Fed. R. Civ. P. 4(e)(I). In turn, CPLR § 308(5), the New York state law provision governing service of summons, provides for alternative service, but only upon a showing that "service is impracticable" under conventional means of service,; and even then, only "[fin such manner as the court, upon motion without notice, directs." N.Y. C.P.L.R. § 308(5) (emphasis added); see also Bozza v. Love, No. 15-cv-3271 (LGS), 2015 WL 4039849, at \*1 (S.D.N.Y. July 1, 2015). + +"Though the impracticability standard is not capable of easy definition, .... a plaintiff seeking to effect alternative service must make some showing that the other prescribed methods of service could not be made." Bozza, 2015 WL 4039849, at "1 (internal citations omitted); see also Markoff v. S. Nassau Cmty. Hosp., 61 N.Y.2d 283, 287 n.2 (1984) (finding a "conclusory affidavit stating that service was impracticable ... was insufficient to justify the order of expedient service under CPLR 308 (subd. 5)"). Preza v. Sever's Gourmet, 212 A.D.2d 765, 765 (2d Dep't 1995) (finding alternative service was improperly granted). In particular, courts have found the impracticability standard unsatisfied where the defendant could have been properly served in a foreign country. See, e.g., Yamamoto v. Yamamoto, 43 A.D.3d 372, 373 (1st Dep't 2007) (where defendant was located in Japan, in "the absence of any evidence that service in that manner is 'impracticable,' the court properly denied plaintiffs request, pursuant to CPLR 308(5), for an order directing that service on defendant be effectuated by personal delivery of process upon his attorneys.").4 + +Here, Plaintiff has failed to make the requisite showing of "impracticability" in order to justify a court-ordered alternate method of service. Plaintiff's counsel cites "intemet inquiries" without elaboration. Plaintiff's counsel further cites a single "attempt" at service — initiated only nine days before the expiration of Plaintiff's deadline + +3Specifically, substitute service is available only where it is impracticable to serve an individual under CPLR § 308(1), (2), or (4) — the provisions for personal service, leave-and-mail, and nail-and-mail. See N.Y. C.P.L.R. § 308(5). + +4Pursuant to Fed.R.Civ.P. 4(f), an individual may be served in a foreign country' by any internationally agreed means of service that is reasonably calculated to give notice, such as those authorized by the Hague Convention on the Service Abroad of Judicial and Extrajudicial Documents" (the "Hague Convention"). Fed. R. Civ. P. 4(t). The United Kingdom and the United States are both signatories to the Hague Convention. + +to serve Maxwell, and then abandoned. Plaintiff failed to inform the Court of Maxwell's residence in London, and has never purported to have attempted service there. In short, Plaintiff should not have asked the Court to enlist Maxwell's counsel as an agent of service, in lieu of bona fide diligent efforts to serve her. + +## Conclusion + +For the reasons set forth above, we respectfully request that the Court withdraw its Order, or permit Haddon an opportunity to oppose Plaintiff's Alternative Service Motion or to file a motion to reconsider. We further respectfully request that any deadlines to formally answer or res iand to the Complaint be held in abeyance pending the Court's resolution of Haddon objections to service. + +Respectfully submitted, + +/s/ Kimo S. Peluso + +Kimo S. Peluso + +cc: All counsel of record (via ECF) + +Haddon, & . 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John G. Koeltl United States District Judge United States District Court Daniel Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 + +Haddon, and r c Laura A. MennIngor + +150 East ;0'h Avenue Denver. Colorado 80203 PH 303831 7364 rr 303 832 2628 www Naas./ corn Irnc•nnangerehmlave Com + +USDC SONY DOCUMENT 7,TRC'.ICALLY FILED \_\_\_ \_\_ + +Re: Jane Doe 43 v. Jeffrey Epstein, et al., 17-cv-00616 (JGK) + +Dear Judge Kochi: + +As you know 1 anca, partners, Jeffrey I'agliuca and Ty Gee, of the law firm Iladdon, & P.C., represented Ms. Ghislaine Maxwell in Case No. 15-cv-7433 (RWS) (S.D.N.Y.), which was dismissed with prejudice on May 25, 2017. v Maxwell, Case No. 15-cv-7433 (RWS) (S.D.N.Y. May 25, 2017), ECF No. 919. Our firm has retained Sher Tremonte LIP with regard to this Court's Order, Ea; No. 57, authorizing substitute service on "counsel for Maxwell in 15-cv-7433 (S.D.N.Y)," in the matter pending in this Court. + +On today's date, Sher Tremonte has filed a letter motion seeking an opportunity on our behalf to oppose Plaintiffs motion for alternative service, or to seek reconsideration of the Court's Order granting that motion. ECF No. 68. On behalf of, but not having consulted with, Ms. Maxwell we join in that motion. + +In an abundance of caution on behalf of Ms. Maxwell, and without consulting with Ms. Maxwell, we request that the Court extend the time to respond, if necessary, to the Complaint in this matter until 21 days after the Court rules on our counsel's letter motion. + +> 9/ 3 Jaohn G. Knelt). I' I s D. 1 + +APPLICATION GRANTED SO ORDERED + +Hon. John G. Koeltl October 30, 2017 Page 2 + +Respectfully submitted, + +HADooN, AM)l~p P.C. + +/s/ Laura A. Menninger + +Laura A. Menninger + +## CERTIFICATE OF SERVICE + +I certify that on October 30, 2017, I served the accompanying Letter Motion on the following counsel of record: + +Sigrid S. McCawley Meredith Horns, SCHILLER & FLExt Re: Jane Doe 43 v. Epstein a al., No. 17 Cr/. 616 (J0K) + +Dear Judge Koeltl: + +We represent non-party IIaddon, and which represented Defendant Ghislane Maxwell ("Maxwell") in P.C. laddon v Maxwell, Case No. 15-cv-7433 (RWS) (S.D.N.Y.) (the `=l Action"). + +We write to respectfully request an opportum to oppose Plaintiff's motion for alternative service on Maxwell through Haddon or to seek reconsideration of the Court's order granting that motion, to which fladdon was not provided notice or any opportunity to respond. + +October 30, 2017 + +4 cowfiCA-&-te wt cc- 96 A/6O pr ivEsOni /vov66-40- it no i 4 1 5:00/r • + +SO A. 60 Aar. - S 0 4 107 + +# Procedural Background + +As the Court knows counsel for Plaintiff in this action were also counsel for another plaintiff in the Action, filed in 2015. Haddon represented Maxwell as a defendant in that case. Maxwell and the plaintiff in that case reached a settlement, and the claims against her were dismissed with prejudice on May 25, 2017, see So Ordered Joint Stipulation for Dismissal, v Maxwell, Case No. 15 Civ. 7433 (RWS) (S.D.N.Y. May 25, 2017), ECF No. 919. + +This action before Your honor has been pending since January 26, 2017. See Complaint, Dkt. No. I. On May 11, 2017, Plaintiff filed a motion seeking an additional 90 days to serve Maxwell (Dkt. No. 34), which the Court granted on May 12, 2017 (Dkt. No. 36). On August 10, 2017, Plaintiff's last day to serve Maxwell, Plaintiff filed a motion for alternative service pursuant to Federal Rule of Civil Procedure 4(e)(1) and New York Civil Practice Law and Rules ("CPLR") § 308(5) (Dkt. No. 55) (the "Alternative Service Motion"). The Court issued an order granting the Alternative Service Motion on September 29, 2017 (the "Order"). Thereafter, Plaintiff handdelivered a copy of the Summons and Amended Complaint in this matter to Haddon offices in Denver, Colorado on October 9, 2017. + +USOC SONY DOCUMENT ELECTRO\*IICALLY FILED DOC# DATE FILED: ii' 3 -1'! lion. John G. KoeItl October 30, 2017 Page 2 + +Haddon had not been served with the Alternative Service Motion when onginally filed, and had no notice of it until after the Court entered the Order. Because the Order places ilarldon in the unusual position of being compelled to accept service beyond the scope of its engagement or the client's authorization, and because certain relevant information was omitted from the Alternative Service Motion, Haddon engaged my firm to submit this application for relief from the Order. + +### Plaintiff's Factual Assertions Were Incomplete and Misleading + +Plaintiff made numerous factual assertions that Haddon would have challenged had it been served with a copy of the Alternative Service Motion when filed. + +First, Plaintiffs counsel neglected to inform the Court that Maxwell — described throughout the press as a "British Socialite" - owns a residence in London. Indeed, Maxwell's London home was the subject of motion practice in the Action, in which the same counsel who represent Plaintiff here sought disclosure as to what they called "Maxwell's . . . home."' Maxwell's residence in London has also been discussed in publicly available documents in yet another lawsuit= We respectfully submit that the existence of a known residence on which service had not been attempted would have been fatal to the Alternative Service Motion. + +Second, Plaintiff's counsel asserted lilt is clear" that Maxwell was purposefully and intentionally evading service," Alt. Serv. Mot. ¶ 2, even though Plaintiff admits not attempting any service that could have been evaded. Plaintiff's counsel only describes one "attempt" at service at a Manhattan address nine days before their extended deadline expired. Plaintiff and her counsel abandoned the attempt when they realized the business address, supposedly affiliated with Maxwell, turned out to be a UPS store. See Alt. Serv. Mot. 11 6, 7. Nothing in Plaintiff's submission, however, evidences that Maxwell was actually evading service, as there was no attempt at service to evade. + +Third, Plaintiff's counsel not only ima coed that Maxwell was evading service, they baselessly attempted to link Haddon to such efforts. Plaintiffs counsel submitted that Maxwell "has instructed her counsel not to accept service, and has also instructed her counsel not to disclose her whereabouts in response to inquiries related to effectuating service in this case." Alt. Serv. Mot. 9 4. Plaintiffs counsel had no conceivable basis to make such assertions about communications between Haddon and Maxwell; certainly, Haddon never informed Plaintiff's counsel of + +'See Plaintiff Motion to Compel the Production of Documents Subject to Improper Objections at 22. v Maxwell, No. 15 Civ. 7433 (RWS) (S D.N Y Feb. 26, 2016), ECF No. 404. + +zSee also lane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in Action at 5, Jane Doe #1 and Jane Doe #2 v. United States, No. 9:08-cv-80736 (KAM) (SD. Fla. Dec 30 2014). ECF No. 279 (referencing "Gluslane Maxwell's apartment" in London) See also, e.g., Guy III & Tom Leotard. Why ARE the Rich and Powerful So an Thrall to Ghtlsaine Maxwell', The Daily Mai corn (Jan. 9, 2015, 8.44 PM). httrftwww.dailymail.co.uldnewsAutele-2904115/Ghislame-Maxwell•s-link-sex-scandal-courtpapers-involving-Prince-Andrew-Jeffery-Epstein-don4-stop-having-amazing-social-connections html. + +Hon. John G. Kochi October 30, 2017 Page 3 + +an such instructions. Moreover, although still counsel of record for Maxwell in the Action and attending to post-termination matters (i.e., confidentiality issues), Haddon has no occasion to know Maxwell's current whereabouts. + +#### The Alternative Service Motion was Not Well Founded as a Matter of Law + +Plaintiffs Alternative Service Motion was based on Fed. It Civ. P. 4(c) and CPLR § 308(5), neither of which supported alternative service in light of the facts noted above. Rule 4(e)(1) provides for service on an individual by "following state law for serving a summons in an action brought in courts of general jurisdiction in the state where the district court is located or where service is made." Fed. R. Civ. P. 4(e)(I). In turn, CPLR § 308(5), the New York state law provision governing service of summons, provides for alternative service, but only upon a showing that "service is impracticable" under conventional means of service,3 and even then, only "[iln such manner as the court, upon motion without notice, directs." N.Y. C.P.L.R. § 308(5) (emphasis added); see also Bozza v. Love, No. 15-cv-3271 (LGS), 2015 WL 4039849, at \*1 (S.D.N.Y. July I, 2015). + +"Though the impracticability standard is not capable of easy definition, a plaintiff seeking to effect alternative service must make some showing that the other prescribed methods of service could not be made." Bozza, 2015 WL 4039849, at \*1 (internal citations omitted); see also Markoff v. S. Nassau Cray Hosp., 61 N.Y.2d 283, 287 n.2 (1984) (finding a "conclusory affidavit stating that service was impracticable . . . was insufficient to justify the order of expedient service under CPLR 308 (subd 5)"). Preza v. Sever's Gourmet, 212 A.D.2d 765, 765 (2d Dep't 1995) (finding alternative service was improperly granted). In particular, courts have found the impracticability standard unsatisfied where the defendant could have been properly served in a foreign country. See, e.g., Yamamoto v. Yamamoto, 43 A.D.3d 372, 373 (1st Dep't 2007) (where defendant was located in Japan, in "the absence of any evidence that service in that manner is 'impracticable,' the court properly denied plaintiff's request, pursuant to CPLR 308(5), for an order directing that service on defendant be effectuated by personal delivery of process upon his attorneys.' ).4 + +Here, Plaintiff has failed to make the requisite showing of "impracticability" in order to justify a court-ordered alternate method of service. Plaintiff's counsel cites "intemet inquiries" without elaboration. Plaintiff's counsel further cites a single "attempt" at service — initiated only nine days before the expiration of Plaintiffs deadline + +— — — — 'Specifically, substitute service is available only where it is impracticable to serve an individual under CPLR § 308(1), (2), 01(4) — the provisions for personal service, leave-and-mail, and nad-and-mail See N.Y. C.P L.R. § 308(5) + +'Pursuant to Fed.R Civ P. 4(1), an individual may be served in a foreign country - by any internationally agreed means of service that is reasonably calculated to give notice, such as those authorized by the Hague Convention on the Service Abroad of Judicial and Extrajudicial Documents" (the "Hague Convention'). Fed. R. Civ. P 4(f) The United Kingdom and the United States are both signatories to the Hague Convention

October 30, 2017

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to serve Maxwell, and then abandoned. Plaintiff failed to inform the Court of Maxwell's residence in London, and has never purported to have attempted ser=vice there. In shert, Plaintiff should not have asked the Court to enlist Maxwell's counsel as an agent of service, in Geu bona fide cliliieiiteTTOrtsgtrysher.

Conclusion

For the reasons set forth above, we respectfully request that the Court withdraw its Order, or permit Haddon an opportunity to oppose Plaintiff's Alternative Service Motion or to file a motion to reconsider. We further respectfully request that any deadlines to formally answer or respond to the Complaint be held in abeyance pending the Court's resolution of Haddon objections to service.

Respectfully submitted,

/s/Kimo S. Peluso

Kimo S. Peluso

cc: All counsel of record (via ECF)

Haddon, & P.C. 150 E 10th Avenue Denver, CO 80203

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PELUSO of Sher Tremonte LLP, an attorney duly admitted to practice before this Court, hereby enters an appearance in this action as counsel for interested party Haddon, & P.C. + +Dated: New York, New York November 3, 2017 + +SHER TREMONTE LLP + +By: /s/Kimo S. Peluso Kimo S. Peluso + +90 Broad Street, 23rd Floor New York, New York 10004 (212) 202-2600 (212) 202-4156 (fax) kpeluso@shertremonte.com + +Attorneys for Haddon, & P.C. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819713/EFTA02819713.metadata.json b/marker2/court-jane-doe-43/EFTA02819713/EFTA02819713.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ccc14a8e38765ba4353319feacb2d431762e38ef --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819713/EFTA02819713.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819713.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 727, + "elapsed_seconds": 0.76, + "image_assets": [], + "marker_metadata": { 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TREMONTE LLP + +By: /s/ Justine Harris Justine Harris + +90 Broad Street, 23rd Floor New York, New York 10004 (212) 202-2600 (212) 202-4156 (fax) jharris@shertremonte.com + +Attorneys for Haddon, P.C. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819714/EFTA02819714.metadata.json b/marker2/court-jane-doe-43/EFTA02819714/EFTA02819714.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ec56ccef9efdbec91ed0ac599c1f240b1f13cd86 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819714/EFTA02819714.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819714.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 726, + "elapsed_seconds": 0.74, 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Peluso direct: (212) 300-2442 kpelusoeshenremonte.com + +VIA ECF November 9, 2017 + +The Honorable John G. Koeltl United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 + +> Re: Jane Doe 43 v. Epstein et al., No. 17 Civ. 616 (JGK) + +Dear Judge Koeltl: + +On behalf of non-party Haddon, and P.C. ("Haddon M"), we write to request an adjournment of the conference currently scheduled for November 14, 2017 at 3:00 pm. (Dkt. No. 71), which the Court scheduled in response to our letter dated October 30, 2017 (Dkt. No. 69). + +We are unavailable to attend the conference on November 14 due to travel arrangements made before Your Honor's order. We request that the conference be adjourned to November 28, 29, 30 or December 1, 4, 5, 10, II, 12 or 13. There have been no previous requests to adjourn the conference. Plaintiff and counsel for the other parties who have appeared have consented to this request. + +Respectfully submitted, + +/s/Kimo S. Peluso + +Kimo S. 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newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819720/EFTA02819720.md b/marker2/court-jane-doe-43/EFTA02819720/EFTA02819720.md new file mode 100644 index 0000000000000000000000000000000000000000..6c8ebed9f1e4902f532139bd921bdac6ac73f2a4 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819720/EFTA02819720.md @@ -0,0 +1,45 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +### MEMORANDUM IN OPPOSITION TO LETTER MOTION TO OPPOSE ALTERNATIVE SERVICE ON MAXWELL + +# REDACTED + +### Conclusion + +The motion for the Court to reconsider its order should be denied. + +Dated: November 13, 2017 Respectfully submitted, + +M IAFFE, WEISSING, FISTOS&LEHRMAN, P.L. + +/s/~J. + +J. + +425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: brad@pathtojustice.com Attorney for Plaintiff Jane Doe 43 + +#### CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on the 13th of November, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. + +Kimo S. Peluso Sher Tremonte, LLP 90 Broad Street, 2r Floor New York, NY 10004 kpeluso@sheruemonte.com + +Counsel for Haddon, & P.C. + +Laura A. Menninger, Esq. Jeffrey Pagliuca Es . HADDON, & 150 East 101° Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmfiaw.com jpagliuca@hmflaw.com , P.C. + +Michael C. 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoie.com Counsel for Defendants, Jeffrey Epstein and Lesley Groff + +/s/ J \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819720/EFTA02819720.metadata.json b/marker2/court-jane-doe-43/EFTA02819720/EFTA02819720.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..258f2e09d9b1fd417982a6862c53ff04a83a30c1 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819720/EFTA02819720.metadata.json @@ -0,0 +1,216 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819720.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false 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b/marker2/court-jane-doe-43/EFTA02819726/EFTA02819726.md new file mode 100644 index 0000000000000000000000000000000000000000..7aca57cbcf5dc14ccf9b6152f73229beb97c8312 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819726/EFTA02819726.md @@ -0,0 +1,47 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff, + +V. + +JEFFREY EPSTEIN. GHISLAINE MAXWELL. LESLEY GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +CORRECTED MEMORANDUM IN OPPOSITION TO LETTER MOTION TO OPPOSE ALTERNATIVE SERVICE ON MAXWELL + +REDACTED + +## REDACTED + +## Conclusion + +The motion for the Court to reconsider its order should be denied. + +Dated: November 14, 2017 Respectfully submitted, + +M AFFE, WEISSING, FISTOS&LEHRMAN, P.L. + +/s/~J. + +J. + +425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: brad@pathtojustice.com Attorney for Plaint fff Jane Doe 43 + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on the 13th of November, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. + +Kimo S. Peluso Sher Tremonte, LLP 90 Broad Street, 23rd Floor New York, NY 10004 kpeluso@shertremonte.com + +Counsel for Haddon, P.C. + +Laura A. Menninger, Esq. Jeffrey Paeoitfias i HADDON, & 150 East 1 Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com ipagliuca@hmflaw.com , P.C. + +Michael C. 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoie.com Counsel for Defendants, Jeffrey Epstein and Lesley Groff + +/s/ \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819726/EFTA02819726.metadata.json b/marker2/court-jane-doe-43/EFTA02819726/EFTA02819726.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d5ba37bf0e58f183e9ebf321f9479fcb062b4275 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819726/EFTA02819726.metadata.json @@ -0,0 +1,227 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819726.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 1487, + "elapsed_seconds": 0.76, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 190.332, + 72.9 + ], + [ + 415.8131103515625, + 72.9 + ], + [ + 415.8131103515625, + 104.103515625 + ], + [ + 190.332, + 104.103515625 + ] + ] + }, + { + "title": "REDACTED", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 243.57600000000002, + 156.7984619140625 + ], + [ + 370.5017395019531, + 156.7984619140625 + ], + [ + 370.5017395019531, + 179.9329833984375 + ], + [ + 243.57600000000002, + 179.9329833984375 + ] + ] + }, + { + "title": "Conclusion", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 274.176, + 234.89999999999998 + ], + [ + 337.3619384765625, + 234.89999999999998 + ], + [ + 337.3619384765625, + 249.7330322265625 + ], + [ + 274.176, + 249.7330322265625 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 222.768, + 639.9000000000001 + ], + [ + 388.9223937988281, + 639.9000000000001 + ], + [ + 388.9223937988281, + 654.7330169677734 + ], + [ + 222.768, + 654.7330169677734 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 32 + ], + [ + "Line", + 15 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 19 + ], + [ + "Text", + 8 + ], + [ + "SectionHeader", + 3 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 28 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819726" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819729/EFTA02819729.md b/marker2/court-jane-doe-43/EFTA02819729/EFTA02819729.md new file mode 100644 index 0000000000000000000000000000000000000000..5781475336ed830cecdc7ce8803060f9c02c602b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819729/EFTA02819729.md @@ -0,0 +1,40 @@ +Kimo S Peluso +direct (212) 300-2442 +kpcluso@shertremonte.com + +VIA ECF + +November 9, 2017 + +The Honorable John G. Koeltl +United States District Court +Southern District of New York +500 Pearl Street +New York, NY 10007 + +ADJOURNED FO GUESDAY, +NOVEMBER 28, 2017, +AF 3:00PM. + +Re: *Jane Doe 43 v. Epstein et al.*, +No. 17 Civ. 616 (JGK) + +Dear Judge Koeltl: + +On behalf of non-party Haddon, [REDACTED] and [REDACTED], P.C. ("Haddon Morgan"), we write to request an adjournment of the conference currently scheduled for November 14, 2017 at 3:00 pm. (Dkt. No. 71), which the Court scheduled in response to our letter dated October 30, 2017 (Dkt. No. 69). + +We are unavailable to attend the conference on November 14 due to travel arrangements made before Your Honor's order. We request that the conference be adjourned to November 28, 29, 30 or December 1, 4, 5, 10, 11, 12 or 13. There have been no previous requests to adjourn the conference. Plaintiff and counsel for the other parties who have appeared have consented to this request. + +Respectfully submitted, + +/s/ Kimo S Peluso + +Kimo S. 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Koeltl +United States District Court +Southern District of New York +500 Pearl Street +New York, NY 10007 + +ADJOURNED FO GUESDAY, +NOVEMBER 28, 2017, +AF 3:00PM. + +Re: *Jane Doe 43 v. Epstein et al.*, +No. 17 Civ. 616 (JGK) + +Dear Judge Koeltl: + +On behalf of non-party Haddon, [REDACTED] and [REDACTED], P.C. ("Haddon Morgan"), we write to request an adjournment of the conference currently scheduled for November 14, 2017 at 3:00 pm. (Dkt. No. 71), which the Court scheduled in response to our letter dated October 30, 2017 (Dkt. No. 69). + +We are unavailable to attend the conference on November 14 due to travel arrangements made before Your Honor's order. We request that the conference be adjourned to November 28, 29, 30 or December 1, 4, 5, 10, 11, 12 or 13. There have been no previous requests to adjourn the conference. Plaintiff and counsel for the other parties who have appeared have consented to this request. + +Respectfully submitted, + +/s/ Kimo S Peluso + +Kimo S. 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(with exhibits), Defendants Jeffrey Epstein and Lesley Groff ("Defendants") will move the Court, pursuant to Fed. R. Civ. P. 9(b), 10(a), 12(6)(2) and (6), 12(0, and before the Honorable John G. Koeltl, at the United States Courthouse, 500 Pearl Street, New York, New York 10007, as soon as counsel may be heard, for an Order (I) granting the Defendants' motion to dismiss the First Amended Complaint; (2) striking a portion of the First Amended Complaint if the motion to dismiss is not gr d; (3) requiring Plaintiff to amend the caption to proceed in her own name; and (4) any o err= the Coyft deems just and proper. + +Dated: New York, New York November 21, 2017 + +Michael C. r Justin Y.K. Michael A. 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B. C. | Allegations Regarding the Prior Proceedings Should Be Stricken Plaintiff Should Be Required To Proceed In Her Name The FAC Fails to State a Claim | 2 3 3 4 5 | +|------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------|-----------| +| 1. | Section 1591 Does Not Cover The Alleged Conduct | 6 | +| 2. | The FAC Fails to Plead Fraud | 8 | +| 3. | The FAC Fails to Plead Coercion | 14 | +| 4. | The FAC Fails to Plead a Causal Link | 16 | +| 5. | The FAC Fails To Allege Knowledge Against Groff | 17 | +| 6. | The FAC Fails to Allege Any Predicate Acts | 17 | +| D. | The FAC Fails to Meet the Twomblyfiqbal Standard | 20 | +| E. | The Claim Is Barred by the Statute of Limitations | 21 | +| F. | The Court Does Not Have Jurisdiction Over Defendants | 23 | +| G. | Venue Is Improperly Laid in the Southern District of New York | 24 | +| CONCLUSION | | 25 | + +# TABLE OF AUTHORITIES + +| Cases Abarca v. Little, | Page(s) | +|---------------------------------------------------------------------------------------|------------| +| 54 F. Supp. 3d 1064 (D. Minn. 2014) Am. Sales Co., Inc. v. AstraZeneca AB, | 21, 22, 23 | +| No. 10 Civ. 6062, 2011 WL 1465786 (S.D.N.Y. Apr. 14, 2011) v. MI Polk & Wardwell LLP, | 13 | +| 850 F. Supp. 2d 392 (S.D.N.Y. 2012) Ashcroft v. lqbal, | 3 | +| 129 S. Ct. 1937 (2009) | 20, 21 | +| Ashland Inc. v. Stanley & Co., | | +| 652 F.3d 333 (2d Cir. 2011) Atuahene v. City of Hartford, | 12 | +| 10 F. App'x 33 (2d Cir. 2001) Bell Atlantic Corp. v. Twombly, | 13 | +| 127 S. Ct. 1955 (2007) v. SAC Trading Corp., | 20, 21 | +| 711 F.3d 353 (2d Cir. 2013) Crigger v. Fahnstock & Co., Inc., | 8 | +| 443 F.3d 230 (2d Cir. 2006) Doe v. Del Rio, | 1 I | +| 241 FRD 154 (S.D.N.Y. 2006) Doe v. Shakur, | 5 | +| 164 FRD 359 (S.D.N.Y. 1996) Greenberg v. Chrust, | 4 | +| 198 F. Supp. 2d 578 (S.D.N.Y. 2002) v. Nat'l Prop. Analysts Partners, | 10 | +| 936 F.2d 674 (2d Cir.1991) Much v. Drina, | 10 | +| 101 F. Supp. 3d 325 (S.D.N.Y. 2015) | 22, 23 | + +| Schlaifer=ct Co. v. Estate of Andy Warhol, | | +|------------------------------------------------------------------|-----------| +| 119 F.3d 91 (2d Cir. 1997) Sealed Plaintiff v. Sealed Defendant, | 12 | +| 537 F.3d 185 (2d Cir.2008) v. World-Wide Plumbing Supply Inc., | 4 | +| 71 F. Supp. 3d 320 (E.D.N.Y. 2014) U.S v. Farhane, | 19 | +| 634 F.3d 127 (2d Cir. 2011) United States v. Marcus, | 19 | +| (2d Cir. 2008) Velez v. M, | 16 | +| 693 F.3d 308 (2d Cir. 2012) v. Research Applied Associates, | 18, 19 | +| 328 F. App'x. 744 (2d Cir. 2009) | 9, 10, 20 | + +# Statutes + +| 18 U.S.C. 1593A | 19 | +|------------------------|---------| +| 18 U.S.C. 1594(a)-(c) | 19 | +| 18 U.S.C. § 1591 | passim | +| 18 U.S.C. § 1591(eX2) | 15 | +| 18 U.S.C. § 1592 | 18 | +| 18 U.S.C. § 1595 | passiml | +| 28 U.S.C. § 1391(b)(2) | 24 | +| 114 Stat. § 102(4) | 7 | +| 114 Stat. § 102(5) | 7 | +| 114 Stat. § 102(8) | 7 | +| 1464, 1466 | 7 | + +### Other Authorities + +| CPLR 302(aX2) | 24 | +|---------------------------------|--------------| +| Fed. R. Civ. P. 9(b) | 8, 9, 10, 11 | +| Fed. R. Civ. P. 10(a) | I, 4 | +| Fed. R. Civ. P. 12(bX2) and (6) | 1 | +| Fed. R. Civ. P. 12(f) | 1, 3 | + +Defendants Jeffrey Epstein ("Epstein") and Lesley Groff ("Groff") (collectively "Defendants") move, pursuant to Fed. R. Civ. P. 9(b), 12(6)(2) and (6), to dismiss the First Amended Complaint ("FAC") filed by plaintiff Jane Doe ("Plaintiff'). Exh. A. + +The FAC represents the Plaintiffs second unsuccessful bite at the apple. On January 26, 2017, Plaintiff filed her original complaint in this matter ("Complaint"). Exh. B. On May 15, 2017, and at the suggestion of the Court, the Defendants served a letter on Plaintiff identifying a wide range of deficiencies warranting dismissal of the Complaint ("Deficiency Letter"). Exh. C. On June 5, 2017, Plaintiff filed the FAC — without fixing the deficiencies cited in the Deficiency Letter. + +Indeed, just like the Complaint that it replaced, the FAC should be dismissed because the FAC: (a) fails to state a claim under 18 U.S.C. § 1595 ("Section 1595"), which is the sole claim asserted by Plaintiff; (b) relies on a claim which is barred by the statute of limitations; (c) fails to allege personal jurisdiction over Defendants; and (d) improperly lays venue in the Southern District of New York. The FAC should be dismissed with prejudice. + +The FAC also repeats a laundry list of immaterial, impertinent and scandalous allegations about Epstein which were contained in the Complaint and should be stricken from the FAC pursuant to Fed. R. Civ. P. 12(0 in the event that it is not dismissed in its entirety. + +Plaintiff should also be required to amend the caption of this case to reflect her identity pursuant to Fed. R. Civ. P. 10(a), because she has not satisfied the requirements for proceeding anonymously and, importantly, because she has publicly identified herself by name as the plaintitT in this action in a letter to the editor published in the New York Times. + +#### BACKGROUND + +At its heart, the FAC fails because it chronicles a sexual relationship between two consenting adults and then, ten years after the relationship ended, tries to shoehorn that relationship into a statutory scheme prohibiting sex trafficking that simply does not apply. Plaintiff alleges that she was a South African citizen who lived briefly in New York from October 2006 through May 2007. FAC ¶¶ 3, 34, 64. During a three month portion of that brief period, Plaintiff claims to have engaged in a sexual relationship with Epstein, perceiving him to be a man of "wealth and influence" who could take care of her. FAC ¶ 38. According to the FAC, Epstein did take care of her, providing her with a comfortable lifestyle, including an apartment on the Upper East Side of Manhattan, access to a car service and a cell phone. FAC 52. + +Plaintiff left New York and returned to her father's home in South Africa in January 2007. FAC ¶ 55. She then traveled back to New York on her own accord in February 2007. FAC ¶ 61. Plaintiff left the United States again in May 2007, also on her own accord and without the involvement of defendants, and this time "did not return" to the United States. FAC ¶ 64. However, ten years later, after the expiration of any conceivable statute of limitations period, and in a moment of stunning opportunism, Plaintiff now sues for violation of antitrafficking law, allegedly because Epstein did not help the Plaintiff to gain admission to the Fashion Institute of Technology ("FIT") and advance her career. + +The FAC should be dismissed with prejudice because Plaintiff plainly is not a victim of sex trafficking and because the anti-trafficking law clearly is not meant to regulate, let alone prohibit, the consensual adult relationship alleged here. Moreover, the FAC fails to state a claim + +under Section 1595, advances a claim barred by the statute of limitations, fails to allege personal jurisdiction over Defendants, and improperly lays venue in the Southern District of New York. + +#### ARGUMENT + +## A. Allegations Regarding the Prior Proceedings Should Be Stricken + +The allegations set forth in paragraphs 11 through 33 of the FAC relating to state and federal investigations of Epstein, including his prior guilty plea in Florida, referred to herein as the "Prior Proceedings," are scandalous, harassing, and entirely immaterial to Plaintiff's claim. All of the allegations relating to the Prior Proceedings should be stricken from the FAC. Under Fed. R. Civ. P. 12(f), a "court may strike from a pleading ... any ... immaterial, impertinent, or scandalous matter." v. Polk & Wardwell LLP, 850 F. Supp. 2d 392, 416 (S.D.N.Y. 2012). "An allegation is impertinent or immaterial when it is neither responsive nor relevant to the issues involved in the action." Id. "'Scandalous' generally refers to any allegation that unnecessarily reflects on the moral character of an individual or states anything in repulsive language that detracts from the dignity of the court." Id. + +The allegations in the FAC relating to the Prior Proceedings should be stricken from the FAC, pursuant to Rule 12(f). First, these allegations are immaterial to this action because the Prior Proceedings did not involve Plaintiff; the matters giving rise to the Prior Proceedings occurred more than a year before Plaintiff moved to New York in 2006. FAC ¶ 24. Plaintiff's counsel conceded during the April 6, 2017 court conference ("April 6 Conference") that Plaintiff had nothing to do with the Prior Proceedings. Plaintiff has dragged the Prior Proceedings into the FAC simply to paint Epstein in a poor light and divert attention from the glaring deficiencies of her claim. + +Second, the allegations of the Prior Proceedings arc scandalous, and described by Plaintiff with the breathless language of tabloid publications, lacking both substance and cited + +sources. See FAC at ¶ 11 ("Defendant Epstein is widely recognized...") and ¶ 22 ("Defendants Epstein and Maxwell have been known ...,"). Finally, these allegations create a substantial risk that a jury might infer that Epstein is liable in the instant matter simply because of the alleged Prior Proceedings. Indeed, Plaintiff's decision to rely on these allegations reveals this lawsuit for what it is — an opportunistic gambit by the Plaintiff to extort a settlement out of Epstein. + +## B. Plaintiff Should Be Required To Proceed In Her Name + +The Federal Rules of Civil Procedure requires that "[t]he title of [a] complaint must name all the parties." Fed. R. Civ. P. 10(a). "This requirement, though seemingly pedestrian, serves the vital purposes of facilitating public scrutiny of judicial proceedings and therefore cannot be set aside lightly." Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 188-89 (2d Cir.2008). The use of pseudonyms is not allowed except in limited circumstances, balancing the interests of the party seeking anonymity, the public interest to know and the opposing parties' right to confront the accuser. Id. + +Courts have required an anonymous plaintiff to proceed in their own names under circumstances similar to those alleged in this action. In Doe v. Shakur, 164 FRD 359 (S.D.N.Y. 1996), the plaintiff alleged that she was sexually assaulted by the rapper Tupac Shakur. The Court denied the plaintiff's request to proceed anonymously, explaining: + +> First, plaintiff has chosen to bring this lawsuit. She has made serious charges and has put her credibility in issue. Fairness requires that she be prepared to stand behind her charges publicly. + +> Second, this is a civil suit for damages, where plaintiff is seeking to vindicate primarily her own interests. This is not a criminal case where rape shield laws might provide some anonymity to encourage victims to testify to vindicate the public's interest in enforcement of our laws. + +> Third, Shakur has been publicly accused. If plaintiff were permitted to prosecute this case anonymously, Shakur would be placed at a serious disadvantage, for he would be required to + +defend himself publicly while plaintiff could make her accusations from behind a cloak of anonymity. + +Finally, the public has a right of access to the courts. Indeed, lawsuits are public events and the public has a legitimate interest in knowing the facts involved in them. Among those facts is the identity of the parties. + +Id. at 36. Similarly, a plaintiff who alleged sexual molestation and abuse cannot proceed anonymously without a sufficient showing of particularized harm to the plaintiff if anonymity is not allowed. Doe v. Del Rio, 241 FRD 154 (S.D.N.Y. 2006) (plaintiff alleging sexual abuse by police required to proceed in her actual name, in that her therapist report fails to establish a link between public disclosure of plaintiffs name and alleged harm). + +Here, Plaintiff has not satisfied these requirements. In fact, Plaintiff has publicly identified herself by name as the plaintiff in this action in a letter she wrote to the New York Times. Specifically, she identified herself by her legal name and stated that she is "the plaintiff in Jane Doe 43 v. Jeffrey Epstein, Ghislane Maxwell, , Lesley Groff and Natalya Mayshev." The letter was published on November 15, 2017. Exh. D. Since Plaintiff never satisfied the requirements to proceed anonymously in the first instance and has now publicly identified herself, she should be required to amend the caption to reflect her own name. + +### C. The FAC Fails to State a Claim + +The FAC, like the Complaint it replaces, fails to plead facts sufficient to sustain a claim under Section 1595, which provides for civil liability for violations of 18 U.S.C. § 1591 and other enumerated statutes. The version of Section 1591(a) in effect in 2006-07 (when the events alleged in the FAC purportedly occurred) provided that: + +> "whoever knowingly ... recruits, entices, harbors, transports, provides, or obtains by any means a person ... knowing that force, fraud, or coercion ... will be used to cause the person to engage in a commercial sex act ... shall be punished as provided in subsection (b)." + +The FAC fails to establish the elements of a Section 1591(a) violation for at least the following six reasons. First, the statute does not apply to the alleged relationship between the Plaintiff and Epstein or the alleged conduct. Second, the FAC fails to adequately plead that the Defendants used "fraud" to cause Plaintiff to engage in a commercial sex act. Third, the FAC fails to allege that the Defendants used "coercion" to cause Plaintiff to engage in a commercial sex act. Fourth, the FAC fails to establish that any alleged fraud or coercion "caused" the Plaintiff to engage in a commercial sex act. Fifth, the FAC fails to adequately plead that Groff "knew" that the Plaintiff would be caused by "fraud" or "coercion" to engage in a commercial sex act. Finally, the FAC fails to meet the Twombly/kbal standard for pleading any claim in federal court. + +All six of these points should be read in the context of one major deficiency in the FAC the Plaintiff has elected to provide the Court with no information about her personal, educational and professional background. There is nothing in the FAC about the Plaintiffs age, maturity, level of education, or prior employment experience. Without these factual allegations, the Court is left with little context to consider when evaluating the Plaintiff's allegations of fraud and coercion, and when considering whether the overall narrative described by the Plaintiff is even plausible. + +### 1. Section 1591 Does Not Cover The Alleeed Conduct + +In enacting Section 1591, Congress explained that "(tjhe purposes of this division are to combat trafficking in persons, a contemporary manifestation of slavery whose victims are predominantly women and children, to ensure just and effective punishment of traffickers, and to protect their victims." Trafficking Victims Protection Act of 2000. Pub. L. 106-386, § 109(9), 114 Stat. 1464, 1466 (emphasis added). It noted that: + +Traffickers lure women and girls into their networks through false promises of decent working conditions at relatively good pay as nannies, maids, dancers, factory workers, restaurant workers, sales clerks, or models. + +Id. § 102(4), 114 Stat. at 1466. The traffickers "buy children from poor families and sell them into prostitution or into various types of forced or bonded labor." Id. They "often transport victims from their home communities to unfamiliar destinations." Id. § 102(5), 114 Stat. at 1466. Trafficking is "increasingly perpetrated by organized, sophisticated criminal enterprises" and is "the fastest growing source of profits for organized criminal enterprises worldwide." Id. § 102(8), 114 Stat. at 1467. These sort of descriptions do not apply to what is alleged in this action, which is at most (according to the FAC and the evidence provided by the Plaintiff) a dispute between an adult woman and a boyfriend over an unenforceable promise. Simply put, the Plaintiff was not a victim of sex trafficking. + +First, there are no allegations that "traffickers lured [Plaintiff] into their network by false promises" of a job. Instead, without the involvement of any of the Defendants, Plaintiff traveled to the United States on her own volition. She then voluntarily associated herself with the Defendants and engaged in sexual activity with Epstein because, according to her, she was given an Upper East Side lifestyle and she perceived that Epstein could provide her with some advantage in gaining entrance to an institution of higher learning. These factual allegations do not demonstrate that she was a victim, much less a victim of sex trafficking requiring the protection of Section 1591, a criminal statute. + +Second, to the extent that the Plaintiff alleges that Epstein made promises to her that were not fulfilled in a timeframe that Plaintiff expected or wanted (no matter how unreasonable), these sorts of issues are a matter for resolution between these two adults who allegedly entered into an adult relationship. When enacting Section 1591, Congress did not evidence any intention to legislate the private relationship between two consenting adults. + +In short, Plaintiff's voluntary relationship with Epstein, which she allegedly entered into so as to gain advantage for herself, was not one to which Section 1591 was ever designed to apply. + +### 2. The FAC Fails to Plead Fraud + +Plaintiff's claim that the Defendants used "fraud" to cause her to engage in a commercial sex act does not satisfy the pleading requirements for claims sounding in fraud. + +## a) The FAC Fails to Satisfy Rule 9(b) + +Plaintiff bases her Section 1595 claim on the Defendants' supposed fraudulent statements and, as a result, the heightened pleading standards set forth in Fed. R. Civ. P 9(b) apply. As the Second Circuit has explained, where a claim is based on predicate acts involving fraud, the plaintiff must state the fraud with particularity pursuant to Rule 9(b). v. SAC Trading Corp., 711 F.3d 353, 359 (2d Cir. 2013) (Rule 9(b) "standard also applies to allegations of fraudulent predicate acts supporting a RICO claim"). + +As the Second Circuit explained this standard: + +Rule 9(b) requires that, in alleging fraud or mistake, a party must state with particularity the circumstances constituting fraud or mistake. To satisfy the pleading requirements of Rule 9(b), a complaint must (I) specify the statements that the plaintiff contends were fraudulent, (2) identify the speaker, (3) state where and when the statements were made, and (4) explain why the statements were fraudulent. ... + +[Allthough Rule 9(b) permits knowledge to be averred generally, we have repeatedly required plaintiffs to plead the factual basis which gives rise to a strong inference of fraudulent intent. Essentially. while Rule 9(h) permits scienter to be demonstrated by inference, this must not be mistaken for license to base claims of fraud on speculation and conclusory allegations. An ample factual basis must be supplied to support the charges. + +v. Research Applied Associates, 328 F. App'x. 744, 747 (2d Cir. 2009) (quoting v. Nat'l Prop. Analysts Partners, 936 F.2d 674, 676 (2d Cir.1991)). + +The fraud allegations in the FAC simply do not meet this pleading standard. Indeed, they are premised on the implausible theory that Plaintiff, an apparently educated and sophisticated adult, met complete strangers and was duped into an agreement to engage in commercial sex with one of them by vague promises of admission to FIT. In her own words, Plaintiff's allegations of fraud boil down to this: Epstein allegedly "confirmed to Plaintiff that he would use his wealth and influence" to have Plaintiff admitted into the FIT and to advance her career, but had no intention of doing so. FAC ¶¶ 38, 53, 58-64. Indeed, the FAC only alleges that Epstein "confirmed" this representation, and that Groff "confirmed and reiterated this promise to Plaintiff many times." FAC ¶¶ 38, 53. + +These allegations do not satisfy Rule 9(b) because they fail to adequately specify when and where the allegedly fraudulent statements were made, how (if at all) the alleged statements were fraudulent, and that these statements were made with the requisite intent to defraud. First, the FAC fails to allege with particularity "where and when" the allegedly fraudulent statements were supposedly made. For example, there is no allegation as to when Epstein supposedly made his promise about FIT or where he made this promise. FAC ¶ 38. The assertion against Groff is equally bare. Instead of providing particulars, the FAC merely states that Groff supposedly "repeated and confirmed" Epstein's promise sometime during the period between "October 2006 and May 2007." Id. The bald assertion that Groff "told" Plaintiff that "Epstein would advance Plaintiff's education" is bereft of any details as to when this happened. where they were, or the circumstances as to why and how Plaintiff would even speak with Groff, a stranger to her, regarding Epstein's alleged promises of an FIT education and career advancement. FAC ¶ 53. + +The FAC falls short of the basic fairness requirement, since Defendants are entitled to know when and where they supposedly made fraudulent statements, especially given that Plaintiff's claim is based on events that occurred over ten years ago. + +Second, the FAC fails to show how the alleged promises about Plaintiff's prospects for admission to FIT, if made at all, were fraudulent. The FAC merely states in conclusory terms that the statements were "knowingly false" and "not acted upon." FAC ¶ 53. However, there are no factual allegations to support the assertion that the statements were false when made. Plaintiff's allegations that the Defendants did not act on the alleged promises about FIT are insufficient to show that the representations were false when made. Greenberg v. Chrust, 198 F. Supp. 2d 578, 583 (S.D.N.Y. 2002) ("failure to fulfill a promise to perform future acts is not grounds for a fraud action"). + +Finally, the FAC fails to provide any factual basis, let alone an "ample factual basis," that would give rise to the "strong inference of fraudulent intent" required to plead a fraud claim in satisfaction of Rule 9(b). S 328 F. App'x at 747; 936 F.2d at 676. The allegation that Epstein had no intention of following through on his alleged promises to assist Plaintiff in gaining admission to FIT or her career advancement is merely conclusory, and does not satisfy the requirements of Rule 9(b). Greenberg, 198 F.Supp.2d at 583 ("fraudulent intent cannot be inferred merely from the non-performance of a party's representations"). + +Indeed, Plaintiff has alleged no facts to support the contention that Epstein did not perform as he allegedly promised. To the contrary, the factual allegations state that Epstein promised -- and provided -- generous support to Plaintiff, including "living quarters at 301 East 66th Street" on the Upper East Side of Manhattan, "a car service for Plaintiff to use as needed" and a "cell phone." FAC ¶ 52. The FAC further alleged that Epstein encouraged Plaintiff to fill out an admission application to FIT. FAC ti 59. These specific factual allegations are wholly inconsistent with Plaintiff's conclusory assertion that Epstein had no intention of helping Plaintiff to gain admission to FIT. Accepting the "factual" allegations as true, they tend to demonstrate that Epstein provided the promised benefits to her, and was working with Plaintiff to gain admission to FIT. There is no factual assertion that demonstrates any prior intention of Epstein to withhold support in the specific areas of Plaintiffs education or career advancement. + +The FAC provides no particulars as to any timeframe in which Plaintiff was to be admitted to FIT. Nor does it provide any particulars as to whether and when Plaintiff submitted her application necessary for admission. Thus, even if Plaintiff was not admitted to attend FIT by the time she left the United States in May 2007, it does not demonstrate that Epstein did not help. It simply means that Plaintiff failed to gain admission before she left. In sum, the FAC fails to allege facts sufficient to infer that Epstein would not follow through on the alleged promises of assistance regarding Plaintiff's admission to FIT. + +As to Groff, there is no factual allegation of fraudulent intent at all or that Groff knew that Plaintiff was engaged in a sexual relationship with Epstein in exchange for the alleged promises. In sum, the FAC fails to meet the pleading standards required under Rule 9(b) with respect to every element required to establish that Epstein and Groff committed a fraud, and should therefore be dismissed. + +# b) The FAC Fails for I.ack of Reasonable Reliance + +In order to state a claim sounding in fraud, among other things, a plaintiff must also plead facts to establish that she reasonably relied on the alleged misrepresentations. Crigger v. Fahnstock & Co., Inc., 443 F.3d 230, 234 (2d Cir. 2006). The FAC does not meet this basic requirement. It merely states in conclusory terms that "Plaintiff reasonably relied" on the alleged misrepresentations (FAC I 53) without providing any factual support for this conclusion. To the + +contrary, the allegations in the FAC support just the opposite conclusion. According to the FAC, at the time the statement was made about Plaintiffs prospects for admission to FIT, the Plaintiff barely knew Epstein — she had only just met Epstein through yet another person whom she barely knew. FAC ¶¶ 36, 38. That such a stranger would offer to "use his wealth and influence to have Plaintiff admitted to" FIT or a similar institution in exchange for sexual favors would cause any reasonable person, especially under the circumstances alleged in the FAC, to question, rather than rely on, such a promise. + +The vagueness of the promise, including that there was no timeframe as to when the promised admission to FIT was to occur, should also have caused an educated and worldly person such as Plaintiff to cast further doubt on the alleged promise, instead of relying on it wholesale as alleged here. + +Moreover, the FAC fails to allege facts from which the Plaintiff might have reasonably concluded that Epstein had the ability "to have Plaintiff admitted to" FIT and that her admittance was a "done deal." FAC ¶R 38, 59. For example, the FAC fails to allege that Epstein was associated in any way with FIT, rather asserting that he merely "had contacts at FIT." FAC ¶ 60. Such bare allegations are insufficient. Ashland Inc. v. Stanley & Co., 652 F.3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); Schlaifer & Co. v. Estate of Andy Warhol, 119 F.3d 91, 98 (2d Cir. 1997) ("circumstances may be so suspicious as to suggest to a reasonably prudent plaintiff that the defendant's representations may be false, and that the plaintiff cannot reasonably rely on those representations"). + +In sum, the FAC contains no allegations concerning any diligence or investigation by Plaintiff into the credibility of any of the statements supposedly made to her. Instead, she alleges that she trusted wholesale any and all statements told to her by complete strangers in a foreign country, and contends on that basis she reasonably relied on their promises of a guaranteed education at a particular institution and a successful career. Plaintiff's allegation of reliance, let alone reasonable reliance, is simply implausible. + +# c) The FAC Impermissibly Lumps All Defendants Together + +The FAC also engages in rampant "group pleading." It repeatedly attributes the same conduct and/or statement to all or multiple defendants without identifying which individual defendant engaged in the alleged conduct or made the alleged statement. Such group-pleading does not satisfy the basic requirement of Rule 8 that a complaint must provide "specification as to the particular activities by any particular defendant." Am. Sales Co., Inc. v. AstraZeneca AB, No. 10 Civ. 6062, 2011 WL 1465786, at \*5 (S.D.N.Y. Apr. 14, 2011); Atuahene v. City of Hartford, 10 F. App'x 33, 34 (2d Cir. 2001) (dismissing complaint because plaintiff "Iump[ed] all the defendants together and provided[ed] no factual basis to distinguish their conduct"). + +Defendants in their Deficiency Letter advised Plaintiff of this defect. In response, Plaintiff simply inserted the phrase "each of before the word "defendants" as if that would cure the defect and somehow better identify the conduct of the different defendants. See FAC ¶¶ 38, 52, 53, 61, 63 and a comparison of these same paragraphs as set forth in the Complaint. Exh. E. + +A small sampling of the allegations of the FAC which repeatedly and impermissibly lump all Defendants together amply demonstrates the insurmountable defects in the FAC. First, the FAC alleges that "Defendants recruited Plaintiff into their sexual enterprise," without identifying which defendant was involved in the alleged recruitment and what individual action each defendant allegedly took. FAC ¶¶ 34. Second, the FAC alleges that "Defendants sent Plaintiff ... to South Africa to recruit" without specifying which defendant supposedly "sent" Plaintiff. MC ¶ 55. Third, the FAC alleges that "Defendants Maxwell, and Groff each + +also confirmed and reiterated this promise to Plaintiff many times," but without specifying which of these defendants actually did so or where and when each of the defendants made the alleged statements. FAC ¶ 38. Fourth, the FAC alleges that the "Defendants'] telling Plaintiff that Epstein would use his connections to have her admitted to FIT," but again without specifying which defendant did the "telling" or where and when that occurred. FAC ¶ 40. Fifth, the FAC alleges that "in addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, each of the Defendants continued to pressure her to lose excessive amounts of body weight and offered her no opportunity to decline or resist their instructions." FAC 1 63. Yet, the FAC does not identify which defendants allegedly "required" Plaintiff to provide sex acts, "pressure[d)" her to lose excessive weight, or offered Plaintiff no opportunity to decline or resist these alleged demands. + +By engaging in this pattern of improper group pleading, the FAC fails to state a legally sufficient claim against any one of the Defendants. + +# 3. The FAC Fails to Plead Coercion + +The FAC fails to allege that the Defendants used "coercion" to cause the Plaintiff to engage in a commercial sex act. The statute defines coercion to include the following conduct: + +- (A) threats of serious harm to or physical restraint against any person; +- (B) any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person; or +- (C) the abuse or threatened abuse of law or the legal process. + +18 U.S.C. § 1591(e)(2). The FAC simply fails to provide factual allegations to support any of these three definitions of coercion. + +First, the allegations of coercion in the FAC arc not specific and arc wholly conclusory. See, e.g., FAC ¶ 48. The FAC does not allege a single specific factual instance where Epstein or Groff made a "threat[] of serious harm to or physical restraint against" the Plaintiff. Indeed, the FAC speaks of only one occasion where Plaintiff allegedly suffered unspecified "verbal abuse and threats" and, as a result, "attempted to escape from Defendant Epstein's private island." FAC ¶ 49. This single allegation taken as true does not establish that Plaintiff was subject to a threat of serious harm. The fact that the Plaintiff was allegedly "returned" to the house on the island does not demonstrate that she was subject to "physical restraint" and there is nothing alleged in the FAC that demonstrates that this isolated incident had anything to do with whatever sexual activity Plaintiff claims she engaged in with Epstein. + +Second, the FAC fails to establish that there was a "scheme, plan, or pattern" to cause Plaintiff to believe that she would be seriously harmed or restrained. Indeed, the FAC is devoid of factual allegations concerning threats of physical harm, as discussed above. And, with respect to physical restraint, the FAC alleges that Plaintiff traveled freely within the United States and abroad, and was provided with living quarters of her own on the Upper East Side of Manhattan as well as a car service and cellphone. FAC ¶¶ 45, 52, 55, 64. + +Plaintiff has not provided any factual allegations that any of the defendants held her immigration documents in order to prevent her movement, prevented her from traveling, or had any power to affect her ability to travel to or from the United States. To the contrary, the FAC alleges that she traveled to and from the United States as she wished. She admits that she freely "refused to perform the recruitment assignment" allegedly "demanded" by Epstein to find young females to serve in "sexual servitude" while she was in South Africa. FAC ¶ 56. Yet, she was able to come back to the United States. + +Third, a withdrawal of support to gain admission to FIT or career advancement, or refusal to provide living quarters on the Upper East Side or a car service, does not constitute "threats of serious harm." A withdrawal of such support would simply mean that Plaintiff would no longer + +have the desired lifestyle or assistance for potential educational or career advancement, as to which she had neither a legal right nor moral claim to obtain front Epstein. + +Similarly, the supposed threat by Maxwell and Epstein that "they had the ability to make sure that Plaintiff would not obtain formal education or modeling agency contracts if she failed to provide sexual favors" is no threat at all. FAC ¶ 41. Plaintiff is not alleged to be a gullible person with diminished capacity, uneducated, or inexperienced socially. It is implausible for Plaintiff or any other reasonable person to perceive this as a realistic threat or to believe that defendants had such omnipotent ability. The pleading standard is not lowered simply because Epstein is alleged to be "rich and powerful." + +Fourth, the FAC offers no factual support that the Defendants engaged in any "abuse or threatened abuse of the law or legal process" required by the statute. + +### 4. The FAC Fails to Plead a Causal Link + +The FAC fails to plead that the Defendants' alleged fraudulent and coercive conduct "caused" the Plaintiff to engage in a commercial sex act, as required under Section 1591. United States v. Marcus, 487 F. Supp. 2d 289, 306-07 (E.D.N.Y. 2007), revert on other grounds, 538 F.3d 97 (2d Cir. 2008) (a violation of Section 1591 requires that a "commercial sex act ... be a product of force, fraud or coercion."). + +Indeed, the FAC should be fairly read to evidence that the Plaintiff, then an adult woman, sought and engaged in a consensual sexual relationship with Epstein, an unmarried adult man, on her own accord. Her allegations of receiving financial support amount to nothing more than the claims of an adult girlfriend who received financial support from someone with whom she was in a romantic relationship. When she became dissatisfied with that relationship and decided to terminate it, as would be expected of any similar relationship, the financial support she received based on that relationship terminated as well. Whatever unfulfilled promises about an education + +at FIT and unwelcome criticism of her appearance that Plaintiff claims to have experienced, the FAC makes clear that her sexual acts were not the product of those two events. + +Finally, the sex acts alleged in the FAC are not "commercial sex" acts, much less sex acts in violation of Section 1591, a criminal statute. If they were, a significant percentage of the population likely would have unwittingly engaged in commercial sex and committed a crime in violation of the statute. As demonstrated in Point C.1. above, the kind of relationship between Plaintiff and Epstein alleged hem does not violate the anti-trafficking statute. No crime was committed here. + +# 5. The FAC Fails To Allege Knowledge Against Groff + +The FAC fails to allege facts which establish that Groff engaged in any conduct "knowing that force, fraud, or coercion ... will be used to cause [the Plaintiff] to engage in a commercial sex act," as required in Section 1591. Hem, there are no specific factual allegations showing that Groff knew that the Plaintiff was engaged in a sexual relationship with Epstein, much less that Groff knew that Plaintiff was engaged in commercial sex caused by fraud or coercion. At best, the allegations show that Groff performed legitimate secretarial functions such as making travel arrangements. FAC ¶ 51. + +Plaintiff's conclusion in the FAC that Groff had knowledge is without factual support, and merely parrots the statutory language. PAC ¶ 40 ("knew", "knowingly"). There are simply no facts to show Groff knew of the alleged private relationship between Plaintiff and Epstein or that Epstein did not intend to fulfill his alleged promises. The conclusory allegations against Groff arc insufficient to show that she had the "knowledge" as required tinder Section 1591. + +## 6. The FAC Fails to Allege Any Predicate Acts + +Plaintiff's principal response to the Deficiency Letter (which Plaintiff appears to have largely ignored during her preparation of the FAC) was to add to the FAC other supposed criminal violations which Plaintiff now asserts support her Section 1595 claim. None of these new allegations tip the scale; the FAC is still insufficiently drafted as a matter of law. + +# a) The FAC Fails to State a Violation of Section 1592 + +Plaintiff added a claimed violation of 18 U.S.C. § 1592 and alleges that the defendants "concealed, removed, confiscated, and possessed Plaintiff's passport and associated immigration documents." FAC ¶ 69. Plaintiff alleges that this occurred in the course of violating Section 1591, and that it occurred "to prevent, restrict, attempt to restrict without lawful authority, Plaintiff's liberty to move or travel, in order to maintain the sexual services of Plaintiff, while Plaintiff was a victim of a severe form of sex trafficking." Id. + +This claim is utterly without factual support and without merit. First, as described, above, the FAC simply fails to establish a violation of Section 1591. Second, the FAC is utterly devoid of facts supporting the notion that the defendants ever held her passport against her will. The FAC acknowledges that she traveled to and from South Africa on her own schedule without interference or control by the Defendants. Third, there is no factual allegation supporting the requisite statutory element that her passport was withheld in order to force her into commercial sex. Notably, and as to Groff, the FAC does not even mention that Groff played any role involving her passports. + +# b) The FAC Fails to State a Violation of Section 1593A + +Plaintiff also added a claimed criminal violation of 18 U.S.C. 1593A as a basis for a Section 1595 claim. FAC ¶ 70. This statute, however, was enacted in December 2008, after the events alleged in the FAC had occurred. It therefore has no application here. Velez v. 693 F.3d 308, 325 (2d Cir. 2012) ("there is a well-established presumption against the retroactive application of legislation, including amendments creating a private cause of action"). In any event, the FAC fails to allege facts constituting a violation section 1593A. which criminalizes those who knowingly participate in or benefit from a venture in contravention of Section 1592 and 1595. Because the FAC fails to state a violation of Sections 1592 and 1595, as demonstrated above, there cannot be a violation of Section 1593A. + +# c) The FAC Fails to State a Violation of Sections 1594(a)-(c) + +In a failed attempt to provide another basis for a Section 1595 claim, Plaintiff also asserts that Defendants committed a crime in violation of 18 U.S.C. 1594(a)-(c). As of the time during the events in question, section 1594(a) criminalized any "attempt" to violate Section 1591, and Sections 1594(6) and (c) specified the relevant punishments for violations of various related statutes. For the reasons that the FAC fails to state a violation of Section 1591, and indeed any violation of the anti-trafficking statutes, Plaintiff has failed to state a violation of Section 1594(a). Plaintiff does not allege an unsuccessful violation of the anti-trafficking statutes. She alleges instead, albeit insufficiently and in conclusory fashion only, that Defendants succeeded in making her a victim of the crime of sex trafficking. Moreover, the FAC has failed to allege the requisite elements necessary to establish an attempted crime. U.S. v. Farhane, 634 F.3d 127, 145 (2d Cir. 2011) ("attempt requires proof that a defendant (a) had the intent to commit the object crime and (b) engaged in conduct amounting to a substantial step towards its commission"); v. World-Wide Plumbing Supply Inc., 71 F. Supp. 3d 320, 330 (E.D.N.Y. 2014) ("a claim of attempt requires plaintiff to allege that defendants had the intent to commit the underlying crime"). Here, there are no factual allegations in the FAC to support the contention that Defendants intended to violate the anti-trafficking statutes and, as demonstrated above, Defendants did not take steps, let alone substantial steps, to violate the anti-trafficking statutes. + +The FAC therefore fails to plead a predicate violation under these statutes. Moreover, as discussed in Point C.1. above, the anti-trafficking statutes were not enacted to address the consensual adult relationship alleged here between Plaintiff and Epstein. + +### D. The FAC Fails to Meet the Twomblagbal Standard + +The FAC not only fails to meet the stringent pleading standards applicable to fraud based claims, it also fails to meet the basic pleading standards set forth in Bell Atlantic Corp. v. Twombly, 127 S. Ct. 1955 (2007) and Ashcroft v. lqbal, 129 S. Ct. 1937 (2009). Under these two decisions, as explained and applied by the Second Circuit: + +> [A] complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face. ... Where a complaint pleads facts that are merely consistent with a defendant's liability, it stops short of the line between possibility and plausibility .... + +328 F. App'x. at 746-747 (quoting lqbal, 129 S. Ct. at 1949). Here, at best, the FAC merely parrots the statutory elements of a Section 1595 claim regarding fraud and coercion without specifically alleging the factual basis for those elements. The FAC, taken as a whole, does not plead a plausible claim that Plaintiff was a victim of sex trafficking in violation of criminal statutes entitling her to civil relief pursuant to Section 1595. Instead, the FAC presents the Plaintiff as a consenting adult engaged in a voluntary relationship which provided the Plaintiff with a remarkably comfortable lifestyle and the prospects of help with her FIT application. This is hardly the sort of relationship that the sex trafficking statute was designed to address. + +The FAC should therefore be dismissed with prejudice for failing to meet the plausibility standard under Twombly and !ghat even in her second attempt to do so. + +### E. The Claim Is Barred by the Statute of Limitations + +Plaintiff's claim is time-barred under either (a) the four-year statute of limitations applicable to claims that arose before the 2008 statutory amendment that extended the limitations period to ten years or (b) even the current ten-year statute of limitations period. + +Plaintiffs claim is barred by the four-year statute of limitations. According to the FAC, the conduct giving rise to the claim allegedly occurred between October 2006 and April 2007, and Plaintiff "left the United States" in May 2007 and "did not return." FAC IN 34, 64. This action was not commenced until January 26, 2017, more than four years after any of the events alleged in the FAC occurred. Plaintiff's claim is therefore time-barred. Abarca v. Little, 54 F. Supp. 3d 1064, 1068 (D. Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitations when originally enacted. The statute was amended in December 2008 and the limitations period was extended to ten years. Id. However, "Congress did not expressly state or otherwise indicate that the [statute's] limitations period applies retroactively." Id. The plaintiff in Abarca, like Plaintiff here, filed the Section 1595 claim after the statute was amended to provide for a ten-year statute of limitations. Applying the presumption against retroactive legislation, the Court in Abarca determined that the ten-year statute of limitation did not apply because the alleged wrongful conduct occurred before the statute of limitations was amended. Id. at 1069. The Court therefore applied the four-year statute of limitations and dismissed the Section 1595 claim because it was filed more than four years after the alleged wrongful acts. Id.' + +But see Oluch v. Orina, 101 F. Supp. 3d 325, 330 (S.D.N.Y. 2015) (applying a ten-year statute of limitations). + +Here, all events alleged in the FAC ended in 2007, before the 2008 amendment extending the limitations period from four to ten years was enacted. As a result, the four-year statute of limitations applies. Plaintiffs claim, filed in January 2017 and more than four years after the events described in the FAC, is time-barred. + +Even if the ten year statute of limitations applies, Plaintiffs claim is still time-barred. Plaintiff admits that when she returned home to South Africa in January 2007, she believed that the Defendants were engaged in illegal conduct, were victimizing women and could no longer be trusted. For example, in the FAC Plaintiff alleges that she "knew" she was being asked to recruit "female models" from South Africa who would not be placed in legitimate positions, but would instead "be forced into sexual servitude." FAC ¶ 56; see also, Cplt. ¶ 51. Clearly, by January 2007, Plaintiff could no longer claim to be relying on Defendants' representations about, for example, gaining admission to FIT, because, according to her own allegations, she did not believe what she was being told by the Defendants. She was also free and safe with her father and in her own country. FAC ¶ 55. As plainly demonstrated by Plaintiff's deliberate refusal to comply with Defendants' alleged recruitment request, FAC ¶ 56, and her subsequent unimpeded return to New York in February 2007, Plaintiff was then under no compulsion to follow orders and no longer did so. Thus, based on Plaintiff's own allegations in the FAC, any arguable fraud or coercion terminated in January 2007, and the statute of limitation began to run no later than that time. Oluch v. Orina, 101 F. Supp. 3d 325, 330 (S.D.N.Y. 2015) (Section 1595 claim accrued when plaintiff first left defendant's home); Abarca, 54 F. Supp. 3d at 1070 (Section 1595 claim accrued when plaintiff traveled home to Mexico and had "physical freedom"). Because Plaintiff's claim admittedly turns on whether she was defrauded or coerced, the statute + +of limitations period expired before this action was filed on January 26, 2017, more than ten years after she left New York in January 2007. + +Since Plaintiffs claim accrued no later than January 2007, and as early as late 2006, the allegations concerning the period subsequent to her returns to the United States are irrelevant. To the extent that those events could be considered, the assertions that Defendants defrauded her or coerced Plaintiff into commercial sex when she returned to the United States in February 2007 are wholly insufficient as a matter of law. She merely alleges, again without providing specific facts, that Defendants wanted her to continue the prior relationship and "continue[d] to repeatedly make false representations . . . that she would be admitted to FIT." FAC 9¶ 61, 64. But Plaintiff concedes, however, that before hearing these "false representations" she had already concluded that Epstein could not be trusted at all. Based on these facts, Plaintiff cannot establish that she reasonably relied on anything she was told by the Defendants after she returned to New York in February 2007. + +She has not alleged any continued association with Defendants. For example, she does not allege that she continued to live in the apartment provided by Epstein or whether she had established new relationships or moved in with someone completely unrelated to Defendants. She also does not allege the reasons for or purposes of her return to Ncw York from her home country. The purposeful absence of these factual allegations renders her claim that she was subject to fraud and fraud utterly baseless. + +### F. The Court Does Not Have Jurisdiction Over Defendants + +Other than an alleged ownership of real estate in New York by Epstein, the FAC alleges no present connection of the Defendants to New York. As a result, personal jurisdiction over the Defendants would have to be based on tortious conduct allegedly committed in New York. CP1.8 302(a)(2). As explained below, however, there are insufficient allegations of + +tortious conduct during the limitations period upon which Plaintiff can base personal jurisdiction, even if the ten year limitations period were to apply, which Defendants maintain it does not. + +Because this action was filed on January 26, 2017, all of the conduct alleged to have occurred before February 2007 falls outside of the ten year limitations period. The FAC does not allege conduct after Plaintiff left for South Africa in January 2007 that is sufficient to state a claim under Section 1595. The allegations in the FAC concerning this period merely track the statutory language but without providing the necessary factual support. The FAC, therefore, fails to establish that the Court has personal jurisdiction over Epstein and Groff + +# G. Venue Is Improperly Laid in the Southern District of New York + +For the same reasons that the Court lacks personal jurisdiction over the Defendants, the Southern District of New York is not the proper venue for this action. The applicable venue statute, 28 U.S.C. § 1391(b)(2), requires that "a substantial part of the event or omission giving rise to the claim occurred" within the Southern District of New York. This fundamental element is not met here. The conduct alleged occurred outside of the statute of limitations period and cannot form the basis of either a claim or venue. + +# CONCLUSION + +For all of the reasons set forth, this action should be dismissed with prejudice. + +Dated: November 21, 2017 + +Michael C. + +Justin Y.K. + +Michael A. + +STEPT0E & LLP + +1114 Avenue of the Americas + +New York, New York 10036 + +(212) 506-3900 + +mmiller@steptoe.com + +jchu®steptoe.com + +Attorneys for Defendants + +Jeffrey Epstein & Lesley Groff \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819732/EFTA02819732.metadata.json b/marker2/court-jane-doe-43/EFTA02819732/EFTA02819732.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c2e8294ddd64a6e37ed20ce63e9e6fe08a09ddd4 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819732/EFTA02819732.metadata.json @@ -0,0 +1,1793 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819732.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 30, + "chars": 53933, + "elapsed_seconds": 3.77, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 87.51599999999999, + 76.94999999999999 + ], + [ + 313.0904541015625, + 76.94999999999999 + ], + [ + 313.0904541015625, + 106.99249267578125 + ], + [ + 87.51599999999999, + 106.99249267578125 + ] + ] + }, + { + "title": "MEMORANDUM OF LAW IN SUPPORT OF \nMOTION TO DISMISS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 202.572, + 357.21000000000004 + ], + [ + 451.17242431640625, + 357.21000000000004 + ], + [ + 451.17242431640625, + 386.36248779296875 + ], + [ + 202.572, + 386.36248779296875 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 239.904, + 98.82 + ], + [ + 375.95257568359375, + 98.82 + ], + [ + 375.95257568359375, + 114.06353759765625 + ], + [ + 239.904, + 114.06353759765625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 229.5, + 89.91 + ], + [ + 384.70562744140625, + 89.91 + ], + [ + 384.70562744140625, + 105.11248779296875 + ], + [ + 229.5, + 105.11248779296875 + ] + ] + }, + { + "title": "Statutes", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 68.544, + 367.74 + ], + [ + 117.51466369628906, + 367.74 + ], + [ + 117.51466369628906, + 383.2330322265625 + ], + [ + 68.544, + 383.2330322265625 + ] + ] + }, + { + "title": "Other Authorities", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 67.932, + 74.4375 + ], + [ + 166.73248291015625, + 74.4375 + ], + [ + 166.73248291015625, + 89.04998779296875 + ], + [ + 67.932, + 89.04998779296875 + ] + ] + }, + { + "title": "BACKGROUND", + "heading_level": null, + "page_id": 6, + "polygon": [ + [ + 260.1, + 75.29888916015625 + ], + [ + 354.36871337890625, + 75.29888916015625 + ], + [ + 354.36871337890625, + 89.30352783203125 + ], + [ + 260.1, + 89.30352783203125 + ] + ] + }, + { + "title": "ARGUMENT", + "heading_level": null, + "page_id": 7, + "polygon": [ + [ + 268.05600000000004, + 131.92889404296875 + ], + [ + 345.3167724609375, + 131.92889404296875 + ], + [ + 345.3167724609375, + 145.93353271484375 + ], + [ + 268.05600000000004, + 145.93353271484375 + ] + ] + }, + { + "title": "A. 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upon personal knowledge, information and belief as to all other matters, as follows: + +1. 1. This cause of action arises under federal statutes and jurisdiction is proper under 28 U.S.C. section 1331. +2. 2. Plaintiff files this Complaint under a pseudonym in order to protect her identity because this Complaint makes allegations of a sensitive sexual nature the disclosure of which, in association with her name, would cause further harm to her. + +3. At all times material to the events alleged in this cause of action the Plaintiff was a citizen of South Africa residing in New York, New York. + +4. At all times material to this cause of action Defendant Jeffrey Epstein had multiple residences, including in New York, New York (within the Southern District of New York) and the United States Virgin Islands. He is currently a citizen of the United States and claims to be a resident of the U.S. Virgin Islands. + +5. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in 1953. + +6. At all times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York and was a citizen of Great Britain and France. + +7. At all times material to this cause of action was a United States citizen, residing in New York, New York (within the Southern District of New York). + +8. At all times material to this cause of action Lesley Groff was a United States citizen, employed by New York based company and regularly conducting business in New York, New York (within the Southern District of New York). + +9. A substantial part of the acts, events, and omissions giving rise to this cause of action occurred in the Southern District of New York; venue is proper in that District. 28 U.S.C. section 1391(b)(2) + +10. At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, and Lesley Groff owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional, criminal, fraudulent, or tortious acts against her, including any acts in violation of 18 U.S.C. §1595. + +## FACTUAL ALLEGATIONS + +11. At all times material to this cause of action, Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is widely recognized as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes and to employ and conspire with a group of numerous others, including each of the named Defendants, to assist in committing those crimes and additional torts as well as to conceal the crimes and torts of the Epstein sex trafficking group from being discovered. + +12. Defendant Epstein displays his enormous wealth, power and influence to his employees; to the victims procured for sexual purposes; and to the public in order to advance and carry out his crimes and torts. At all relevant times, Defendant Epstein owned and continues to own, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats and one or more helicopters. For example, he owned (directly or indirectly) a Boeing aircraft (of make and model B-727-31H with tail number N908JE) and a Gulfstream aircraft + +(of make and model G-1159B with tail number N909JE). He also owned numerous properties and homes, including a 51,000-square-foot mansion in Manhattan; a \$30 Million, 7,500-acre ranch in New Mexico; a 70-acre private island formerly known as Little St. James in or near St. U.S. Virgin Islands; a home in Paris, France; and a mansion in Palm Beach County, Florida. The allegations herein primarily concern the defendant's conduct while at his townhouse in New York; on one or more of his private airplanes; and on his private island in the United States Virgin Islands. Epstein used all of the real and personal property described in this paragraph to facilitate the illegal sex trafficking venture and enterprise described in this Complaint and in furtherance of that venture and enterprise. + +13. Defendant Epstein has a compulsive sexual preference for young females as young as 13 and as "old" as 25. Through information and belief Defendant Epstein engages in sexual acts with this age range every day and developed, through the employment of and conspiracy with the other Defendants, a sex trafficking venture and enterprise designed to fulfill his sexual desires and conceal the operation of the venture and enterprise and conduct of its participants. As part of the venture and enterprise, Epstein also provided young females for sexual purposes to his friends in order to secure social, business, and other contacts as well as other things of value. + +14. Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise. She herself recruited young, including underage, females; oversaw and trained other recniiters on how best to recruit girls for sex; developed and executed schemes designed to recruit young females; and ensured that all participants of the Defendants' sex trafficking scheme acted in certain specific ways in order to advance the purposes of the scheme, including providing young females to Epstein for sexual purposes on a daily basis, and concealing these activities from law enforcement. + +15. Defendant recruited young females for Epstein for sexual purposes, brought gifts to females in order to entice those females to commit sex acts with Epstein and to assist in concealing the illegal sexual conduct of the venture and enterprise, and maintained Epstein's sex schedule in order to ensure that he was not without young females for any extended period of time. Defendant also handled travel arrangements for various females being exploited for sexual purposes. Defendant was an integral part of the sex trafficking venture and enterprise and reported directly up the enterprise's line of authority to Defendants Maxwell and Epstein. + +16. Defendant Epstein employed many recruiters of young females. The nature of the Defendants' sex trafficking venture and enterprise enabled victims themselves to elevate their status to that of a paid recruiter of other victims. Recruiters were taught by Defendants Epstein, Maxwell and to inform targeted victims that Epstein possessed extraordinary wealth, power, resources and influence; that he was a philanthropist who would help female victims advance their careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact, however, these representations were fraudulent. The young females were actually required to perform intimate sexual acts at the Defendants' direction and the Defendants did not help nor intend to help advance the victims' careers. Victims were also paid to bring Epstein other young females for sex and were told by Defendants Epstein, Maxwell, and that those young females who brought other females would further benefit from bringing other girls. + +17. Defendant Groff was an integral part of the illegal venture and enterprise. Groff coordinated schedules between Defendant Epstein and the various young females used for sex; made travel arrangements for the young females; tended to the living needs of those females; communicated and coordinated with Defendants Epstein, Maxwell and to assist in facilitating young females being available in locations where the other Defendants were traveling; and she carried messages to the young females from the other Defendants including false representations in order to maintain the young females' compliance with the rules of sexual compliance imposed by this structured sex-trafficking group. Groff was aware of the activities of the venture and enterprise, including the fraudulent representations and other coercion that was being applied to secure the females' compliance with demands of sex. + +18. The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein's compulsive need for sex with young females by preying on their personal, psychological, financial, and related vulnerabilities. The Defendants' tactics included promising the victims money, shelter, transportation, gifts, employment, admission into educational institutions, educational tuition, protection, and other things of value in exchange for sex. Defendants also took possession of the victims' passports to coerce compliance with their demands. Defendants also trafficked young females to Epstein's friends and acquaintances in order to secure financial and other benefits as well as social, educational, and business connections. + +19. Defendants' sex trafficking venture and enterprise operated in a hierarchal structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top. Defendants Epstein and Maxwell operated the sex trafficking scheme dating back to at least the mid-nineties, and over the years perfected their roles and the roles of others, both in terms of the ability to increase the volume of young females recruited for sex and in insulating the enterprise from criminal investigation or prosecution. Defendant Groff conspired with Defendant Epstein and Maxwell + +since at least 2002 and continues to work for Defendant Epstein today. Defendant began working with the Epstein-run sex trafficking venture and enterprise as early as 2001 and her role in their venture and enterprise was well-defined and primarily consisted of conspiring in the commission and cover-up of sex crimes. Underlings included the other named Defendants as well as unnamed coconspirators such as various housekeepers and butlers; an airplane pilot; and various employees, assistants and associates. Wittingly and unwittingly, such underlings performed their respective roles with the purpose and effect of insuring that the enterprise supplied young females to Defendant Epstein and others for sexual purposes. At all times materials to this complaint, the venture and enterprise was a group of two or more individuals associated in fact and deed. + +20. Defendants Epstein and Maxwell, with help from assistants, associates and underlings, recruited and procured hundreds of girls over the decades of the operation of their scheme. Such recruitment and procurement included fraud, coercion, threats, intimidation, fear, the threat of coercion, and a combination of these and similar tactics. Following the Defendants' recruitment and procurement of the young females to join Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent promises, coercion, and threats of coercion in order to entice and coerce the females into sex and, once sexual activities ensued, to cause them to remain in the enterprise. The Defendants also transported females in + +interstate and foreign commerce and in ways that affected interstate and foreign commerce. The sex acts were commercial in nature, because the Defendants promised to provide financial and other compensation to the females in exchange for providing sex acts to Epstein. + +21. Defendants specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females to provide sex for Epstein. + +22. Additionally, Defendants always made clear to every young female that they were wealthy, well-connected and could either help or hurt the females depending on their degree of cooperation. In fact, Defendants Epstein and Maxwell have been known to threaten young females with physical harm. It is unknown exactly how long the Defendants' criminal and illegal venture and enterprise operated, although it was at least continuously and actively in operation from the mid-1990's through and including the calendar year 2007. + +23. Defendant Epstein has continued the venture and enterprise up to the present time in some form or another and with additional co-conspirators and participants. + +24. In 2005, Defendant Epstein and numerous co-conspirators within the venture and enterprise were the subjects of a Palm Beach, Florida Police Department criminal investigation which revealed that Defendant Epstein had engaged in sexual activities with dozens of young teenage school children. Each child identified in that particular investigation was lured into Defendant Epstein's Palm Beach mansion with a promise that she would receive money for providing him with a body massage, although once there, each young female was made to engage in sexual acts in order to receive the promised compensation. Several were also made to engage in sex with another of Defendant Epstein's female traveling sex companions who Epstein referred to as his lesbian sex slave and bragged about purchasing her from her family x% hen she herself was underage. + +25. In 2006, the Palm Beach Police Department investigation was turned over to the FBI and the United States Attorney's Office for the Southern District of Florida. The United States Attorney's Office investigated Defendant Epstein and his co-conspirators for their violations of numerous federal statutes, including 18 U.S.C. Section 1591, one of the statutory bases for this complaint. + +26. The United States Attorney's investigation continued from 2006 through September 2007, at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office deferring federal prosecution of Defendant Epstein and his numerous co-conspirators, including Defendants and Groff, each named by the Federal Government as coconspirators, for identified federal sex crimes against more than 30 minors. + +27. From late 2006 through September 2007, Epstein's team of lawyers negotiated with the federal government in an effort to avoid a fifty-three-page Federal felony indictment from being filed against Epstein. During these negotiations, Defendant Epstein decamped from Palm Beach to New York and the U.S. Virgin Islands in order to convey an image to prosecutors that he and his coconspirators had stopped committing sex crimes. + +28. Remarkably, however—as this case will highlight—Defendant Epstein and his co-Defendants, including the other defendants named herein, did not abandon their sex trafficking venture and enterprise even 'while they were under state and federal investigation for crimes committed in violation of 18 U.S.C. section 1591, among other laws, and even as Defendants and their attorneys were busy arguing Epstein's innocence and publicly defaming his victims as liars. Rather, Defendants merely changed their location. Instead of targeting local Palm Beach Florida school girls, the Defendants transported young females from other places in the U.S. (including the Southern District of New York) and abroad and brought them to Defendant Epstein's mansion in New York City and his private island in the Virgin Islands. + +29. In June of 2008, Epstein pleaded guilty to Florida state felony sex offenses for procuring a minor for prostitution and soliciting prostitution by minors and registered as a Sex Offender for Life. + +30. Defendants Epstein and Maxwell developed and implemented a sophisticated system designed to insulate them from criminal and civil liability by protecting them from potential testimony of knowledgeable subordinates. + +Defendants and Groff adapted to the system and also carried it out for years in exchange for significant pay, benefits, and protection from prosecution. The system included requiring subordinates to sign confidentiality agreements barring disclosure of criminal activity; maintaining records of underage females who were abused by Epstein; requiring subordinates and victims to refrain from speaking with law enforcement officials; requiring them to notify Defendant Epstein's lawyers in the event they (subordinates and victims) were contacted by law enforcement officials; requiring them to accept the representation of attorneys paid for by Defendant Epstein; requiring them to invoke the Fifth Amendment in response to questions they might be asked by investigators and prosecutors; requiring them to invoke the Fifth Amendment in order to refuse to turn over incriminating and non-incriminating evidence to law enforcement officers; requiring them to destroy evidence or refuse to reveal knowledge of destroyed evidence; and requiring them generally to refuse all cooperation with law enforcement officials or investigations. + +31. In 2005, Defendant Epstein and other co-conspirators, aware that law enforcement officials were preparing imminently to execute a search warrant for his home, removed computer systems that logged information about Epstein and his co-conspirators' illegal and criminal conduct; the identities of witnesses; nude photographs of young females; scheduling books; message pads; tangible items such as vibrators and toys; and other incriminating matter. + +32. The sex recruiting and trafficking venture and enterprise designed to procure young females for sexual purposes and to conceal those activities was developed and fine-tuned over time, and each of the named Defendants had a well-defined role and improved in his/her role over time, with practice and experience. By the time Plaintiff was recruited into victimization, each Defendant had years of experience perfecting methods of coercion, understanding Epstein's requirements, and becoming more loyal to the continuance and survival of the venture and enterprise. All of the Defendant's knew about the activities of the venture and enterprise and worked in concert for the goals of the venture and knowingly benefitted, financially and by receiving things of value, from their participation in the venture and enterprise. + +33. A typical way the Defendants procured young females for sex with Defendant Epstein was to make false promises of a modeling opportunity, offer a better life, offer payment for a formal education, or offer other money or consideration. + +34. Beginning in approximately October 2006 and continuing through April 2007, Defendants recruited Plaintiff into their sexual enterprise by fraudulently promising to use their connections and resources to secure her admission to an institution of higher education at the expense of Defendant Epstein. + +35. One of the enterprise's many recruiters, Natalya was working to recruit young females for Epstein for sex when she approached and recruited Plaintiff. + +36. informed Plaintiff that she would introduce Plaintiff to Defendant Epstein, whom she described as a wealthy philanthropist who regularly used his wealth, influence and connections to help financially poor females like Plaintiff achieve their personal and professional goals and aspirations. + +37. reported to her superiors, Defendants = Groff and Maxwell, and was paid for her recruitment of young females, including Plaintiff + +38. introduced Plaintiff to Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology (known as "F.I.T.") in New York City or into a similar institute of higher learning offering a curriculum of fashion industry training. Between October 2006 and May 2007, Defendants Maxwell, =, and Groff each also confirmed and reiterated this promise to Plaintiff many times, each telling Plaintiff that Epstein would use his wealth and connections to advance Plaintiffs education. More specifically, each of the Defendants last verified this information that Epstein was using his connections to ensure Plaintiff was admitted + +into F.I.T. in exchange for Plaintiff's continued sexual cooperation with Epstein in March or April of 2007. + +39. Defendant Maxwell told Plaintiff she would need to provide Defendant Epstein with body massages in order to reap the benefits of his and Maxwell's connections. + +40. All Defendants, including Maxwell, Epstein, Groff and , knew that Plaintiff was actually being recruited for sexual purposes, and each knowingly and deliberately made false representations to ensure that Plaintiff would cooperate in fulfilling Epstein's sexual desires. These false and fraudulent representations included Defendants' telling Plaintiff that Epstein would use his connections to have her admitted into F.I.T. or a similar institute, college, university or school of higher learning and provide her with employment opportunities. Plaintiff reasonably relied on these representations and had a credible basis for such reliance, including the credible representations of Epstein and the other Defendants that they possessed extensive political, business, financial, social, and educational influence and connections. Epstein and the other Defendants represented to Plaintiff in manners that were persuasive, credible, and reasonable to Plaintiff, as they would have been to any other person similarly situated, that they had the political, business, financial, social, educational, and other influence and + +connections sufficient to arrange for and insure her admission into F.I.T. or a similar school of higher learning. + +41. Maxwell and Epstein also threatened Plaintiff that, while they had the ability to advance her education and career, they also had the ability to make sure that Plaintiff would not obtain formal education or modeling agency contracts if she failed to pros ide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein, Groff, and Maxwell. + +42. Plaintiff reasonably believed that her compliance with Defendants' demands was crucial to her physical, psychological, financial, and reputational well-being and survival. + +43. Defendant Maxwell instructed Plaintiff how to massage Epstein using the techniques that Maxwell knew that Epstein preferred. During Plaintiff's first massage, Defendant Epstein converted it into a sexual act and made it known to Plaintiff that further sex would be required in order for her to obtain the assistance he promised her and to avoid Defendants' threatened retaliation against her if Plaintiff did not perform as demanded. + +44. Maxwell and Epstein informed Plaintiff that other young females in Epstein's company were there also to perform sexual acts for Epstein and his friends. Groff and helped to secure the presence of the other young females for these purposes. + +45. Plaintiff was instructed dozens of times to provide body massages to Epstein, both at his townhouse in New York and on his private island in the U.S. Virgin Islands. Each time she was so instructed she was also required to perform a sexual act with Epstein. The Defendants all participated in arranging for Plaintiff to be transported in interstate and foreign commerce, and affecting interstate and foreign commerce, for these sexual purposes. The Defendants Epstein, Maxwell, and used possession and control of Plaintiff's passport to induce and coerce Plaintiff into performing sexual acts with Epstein and others. + +46. During many sexual encounters, Defendant Epstein gave Plaintiff no option, opportunity, or choice not to participate in the prescribed sexual acts. + +47. Defendant Maxwell frequently controlled the assignment, or "rotation," of Plaintiff and the other young females concerning the time, place and manner of the sex acts they were told to provide to Defendant Epstein. Defendant Maxwell also gave instructions on how to perform certain sexual techniques on Epstein. Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with other females. + +48. Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaintiff with serious harm, as well as serious psychological, financial, and reputational harm, compelling Plaintiff to perform and continue performing the commercial sexual activity demanded by Defendants. + +49. On one occasion, after suffering verbal abuse and threats by Defendants Epstein, Maxwell, and =, Plaintiff attempted to escape from Defendant Epstein's private island. A search party led by Defendants Epstein and Maxwell located her and physically returned her to the main house on the island. Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind. Defendants further used possession and control of Plaintiff's passport, without lawful consent or authority, to restrict Plaintiff's liberty and thereby force her to provide sex to Epstein. + +50. Defendant Epstein's wealth, influence, power and connections were used by Defendants Maxwell, = and Groff, both as an inducement to provide sex (in exchange for promises of support to Plaintiff) and as a means of threatening punishment (in the event Plaintiff refused to comply with Defendants' instructions to provide sex to Epstein and others). + +51. In addition to Plaintiff's being trafficked on Epstein's private airplane, Defendants Groff, Maxwell and , with the knowledge of and instruction by Defendant Epstein, arranged Plaintiffs living accommodations, private car travel, and commercial air travel on numerous occasions for the purpose of causing Plaintiff to commit commercial sex acts. These Defendants worked in concert with one another to recruit, procure, entice, and otherwise cause many other females to engage in commercial sex acts, through their use of threats, fraud, and coercion. Among these means of coercion were the Defendant's possession and control of the females' passports and other immigration documents. This coercion was most salient, and especially effective, while the females, including Plaintiff, were on Epstein's island. + +52. In furtherance of their venture and enterprise, Defendants provided living quarters for Plaintiff at 301 East 66th Street, New York, in the Southern District of New York; a car service for Plaintiff to use as needed; a cell phone; and other valuable consideration in order to maintain Plaintiffs sexual compliance. Each of the Defendants told Plaintiff she would obtain the benefits of a place to live and phone and transportation as long as she remained compliant with their demands that she service Epstein sexually. Each of the Defendants also told her that if she was not compliant, these benefits would be taken from Plaintiff. + +53. The relationship between Plaintiff and Defendants Epstein and Maxwell was defined and characterized by Defendant Epstein's and Defendant Maxwell's frequent and persistent fraudulent representations that they would provide Plaintiff with a formal education and career advancement if she provided sex to Defendant + +Epstein and others in the times, places and manners demanded by Defendants. Defendants Groff and each also told Plaintiff that Defendant Epstein would advance Plaintiffs education and career in order to coerce Plaintiff into sex. Defendant told Plaintiff that Epstein had done the same for her career. As a result of these and other representations by Defendants, Plaintiff reasonably relied on these representations. In fact, however, these representations were knowingly false, were not acted upon by Defendants, and were made by Defendants Epstein, Groff, =, and Maxwell solely for the purpose of maintaining Plaintiffs fmancial dependence on, emotional vulnerability to, and sexual compliance with Defendant Epstein's demands. The other Defendants intentionally repeated these representations and intentionally made statements designed to convince Plaintiff that the representations were true and could be relied upon. These representations and statements were made to Plaintiff in furtherance of the sex trafficking venture and enterprise for which they were each employed. + +54. As part of the venture and enterprise, Defendants Epstein, Maxwell, and took possession of Plaintiff's passport when she was being trafficked by them, including when she travelled to Epstein's island in the U.S. Virgin Islands. The Defendants took possession of Plaintiff's passport in the course of sexually trafficking Plaintiff and with the intent to violate laws against sex trafficking, including 18 U.S.C. 1591 et. seq. The Defendants used their control of Plaintiff's passport in order to coerce compliance with their demands, including their demands that Plaintiff have sex with Epstein and others. + +55. In January 2007, as part of their illegal venture and enterprise, Defendants sent Plaintiff from New York City, in the Southern District of New York, to South Africa to recruit, for a promised fee, one or more aspiring female models supposedly for Epstein to use as a personal assistant. The Defendants did not care whether the prospective female was qualified to work as a personal assistant because each knew that the female recruit would be immediately placed into the same sexually vulnerable position as Plaintiff (and the dozens of other victims of the sex trafficking enterprise) and would be induced and coerced into being used for sex through fraudulent representations and other means. + +56. Defendants Epstein and Maxwell continuously and frequently demanded that Plaintiff fulfill this task of bringing another female back to the United States and Defendants' control as a condition of Plaintiff's receiving the education, career and related benefits promised by Defendants Epstein and Maxwell. Based upon Plaintiff's experience with Defendants, however, she knew that the requested female model would not be placed in a legitimate position of employment with Defendant Epstein but would, instead, be forced into sexual servitude. Plaintiff also knew that this objective was the only purpose of Defendants , Groff, + +Maxwell and Epstein's demand for Plaintiff's recruitment efforts. As a result, Plaintiff deliberately refused to perform the recruitment assignment. + +57. As part of their ongoing scheme, Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts with Epstein and others. While Plaintiff was in South Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be permitted to return to the United States to receive her promised education unless she underwent a diet and lowered her body weight from 57 kilograms (approximately 125 pounds) to 52 kilograms (approximately 114 pounds). Epstein and Maxwell promised Plaintiff that, if she complied, she would receive her promised education. Defendant Groff monitored Plaintiffs progress in losing weight and continued to communicate with Plaintiff about Plaintiff's application to be admitted into F.I.T. as part of the Defendants' ruse to coerce Plaintiff to return to the United States for sex. Defendant Groff was aware of the coercion Epstein and Maxwell were applying to Plaintiff and acted to help further that coercion. Believing she had no practical choice in the matter, Plaintiff attempted to comply with the order but, given her physical height and body structure and her already existing body weight, the diet imposed upon her placed her in serious physical jeopardy, including kidney malfunction and extreme emotional and psychological distress. + +58. As part of their scheme, Defendants Epstein and Maxwell called Plaintiff's parents in South Africa to tell them that Defendant Epstein would take good care of Plaintiff when she returned to the United States, and that Defendants Maxwell and Epstein would use their connections and influence to have her admitted to F.I.T. or another well-regarded fashion school or school of higher learning. + +59. As part of their scheme, Epstein and Groff told Plaintiff that she should fill out an application for admission to F.I.T., and supporting essay, and send it to Epstein for his review. Pursuant to these instructions, Plaintiff completed an application, and supporting essay, and sent it to Epstein. As part of his scheme, Epstein told Plaintiff that he had reviewed these materials. His statements were intended to convince Plaintiff, and had the effect of convincing plaintiff (as they would have convinced any reasonable person), that her admission to F.I.T. was a "done deal" if she would comply with his instructions. Groff also made the same representations to plaintiff on Epstein's behalf. Plaintiff reasonably relied on these representations by Epstein and Groff. + +60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had contacts at F.I.T. and at modeling agencies who could ensure her admission to F.I.T. and advance Plaintiff's career. As part of their scheme, Epstein and Maxwell told Plaintiff about Epstein's vast wealth and specifically identified him as a billionaire. Epstein and Maxwell told Plaintiff that they had extensive contacts, in addition to those identified above, throughout New York City and elsewhere. + +61. In February of 2007, in reliance on promises made by the Defendants, Plaintiff returned to New York City, in the Southern District of New York, and was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants Maxwell, Groff, and Epstein each fraudulently promised Plaintiff again that her sexual compliance would be rewarded with admission to F.I.T. or a comparable college, a promise which they each knew to be false. In fact all four Defendants had for years worked solely to recruit females for sex and to conceal the operation of the sex scheme, and in 2007 were under Federal investigation for their conspiracy to engage in Federal sexual crimes like those committed against Plaintiff. Plaintiff knew that if she did not comply, Defendants Maxwell and Epstein would use their power, influence and connections in order to ensure that Plaintiff was unable to gain admission to F.I.T. or a comparable school, and that they would destroy her career, just as they had destroyed the careers of others who had failed to comply with their demands. + +62. Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiff's continued compliance with Epstein's sexual demands; however, they failed and refused to perform their promises to help Plaintiff be admitted to F.I.T. or another school, or to provide financial support for + +college admission or on-going education, false promises they repeatedly made in order to coerce her into commercial sex acts. + +63. Defendants' sexual demands on Plaintiff continued while she was in New York City, in the Southern District of New York, or in other locations in close proximity to the Defendants. In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, each of the Defendants continued to pressure her to lose excessive amounts of body weight and offered her no opportunity to decline or resist their instructions. + +64. In May, 2007, Plaintiff left the United States and did not return. Between returning from South Africa in February 2007 and leaving in May 2007, Defendants =, Groff, and Maxwell each continued to repeatedly make false representations to Plaintiff, including false and fraudulent representations that she would be admitted to F.I.T. if she continued to engage in sex with Epstein. Defendant Epstein continued to make similar false and fraudulent promises in order to have sex with Plaintiff. + +65. In and after May 2007, Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's coverup included efforts to intimidate witnesses who might provide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done. + +66. Unknown to Plaintiff, Defendants' representations and promises to Plaintiff were all false and fraudulent. Plaintiff reasonably relied on the representations and promises of the Defendants. Plaintiff also considered the Defendants' threats against the current and future well-being and safety of Plaintiff to be real and credible. All such representations, promises, and threats were made solely for the purpose of coercing and otherwise inducing Plaintiff into prolonged sexual compliance. Defendants knowingly benefitted financially and received things of value as a result of coercing and inducing Plaintiff into sexual compliance and otherwise participating in their illegal venture and enterprise. + +## COUNT I CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C. 1595 + +67. Plaintiff adopts and realleges paragraphs 1 through 66 above. + +68. Defendants individually and together, within the special maritime and territorial jurisdiction of the United States, in interstate and foreign commerce, and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, maintained, patronized, solicited, threatened, forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by Defendants were undertaken with knowledge and/or reckless disregard of the fact that their threats of force, fraud, coercion, and combinations of such means would + +be used, and were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In so doing, Defendants violated 18 U.S.C. §1591. + +69. Additionally, Defendants Epstein, Maxwell, and individually and together, knowingly concealed, removed, confiscated, and possessed Plaintiff's passport and associated immigration documents, in the course of violating 18 U.S.C. § 1591, and ith the intent of violating 18 U.S.C. § 1591, and to prevent, restrict, attempt to restrict, without lawful authority, Plaintiff's liberty to move or travel, in order to maintain the sexual services of Plaintiff, while Plaintiff was a victim of a severe form of sex trafficking, as defined in section 103 of the Trafficking Victims Protection Act of 2000, enacted in 22 U.S.C. § 7102. In so doing, Defendants violated 18 U.S.C. § 1592. These Defendants also obstructed, and attempted to obstruct and to interfere with the enforcement of 18 U.S.C. § 1592. + +70. Additionally, Defendants knowingly benefitted, financially and by receiving things of value, from participating in a venture (the Epstein sex trafficking venture enterprise) which had engaged in acts in violation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in such violations. In so doing, Defendants violated 18 U.S.C. § 1593A. + +71. Additionally, Defendants attempted to violate 18 U.S.C. § 1591. In so doing, Defendants violated 18 U.S.C. § 1594(a). + +72. Additionally, Defendants conspired with each other, and with other persons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants violated 18 U.S.C. § 1594(b). + +73. Additionally, Defendants conspired with each other, and with other persons known and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendants violated 18 U.S.C. § 1594(c). + +74. By virtue of their violations of 18 U.S.C. §§ 1591, 1592, 1593A, and 1594, Defendants are subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their violations. + +75. Certain property of Defendant Epstein's was essential to the commission of the federal crimes and torts described herein, including the use of multiple private aircraft including a Boeing aircraft (of make and model B-727-31H with tail number N908JE) and a Gulfstream aircraft (of make and model G-1159B with tail number N909JE). Such aircraft, along with other of Defendants' property, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. + +76. Additionally, Defendant Epstein's New York mansion, located at 9 East 71st Street, New York, New York, in the Southern District of New York, and his private island located in the United States Virgin Islands, were used as means and + +instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. + +77. As a direct and proximate result of Defendants' commission of the aforementioned criminal offenses enumerated in 18 U.S.C. § 1591, 1592, 1593A, and 1594, and the associated civil remedies provided in § 1595, Plaintiff has in the past suffered and will continue to suffer injury and pain; emotional distress; psychological and psychiatric trauma; mental anguish; humiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of enjoyment of life; invasion of privacy; and other damages associated with Defendants' actions. Plaintiff will incur further medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to these losses, Plaintiff has incurred attorneys' fees and will be required do so in the future. + +WHEREFORE, Plaintiff demands judgment against Defendants for compensatory and general damages, attorney's fees, punitive damages and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury. + +Dated: June 5, 2017. + +Respectfully Submitted, + +JAFFE, WEISSING. FISTOS, LEHRMAN, P.L. + +Bar 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954)-524-2820 Fax: (954)-524-2822 Email: brad@pathtojustice.com PRO HAC VICE + +BOLES, SCHILLER & FLEXNER LLP David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 (919) 749-8200 Fax: (914) 749-8300 Email: dboies®bsflIp.com + +Sigrid McCaysle Meredith Boies Schiller & Flexner LLP 401 East Las Olas Blvd., Ste. 1200 Fort Lauderdale, Florida 33301 (954) 356-0011 Fax: Email: smccawley@bsfllp.com Email: mschultz@bsfllp.com PRO HAC VICE + +Paul G Cassell S.J. Quinney College of Law at the University of Utah 383 S. University Street Salt Lake City, UT 84112-0730 (801)-585-5202 Fax: (801)-585-2750 Email: cassellp@law.utah.edue PRO HAC VICE + +• This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation + +### CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on the 5th day of June, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. + +STEPTOE & LLP + +Michael C. + +Justin Y.K. + +mmiller@steptoe.com, cjenkins@steptoe.com, pparker@steptoe.com jchuesteptoe.com, cjenkinsasteptoe.com, pparkerasteptoe.com, psafirstein@steptoe.com + +Attorneys for Defendants Jeffrey Epstein & Lesley Groff + +ALSTON & BIRD, LLP + +John E. Stephenson, Jr. + +Alexander S. Lorenzo + +alexander.lorenzo@alston.com, autodocket-nvc alston.com, managingclerksoffice-nyc@alston.com, john.stephenson@alston.com + +Attorneys for Defendant + +By: \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819762/EFTA02819762.metadata.json b/marker2/court-jane-doe-43/EFTA02819762/EFTA02819762.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..421ebed8d44b085a8303a6570bc6f1454bea938c --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819762/EFTA02819762.metadata.json @@ -0,0 +1,1267 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819762.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 32, + "chars": 43508, + "elapsed_seconds": 6.97, + "image_assets": [], + 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NO.: + +Plaintiff Jane Doe 43, by and through her undersigned counsel, for her claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, Lesley Groff, and Natalya , alleges upon personal knowledge with respect to her own acts and status and upon information and belief as to all other matters, as follows: + +- 1. This cause of action arises under federal statutes and jurisdiction is proper under 28 U.S.C. § 1331. +- 2. Plaintiff files this Complaint under a pseudonym in order to protect her identity because this Complaint makes allegations of a sensitive sexual nature and disclosure of Plaintiffs name publicly will cause further harm to her. +- 3. At all times material to the events alleged in this cause of action the Plaintiff was a citizen of South Africa residing in New York, New York. + +4. At all times material to this cause of action Defendant Jeffrey Epstein had multiple residences, including in New York, New York and the United States Virgin Islands. He is currently a citizen of the United States and a resident of New York and the U.S. Virgin Islands. + +5. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in 1953. + +6. At all times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York and was a citizen of Great Britain and France. + +7. At all times material to this cause of action was residing in New York, New York, and, on information and belief, was a citizen of the United States. + +8. At all times material to this cause of action Lesley Groff was residing in New York, New York and, on information and belief, was a citizen of the United States. + +9. At all material times, Natalya was residing in New York, New York and, on information and belief, was a citizen of the United States. + +10. Including because a substantial part of the events and omissions giving rise to this cause of action occurred in the Southern District of New York, venue is proper in that District. 28 U.S.C. § 1391(b)(2) + +11. At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, , Lesley Groff, and Natalya owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional or tortious illegal acts against her. + +#### FACTUAL ALLEGATIONS + +12. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is known as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes and to employ numerous others, including the named Defendants, to conspire and assist in committing those crimes and additional torts as well as to protect and conceal his crimes and torts from being discovered. + +13. Defendant Epstein displays his enormous wealth, power and influence to his employees; to the victims procured for sexual purposes; and to the public in order to advance and carry out his crimes and torts. At all relevant times, Defendant Epstein owned and continues to own, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats and one or more helicopters. He owned and owns numerous properties and homes, including a 51,000-square-foot mansion in Manhattan; a \$30 Million, 7,500-acre ranch in New Mexico; a 70-acre private island formerly known as Little St. James in or near St. M, U.S. Virgin Islands; a mansion in London, England; a home + +in Paris, France; and a mansion in Palm Beach County, Florida. The allegations herein primarily concern the defendant's conduct while at his townhouse in New York; on one or more of his private airplanes; and on his private island in the United States Virgin Islands. + +14. Defendant Epstein has a compulsive sexual preference for young females as young as 13 and as "old" as 25. Defendant had sex with young females virtually every day and assisted in the development and execution of a sex trafficking scheme designed to fulfill his sexual desires. + +15. Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking enterprise. She herself recruited young females; oversaw and trained other recruiters on how best to recruit girls for sex; developed and executed schemes designed to recruit young females; and ensured that all participants of the Defendants' sex trafficking scheme acted in certain specific ways in order to advance the purposes of the scheme and conceal it from law enforcement. + +16. Defendant recruited young females and maintained Epstein's sex schedule in order to ensure that he was not without the sexual favors of young females for any extended period of time. Defendant also handled travel arrangements for the various females being exploited for sexual purposes. + +Defendant reported directly up the enterprise's line of authority to Defendant Maxwell. + +17. Defendant Epstein employed many recruiters of young females. The nature of the Defendants' sex trafficking scheme enabled victims themselves, such as Defendant to elevate their status to that of a paid recruiter of other victims. Recruiters were taught by Defendants Epstein and Maxwell to inform targeted victims that Epstein possessed extraordinary wealth, power, resources and influence; that he was a philanthropist who would help female victims advance their careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact, however, these representations were fraudulent. The vast majority of girls were required to perform intimate sexual acts at the Defendants' direction and the Defendants did not help or intend to help advance the victims' careers. + +18. Defendant Groff coordinated schedules between Defendant Epstein and the various young females used for sex; made travel arrangements for the girls; tended to their living needs; and communicated with them in order to maintain their compliance with the rules of behavior imposed upon them by the enterprise. + +19. The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein's compulsive need for sex with young females by preying on their personal, psychological, financial, and related vulnerabilities. The Defendants' tactics included promising the victims money, shelter, transportation, employment, admission into educational institutions, educational tuition, and other things of value in exchange for sex. + +20. Defendants' sex trafficking venture and enterprise operated in a hierarchal structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top and underlings below. Underlings included the other named Defendants as well as unnamed co-conspirators such as various housekeepers and butlers; an airplane pilot; and various employees, assistants and associates. Wittingly and unwittingly, such underlings performed their respective roles with the purpose and effect of insuring that the enterprise supplied young females to Defendant Epstein and others for sexual purposes. At all times materials to this complaint, the venture and enterprise was a group of two or more individuals associated in fact and deed. + +21. Defendants Epstein and Maxwell, with help from assistants, associates and underlings, recruited and procured hundreds of girls over the decades of the operation of their scheme. Such recruitment and procurement included fraud, coercion, the threat of coercion, and a combination of these and similar tactics. Following the Defendants' recruitment and procurement of the females to join Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent promises, coercion, and threats of coercion in order to entice young females into sex and, once sexual activities ensued, to cause them to remain in the enterprise. The Defendants also transported females in interstate and foreign commerce and in ways that affected interstate and foreign commerce. + +22. Defendants specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females to join the Defendants' enterprise. + +23. It is unknown exactly how long Defendant Epstein and Maxwell's aforementioned criminal and illegal enterprise operated, although it was at least continuously and actively in operation from the mid-1990's through and including the calendar year 2007. + +24. Defendant Epstein has continued the enterprise and conspiracy up to the present time. + +25. In 2005, Defendant Epstein and numerous co-conspirators within the enterprise were the subjects of a Palm Beach, Florida Police Department criminal investigation which revealed that Defendant Epstein had engaged in sexual activities with dozens of young teenage children. Each child was lured into Defendant Epstein's Palm Beach mansion with a promise that she would receive money for providing him with a body massage, although once there, each child was made to engage in a sex act in order to receive the promised compensation. Several were also made to engage in sex with another of Defendant Epstein's female sexual traveling companions. + +26. In 2006, the Palm Beach Police Department investigation was turned over to the FBI and the United States Attorney's Office for the Southern District of Florida. The United States Attorney's Office investigated Defendant Epstein and his co-conspirators for their violations of numerous federal statutes, including 18 U.S.C. §1591, one of the statutory bases for this complaint. + +27. The United States Attorney's investigation continued from 2006 through September 2007, at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office deferring federal prosecution of Defendant Epstein and his numerous co-conspirators for identified federal sex crimes against more than 30 minors. + +28. From late 2006 through September 2007, Epstein's team of lawyers negotiated with the federal government in an effort to avoid the filing of the fiftythree-page draft indictment of Epstein. During these negotiations, Defendant Epstein decamped from Palm Beach to New York and the U.S. Virgin Islands in order to convey an image to prosecutors that he and his co-conspirators had stopped committing sex crimes. + +29. Remarkably, however—as this case will highlight—Defendant Epstein and his co-Defendants, including the other defendants named herein, did not abandon their sex trafficking enterprise even while they were under state and federal investigation for crimes committed in violation of 18 U.S.C. § 1591, among other laws, and even as Defendants and their attorneys were busy arguing Epstein's innocence and publicly defaming his victims as liars. Rather, Defendants merely changed their style. Instead of targeting local Palm Beach Florida high school girls, the Defendants transported young females from other places in the U.S. and abroad and brought them to Defendant Epstein's mansion in New York and his private island in the Virgin Islands. + +30. In June of 2008, Epstein pleaded guilty to Florida state felony sex offenses for procuring a minor for prostitution and soliciting prostitution by minors. + +31. Defendants Epstein and Maxwell developed and implemented a sophisticated system designed to insulate them from criminal and civil liability by protecting them from potential testimony of knowledgeable subordinates. The system included requiring subordinates to sign confidentiality agreements covering civil and criminal activity; requiring subordinates and victims to refrain from speaking with law enforcement officials; requiring them to notify Defendant Epstein's lawyers in the event they (subordinates and victims) were contacted by law enforcement officials; requiring them to accept the representation of attorneys paid for by Defendant Epstein; requiring them to invoke the Fifth Amendment in + +response to questions they might be asked by investigators and prosecutors; requiring them to invoke the Fifth Amendment in order to refuse to turn over incriminating and non-incriminating evidence to law enforcement officers; requiring them to destroy evidence or refuse to reveal knowledge of destroyed evidence; and requiring them generally to refuse all cooperation with law enforcement officials or investigations. + +32. In 2005, Defendant Epstein and other co-conspirators, aware that law enforcement officials were preparing imminently to execute a search warrant of his home, removed computer systems that logged information about Epstein and his co-conspirators' illegal and criminal conduct; the identities of witnesses; nude photographs of young females; scheduling books; message pads; tangible items such as vibrators and toys; and other incriminating matter. + +33. Commencing in approximately October 2006 and continuing through April 2007, Defendants recruited Plaintiff into their sexual enterprise by fraudulently promising to use their connections and resources to secure her admission to an institution of higher education at the expense of Defendant Epstein. + +34. Defendant was working as one of the enterprise's recruiters of young females when she approached and recruited Plaintiff. + +35. Defendant informed Plaintiff that she would introduce Plaintiff to Defendant Epstein, whom she described as a wealthy philanthropist who regularly used his wealth, influence and connections to help financially poor females like Plaintiff achieve their personal and professional goals and aspirations. + +36. Defendant reported to her superiors, Defendants =, Groff and Maxwell, and was paid for her recruitment of young females, including the recruitment of Plaintiff. + +37. Defendant introduced Plaintiff to Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology, known as "F.I.T.", in New York City, or into a similar institute of higher learning offering a curriculum of fashion industry training. Defendants Maxwell, and Groff each confirmed this promise to Plaintiff many times. + +38. Defendant Maxwell told Plaintiff she would need to provide Defendant Epstein with body massages in order to reap the benefits of his and Maxwell's connections. Maxwell and Epstein also threatened Plaintiff that, while they had the ability to advance her education and career, they also had the ability to make sure that she would obtain no formal education or modeling agency contracts if she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein and Maxwell. + +39. Plaintiff reasonably believed that her compliance with Defendants' demands was crucial to her physical, psychological, financial, and reputational survival. + +40. Defendant Maxwell instructed Plaintiff how to massage Epstein using the techniques that he preferred. During Plaintiff's first massage, Defendant Epstein converted it into a sexual act and made it known to Plaintiff that further sex would be required in order for her to obtain the assistance he promised and to avoid Defendants' threatened retaliation if Plaintiff did not perform as demanded. + +41. Defendants Maxwell and Epstein informed Plaintiff that other young females in Defendant Epstein's company were there not only to provide massages, but also sexual acts. + +42. Plaintiff was instructed dozens of times to provide body massages to Defendant Epstein, both at his townhouse in New York and on his private island in the U.S. Virgin Islands. Each time she was so instructed she was also required to perform a sexual act with Defendant Epstein. The Defendants transported Plaintiff in interstate and foreign commerce, and affecting interstate and foreign commerce, for these sexual purposes. + +43. During many sexual encounters, Defendant Epstein gave Plaintiff no option, opportunity or choice not to participate in the prescribed sexual acts. + +44. Defendant Maxwell frequently controlled the assignment, or "rotation," of Plaintiff and the other young females concerning the time, place and manner of the sex acts they were told to provide to Defendant Epstein. Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with other females. + +45. Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaintiff with serious harm, as well as serious psychological, financial, and reputational harm, with the purpose and effect of compelling Plaintiff to perform and continue performing the demanded commercial sexual activity. + +46. On one occasion, after suffering verbal abuse and threats by Defendants Epstein, Maxwell, and a, Plaintiff attempted to escape from Defendant Epstein's private island. A search party led by Defendant Epstein located her and physically returned her to the main house on the island. Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind. + +47. Defendant Epstein's wealth, influence, power and connections were used both as an inducement to provide sex (in exchange for promises of support), and as a means of threatening punishment (should Plaintiff refuse to comply with Defendants' instructions). + +48. In addition to Plaintiff's being trafficked on Defendant Epstein's private plane, Defendants Groff, Maxwell and with the knowledge of and instruction by Defendant Epstein, arranged Plaintiff's commercial air travel on numerous occasions for the purpose of causing Plaintiff to commit commercial sex acts. + +49. Defendants provided living quarters for Plaintiff at 301 East 66 Street, New York; a car service for Plaintiff to use as needed; a cell phone; and other valuable consideration in order to maintain Plaintiffs sexual compliance. + +50. The relationship between Plaintiff and Defendants Epstein and Maxwell was defined and characterized by Defendant Epstein's and Defendant Maxwell's frequent and persistent fraudulent representations that they would provide Plaintiff with a formal education and career advancement if she provided sex to Defendant Epstein and others in the times, places and manners demanded by Defendants. Plaintiff reasonably relied on those representations. In fact, however, those representations were knowingly false, were not acted upon, and were made by Defendants Epstein and Maxwell solely for the purpose of maintaining Plaintiffs financial dependence on, emotional vulnerability to, and sexual compliance with Defendants Epstein and Maxwell and their demands. The other Defendants intentionally repeated those representations and intentionally attempted to convince Plaintiff that the representations were true and could be relied upon. + +51. In January 2007, Defendants sent Plaintiff from the United States to South Africa in part to recruit, for a promised fee, one or more aspiring female models supposedly for Defendant Epstein to use as an alleged personal assistant. Defendants Epstein and Maxwell continuously and frequently demanded that Plaintiff fulfill this task as a condition of her receiving the education, career and related benefits promised by Defendants Epstein and Maxwell. Based upon Plaintiff's experience with Defendants, however, she did not believe that the requested model would be placed in a legitimate position of employment with Defendant Epstein but would, instead, be forced into sexual servitude. As a result, Plaintiff deliberately refused to perform the recruitment assignment. + +52. As part of their ongoing scheme, Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts. While Plaintiff was in South Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be permitted to return to the United States to receive her promised education unless she underwent a diet and lowered her body weight from 57 kilograms (approximately 125 pounds) to 52 kilograms (approximately 114 pounds). Believing she had no practical choice in the matter, Plaintiff attempted to comply with the order but, given her physical height and structure and her existing low body weight, the diet imposed upon her placed her in serious physical jeopardy, including kidney malfunction and extreme emotional and psychological distress. + +53. Defendants Epstein and Maxwell called Plaintiffs parents in South Africa to tell them that Defendants would take good care of Plaintiff when she returned to the United States and that they would use their connections and influence to have her admitted to F.I.T. or another well-regarded fashion school. + +54. In February of 2007, Plaintiff returned to New York and was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants Maxwell and Epstein fraudulently promised her again that her sexual compliance would be rewarded with admission to F.I.T. or a comparable college, a promise which they knew to be false. Plaintiff knew that if she did not comply, Defendants Maxwell and Epstein would use their power, influence and connections in order to ensure that Plaintiff was unable to gain admission to F.I.T. or a comparable school, and that they would destroy her career as they had destroyed the careers of others who had failed to comply. + +55. Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiffs continued compliance with Epstein's sexual demands; however, they failed and refused to perform their promises to help Plaintiff be admitted to F.I.T. or another school, or to provide financial support for college admission or on-going education, false promises they repeatedly made in order to coerce her into commercial sex acts. + +56. Defendants Epstein and Maxwell's sexual demands on Plaintiff continued while she was in New York or other geographic proximity to the Defendants. In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, Defendants continued to pressure her to lose excessive amounts of body weight and offered her no opportunity to decline or resist their instructions. + +57. In May, 2007, Plaintiff left the United States and did not return. + +58. Defendants' representations and promises were all false and fraudulent. Their threats were considered by Plaintiff to be real and credible. All such representations, promises and threats were made solely for the purpose of coercing and otherwise inducing Plaintiff into prolonged sexual compliance. Defendants knowingly benefitted financially and received things of value as a result of their participating in their illegal enterprise. + +## COUNT I + +#### CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C. 1595 + +59. Plaintiff adopts and realleges paragraphs 1 through 58 above. + +60. Defendants individually and together, within the special maritime and territorial jurisdiction of the United States, in interstate and foreign commerce and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, maintained, patronized, solicited, threatened, forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by Defendants were undertaken with knowledge and/or reckless disregard of the fact that their threats of force, fraud, coercion, and combinations of such means would be used, and were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In so doing, Defendants violated 18 U.S.C. §§1591 through 1594 and are subject to civil causes of action under 18 U.S.C. § 1595. + +61. Defendants additionally profited from the sex trafficking of Plaintiff; obstructed investigations of the violations; attempted and conspired to violate, and succeeded in violating, 18 U.S.C. §§ 1591 through 1595, by the commission of the torts and crimes described in this complaint. + +62. Certain property of Defendant Epstein's was essential to the commission of the federal crimes and torts described herein, including the use of multiple private aircraft including a Boeing aircraft (of make and model B-727- 31H with tail number N908JE) and a Gulfstream aircraft (of make and model G-1159B with tail number N909JE). Such aircraft, along with other of Defendants' + +property, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. + +63. Additionally, Defendant Epstein's New York mansion, located at 9 East 71st street, New York, New York, and his private island located in the United States Virgin Islands, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. + +64. As a direct and proximate result of Defendants' commission of the aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 et. seq. and the civil remedies provided in § 1595, Plaintiff has in the past suffered and will continue to suffer injury and pain; emotional distress; psychological and psychiatric trauma; mental anguish; humiliation; confusion; embarrassment; loss of selfesteem; loss of dignity; loss of enjoyment of life; invasion of privacy; and other damages associated with Defendants' actions. Plaintiff will incur medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to these losses, Plaintiff has incurred attorneys' fees and will do so in the future. + +WHEREFORE, Plaintiff demands judgment against Defendants for compensatory damages, attorney's fees, punitive damages and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury. + +Dated: January 26, 2017 + +Respectfully Submitted, + +BOIES, SCHILLER & FLEXNER LLP + +By: /s/ David Boies + +David Boies + +Boies Schiller & Flexner LLP + +333 Main Street + +Armonk, New York 10504 + +T: (914) 749 8200 + +E: dboies@bsfllp.com + +Alex Boies + +Boies Schiller & Flexner LLP + +575 Lexington Ave., 7'h Fl. + +New York, New York 10022 + +T: (212) 446-2300 + +E: aboies@bsfllp.com + +Sigrid McS i + +Meredith + +Boies Schiller & Flexner LLP + +401 East Las Olas Blvd., Ste. 1200 + +Fort Lauderdale, Florida 33301 + +T: (954) 356-0011 + +E: smccawley®bsflIp.com + +E: mschultz@bsfflp.com + +Pro Hac Vice to be filed + +J. Jaffe, Weissing, + +Fistos & Lehrman, P.L. 425 North Andrews Ave., Ste. 2 Fort Lauderdale, Florida 33301 T: (954) 524-2820 E: brad@pathtojustice.com Pro Hac Vice to be filed + +J. Stanley Pottinger J. 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0000000000000000000000000000000000000000..d47c635b95305894fbd6467175062f0f1cd861d3 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819816/EFTA02819816.md @@ -0,0 +1,227 @@ +# EXHIBIT C + +Michael C 212 506 3955 mmiller©steptoe coin + +1114 Avenue of the Americas New York, NY 10036 212 506 3900 main mvw.steptoe.com + +May 15, 2017 + +Brad Esq. , Jaffe, Weissing, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 + +Dear Brad: + +![](_page_1_Picture_3.jpeg) + +In accordance with the Court's May 15, 2017 Stipulation and Order in the abovereferenced matter, defendants Jeffrey Epstein ("Epstein") and Lesley Groff ("Groff") (collectively "Defendants" set forth in this letter the to which the Complaint filed by plaintiff ("Plaintiff" or ' should be dismissed pursuant to Fed.R.Civ.P. 12(bX2) and (6). + +As athreshold matter, the allegations set forth in paragraphs 12 through 32 of the Complaint relating to state and federal investigations of Epstein, including his prior guilty plea in Florida, referred to herein as the "Prior Proceedings," are scandalous, harassing, and entirely immaterial to the Plaintiff's claims. Plaintiff should remove all of allegations relating to the Prior Proceedings from the Complaint. + +Under Rule 12(1) of the Federal Rules of Civil Procedure, a"court may strike from a pleading ... any ... immaterial, impertinent, or scandalous matter." v. Polk & Wardwell LLP, 850 F. Supp. 2d 392, 416 (S.D.N.Y. 2012). "An allegation is impertinent or immaterial when it is neither responsive nor relevant to the issues involved in the action." Id. "'Scandalous' generally refers to any allegation that unnecessarily reflects on the moral character of an individual or states anything in repulsive language that detracts from the dignity of the court." Id. + +The allegations in the Complaint relating to the Prior Proceedings should be struck from the Complaint, pursuant to Rule 12(1). These allegations have no connection to the Plaintiff. As even you acknowledge to the Court during the April 6, 2017 conference ("April 6 Conference"), the Plaintiff had nothing to do with the Prior Proceedings. Plaintiff's references to the Prior + +![](_page_2_Picture_13.jpeg) + +Proceedings in the Complaint serve only one purpose – to put Epstein in a poor light for conduct wholly unrelated to this dispute. These allegations create a substantial risk that finders of fact might conclude that Epstein engaged in the conduct alleged in the Complaint simply because of the alleged Prior Proceedings. For that reason, evidence of the alleged Prior Proceedings should be removed from the Complaint.1 + +\*\*\*\*\* + +The grounds for dismissal are that: (a) the Complaint fails to state a claim under 18 U.S.C. § 1595 (“Section 1595”), which is the sole claim asserted by Plaintiff; (b) the claim is barred by the statute of limitations; (c) the Complaint fails to allege personal jurisdiction over Defendants; and (d) venue is improperly laid in the Southern District of New York. Because the Plaintiff’s Section 1595 claim turns solely on whether the Defendants engaged in fraud and coercion, as you admitted during the April 6 Conference, this letter will focus on those two elements of the claim. + +#### **I. The Complaint Fails to State a Claim** + +Section 1595 gives rise to civil liability for whoever violates 18 U.S.C. § 1591 (“Section 1591”). The version of Section 1591(a) in effect in 2006-07 provided that: “whoever knowingly ... recruits, entices, harbors, transports, provides, or obtains by any means a person ... knowing that force, fraud, or coercion ... will be used to cause the person to engage in a commercial sex act ... shall be punished as provided in subsection (b).” + +The Complaint fails to establish the elements of a Section 1591(a) violation for at least the following six reasons. First, the Complaint fails to adequately plead that the Defendants used “fraud” to cause Plaintiff to engage in a commercial sex act. Second, the Complaint fails to allege that the Defendants used “coercion” to cause Plaintiff to engage in a commercial sex act. Third, the Complaint fails to establish that any alleged fraud or coercion “caused” the Plaintiff to engage in a commercial sex act. Fourth, the Complaint fails to adequately plead that Groff “knew” that the Plaintiff would be caused by “fraud” or “coercion” to engage in a commercial sex act. Fifth, the Complaint fails to specify what provisions of the commercial sex trafficking + +--- + +1 While Plaintiff makes public accusations against the defendants that are designed to embarrass and harass, she makes these highly charged and scandalous allegations anonymously. As we noted in the Joint Rule 26(f) Report filed on April 5, 2017, Defendants object to Plaintiff’s efforts to proceed in this matter naming the Defendants publicly but without disclosing her own identity. We do not believe that Plaintiff has rebutted the presumption of open court proceedings or met the strict standard required for proceeding anonymously. *See, e.g., Doe v. Shakur*, 164 F.R.D. 359 (S.D.N.Y. 1996). + +Brae, Est May 15, 2017 Page 3 + +![](_page_3_Picture_2.jpeg) + +statutes it is relying on. Finally, the Complaint fails to meet the Twombly/kbal standard for pleading any claim in federal court. + +# A. The Complaint Fails to Plead Fraud + +Plaintiff's claim that the Defendants used "fraud" to cause her to engage in a commercial sex act does not satisfy the pleading requirements for claims sounding in fraud. + +## 1. The Complaint Fails to Satisfy Rule 9(b) + +Plaintiff bases her Section 1595 claims on the Defendants' supposed fraudulent statements and, as a result, the heightened pleading standards set forth in Fed.R.Civ.P 9(b) apply. le v. SAC Trading Corp., 711 F.3d 353, 359 (2d Cir. 2013) (Rule 9(b) "standard also applies to allegations of fraudulent predicate acts supporting a RICO claim"). + +As the Second Circuit explained: + +Rule 9(b) requires that, in alleging fraud or mistake, a party must state with particularity the circumstances constituting fraud or mistake. To satisfy the pleading requirements of Rule 9(b), a complaint must (I) specify the statements that the plaintiff contends were fraudulent, (2) identify the speaker, (3) state where and when the statements were made, and (4) explain why the statements were fraudulent. ... + +[A]Ithough Rule 9(b) permits knowledge to be averred generally, we have repeatedly required plaintiffs to plead the factual basis which gives rise to a strong inference of fraudulent intent. Essentially, while Rule 9(b) permits scienter to be demonstrated by inference, this must not be mistaken for license to base claims of fraud on speculation and conclusory allegations. An ample factual basis must be supplied to support the charges. + +v. Research Applied Associates, 328 Fed.Appx. 744, 747 (2d Cir. 2009); v. Nat'l Prop. Analysts Partners, 936 F.2d 674, 676 (2d Cir.1991). Plaintiff's allegations of fraud boil down to this: Epstein allegedly "confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into the Fashion Institute of Technology" ("FIT"), but had no intention of doing so. Cplt. 11 37, 50, 53-55. This is insufficient to satisfy Rule 9(b). + +First, the Complaint fails to identify with particularity the "fraudulent statements" that Epstein or Groff are each alleged to have made to Plaintiff. Indeed, the Complaint only alleges that Epstein "confirmed" this representation, that Groff "confirmed this promise to Plaintiff many times." and that the representation was "intentionally repeated." Cplt. VI 37, 50. These + +![](_page_4_Picture_11.jpeg) + +allegations fail to provide the particulars of what each Defendant said to Plaintiff on each occasion when each of the alleged misrepresentations was made. + +Second, the Complaint fails to identify with particularity that Epstein and Groff were the speakers of these alleged fraudulent statements. Indeed, the Complaint only alleges that Epstein and Groff "confirmed" the statements, not that they made the statements. Cplt. ¶¶ 37, 50. The Complaint does not allege who actually made the alleged statement that was allegedly confirmed by the Defendants. Indeed, as to Groff, there is no allegation that she ever spoke to or met with Plaintiff. + +Third, the Complaint fails to allege with particularity "where and when" the alleged fraudulent statements were supposedly made. Rather, the Complaint only alleges that Defendants allegedly "confirmed" and "repeated" supposed fraudulent statements "many times." Cplt. ¶¶ 37, 50. In addition to failing to meet the requirements of Rule 9(b), these allegations fall short of the basic fairness requirement, since Defendants are entitled to know when and where they supposedly made fraudulent statements to Plaintiff, especially given that Plaintiff has asserted a claim based on events that occurred over ten years ago. + +Fourth, the Complaint fails to allege with particularity how the fraudulent promises about Plaintiff's prospects for admission to FIT, if made at all, were fraudulent. The Complaint merely states in conclusory terms that the statements were "knowingly false" and "not acted upon." Cplt. ¶ 50. However, there are no factual allegations to support the assertion that the statements about the Plaintiff and FIT were false when made. Plaintiff's allegations that the Defendants did not act on the alleged promise is insufficient to show that the representation was false when made. *Greenberg v. Chrust*, 198 F.Supp.2d 578, 583 (S.D.N.Y. 2002) ("failure to fulfill a promise to perform future acts is not grounds for a fraud action" and "fraudulent intent cannot be inferred merely from the non-performance of a party's representations"). + +Finally, the Complaint fails to provide a factual basis, let alone an "ample factual basis," that would give rise to a "strong inference of fraudulent intent." [REDACTED], 328 Fed.Appx. at 747; *O'Brien*, 936 F.2d at 676. The allegation that Epstein had no intention of following through on his alleged promises to assist Plaintiff in gaining admission to FIT is merely conclusory, and does not satisfy the requirements of Rule 9(b). *Greenberg*, 198 F.Supp.2d at 583 ("fraudulent intent cannot be inferred merely from the non-performance of a party's representations"). Plaintiff has alleged no facts to support the contention that Epstein did not perform as he allegedly promised. Instead, the factual allegations state that Epstein promised and Plaintiff received generous support from Epstein, including "living quarters at 301 East 66[th] Street" on the Upper East Side of Manhattan, "a car service for Plaintiff to use as needed" and a "cell phone." Cplt. ¶ 49. These specific factual allegations do not support and, indeed, are wholly inconsistent with Plaintiff's conclusory assertion that Epstein had no intention of helping Plaintiff to gain admission to FIT. Accepting the allegations as true, they tend to demonstrate + +![](_page_5_Picture_13.jpeg) + +that Plaintiff was receiving support from Epstein in several respects and provide no hint of any prior intention of Epstein to withhold support in the specific area of Plaintiff's education. + +On a related note, the Complaint is utterly silent as to the date by which Epstein allegedly promised that the Plaintiff would be admitted to FIT or some other comparable school. Not surprisingly, there is nothing in the Complaint which demonstrates that a specific promised deadline lapsed. + +Based on the foregoing, the Complaint fails to establish facts sufficient to infer that Epstein would not follow through on the alleged promises of assistance with admission to FIT. As to Groff, there is simply no allegation of fraudulent intent on her part or that Groff knew that Plaintiff was engaged in a sexual relationship with Epstein in exchange for the alleged promises. + +In short, the Complaint fails to meet the pleading standards required under Rule 9(b) with respect to every element required to establish that Epstein and Groff made fraudulent statements. + +## 2. The Complaint Fails for Lack of Reasonable Reliance + +The Complaint also fails to plead facts which establish that the Plaintiff reasonably relied on the misrepresentations allegedly made by the Defendants. In order to state a claim sounding in fraud, a plaintiff must plead, among other things, that she reasonably relied on the alleged misrepresentation. *Crigger v. Fahnstock & Co., Inc.*, 443 F.3d 230, 234 (2d Cir. 2006). The Complaint does not meet this basic requirement. Instead, the Complaint merely states in conclusory terms that "Plaintiff reasonably relied" on the alleged misrepresentations. Cplt. ¶ 50. The Complaint, however, does not provide any factual support for this conclusion. In fact, the allegations in the Complaint support just the opposite. According to the Complaint, at the time the statement was made about Plaintiff's prospects for admission to FIT, the Plaintiff barely knew Epstein – she had been introduced to Epstein by yet another person whom she barely knew. Cplt. ¶¶ 35, 37. That such a stranger would offer to "use his wealth and influence to have Plaintiff admitted to" FIT or a similar institution in exchange for sexual favors would cause any reasonable person, especially under the circumstances alleged in the Complaint, to question, rather than rely on, such a promise. + +Moreover, the Complaint fails to allege facts from which the Plaintiff might have reasonably concluded that Epstein had the ability "to have Plaintiff admitted to" FIT. For example, the Complaint fails to allege that Epstein was associated in any way with FIT. *Ashland Inc. v. [REDACTED] Stanley & Co.*, 652 F.3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); *Schlaifer [REDACTED] & Co. v. Estate of Warhol*, 119 F.3d 91, 98 (2d Cir. 1997) ("circumstances may be so suspicious as to suggest to a reasonably prudent plaintiff that the defendant's representations may be false, and that the plaintiff cannot reasonably rely on those representations"). + +![](_page_6_Picture_12.jpeg) + +In short, the Complaint fails to establish that Plaintiff reasonably relied on the alleged fraudulent statements about her prospects for admission to FIT that she attributes to Epstein and Groff.2 + +### 3. The Complaint Impermissibly Lumps All Defendants Together + +The Complaint engages in rampant and impermissible “group pleading.” It repeatedly attributes the same conduct and/or statement to all or multiple defendants without identifying which individual defendant engaged in the alleged conduct or made the alleged statement. Cplt. ¶¶ 33, 38, 44, 45, 49, 50, 51, 52, 54, 55, 56, 58. Since the asserted claim involves allegations of fraud, the Plaintiff’s decision to lump all defendants in groups is insufficient to state a claim. *Camofi [REDACTED] LDC v. Riptide Worldwide, Inc.*, 2011 WL 1197659, at \*6 (S.D.N.Y. Mar. 25, 2011) (“group pleading doctrine is an exception to the requirement that the fraudulent acts of each of the defendants be identified separately in the complaint,” its application is “limited to group-published documents,” and “does not apply to oral statements”); *In re Braskem S.A. Sec. Litig.*, 2017 WL 1216592, at \*20 (S.D.N.Y. Mar. 30, 2017) (“the Court has doubt whether the group-pleading doctrine remains good law”). + +A small sampling of Plaintiff’s allegations which repeatedly and impermissibly lump all Defendants together amply demonstrates the insurmountable defects in her Complaint. First, the Complaint alleges that “Defendants recruited Plaintiff into their sexual enterprise,” without identifying which defendant was involved and what individual action each defendant allegedly took to recruit Plaintiff. Cplt. ¶¶ 33. Second, the Complaint alleges that “Defendants sent Plaintiff from the United States to South Africa in part to recruit” without specifying which defendant supposedly “sent” Plaintiff or communicated to Plaintiff what, if anything, she was supposed to do upon her arrival in South Africa. Cplt. ¶ 51. Third, the Complaint alleges that “in addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, Defendants continued to pressure her to lose excessive amounts of body weight and offered her no opportunity to decline or resist their instructions.” Cplt. ¶ 56. Yet, the Complaint does not state which defendants allegedly “required” Plaintiff to provide sex acts, “pressure[d]” her to lose excessive weight, or offered Plaintiff no opportunity to decline or resist these alleged demands. + +By engaging in this pattern of improper group pleading, the Complaint fails to state a legally sufficient claim, based on both theories of “fraud” and “coercion,” against any one of the Defendants. + +--- + +2 Assuming arguendo that Plaintiff’s reliance on Epstein’s representations was ever reasonable, her reliance certainly was not plausible by January 2007, when Plaintiff expressly acknowledged that she “did not believe” the Defendants. Cplt. ¶ 51. Her distrust of the Defendants renders her claim time-barred, as explained in detail below. *Infra*, pp. 10-12. + +![](_page_7_Picture_13.jpeg) + +#### 4. Section 1591 Does Not Cover Garden Variety Fraud + +Congress enacted Section 1591 in order to “combat trafficking in persons, a contemporary manifestation of slavery whose victims are predominantly women and children, to ensure just and effective punishment of traffickers, and to protect their victims.” H.R. Conf. Rep. 106-939 (2000). Among other specific factual findings reached by Congress when it was drafting Section 1591, Congress found as follows: + +Traffickers lure women and girls into their networks through false promises of decent working conditions at relatively good pay as nannies, maids, dancers, factory workers, restaurant workers, sales clerks, or models. + +*Id.* Congress also found that additional legislation was needed to combat commercial sex engaged in by women lured to the United States by means of fraud. *Id.* Based on these factual findings, Congress enacted Section 1591 to prohibit sex trafficking “by means” of fraud. *Id.*; 18 U.S.C. 1591(a)(1). + +Based on this legislative history, and a clear reading of Section 1591, this statute was not designed to address the relationship which, according to the Complaint, the Plaintiff entered into with Epstein. The allegations in the Complaint do not establish that the Plaintiff was a victim of sex trafficking under Section 1591 or that she participated in commercial sexual acts as a result of a “fraud” perpetrated by the Defendants. + +First, there are no allegations that “traffickers lured [Plaintiff] into their network by false promises” of a job. Instead, Plaintiff alleges that, without the involvement of any of the Defendants, she traveled to the United States on her own volition and for reasons that appear to have nothing whatsoever to do with the Defendants. She then voluntarily associated herself with the Defendants and, accepting the truth of Plaintiff’s allegations fully, engaged in sexual activity with Epstein because she perceived that Epstein could provide her with some advantage in gaining entrance to an institution of higher learning and because she was given living quarters on the Upper East Side of Manhattan, the use of a car service and a cell phone. These factual allegations do not demonstrate that she was a victim of fraud, much less a victim of sex trafficking requiring the protection of Section 1591. + +Second, to the extent that Epstein allegedly made promises to the Plaintiff that were not fulfilled in a timeframe that Plaintiff expected or wanted, these sorts of issues are a matter for resolution between these two adults who allegedly entered into an adult relationship. When enacting Section 1591, Congress did not evidence any intention to legislate the private relationship between two consenting adults. + +![](_page_8_Picture_12.jpeg) + +**B. The Complaint Fails to Plead Coercion** + +The Complaint fails to allege that the Defendants used “coercion” to cause the Plaintiff to engage in a commercial sex act. The statute defines coercion to include the following categories of conduct: + +- (A) threats of serious harm to or physical restraint against any person; +- (B) any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person; or +- (C) the abuse or threatened abuse of law or the legal process. + +The Complaint simply fails to meet any of these three theories for establishing coercion. + +First, the allegations of coercion are unspecific and wholly conclusory, as exemplified by the allegations in paragraph 45 that “Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaintiff with serious harm, as well as serious psychological, financial, and reputational harm, with the purpose and effect of compelling Plaintiff to perform and continue performing the demanded commercial sexual activity.” Cplt. ¶ 45. The Complaint does not allege a single specific factual instance where Epstein or Groff made a “threat[] of serious harm to or physical restraint against” the Plaintiff. Indeed, the Complaint speaks of only one occasion where Plaintiff allegedly suffered unspecified “verbal abuse and threats” and, as a result, “attempted to escape from Defendant Epstein’s private island.” Cplt. ¶ 46. This single allegation taken as true does not establish that Plaintiff was subject to a threat of serious harm. And the fact that the Plaintiff was allegedly “returned” to the house on the island does not demonstrate that she was subject to “physical restraint.” And there is nothing alleged in the Complaint that demonstrates that this isolated incident had anything at all to do with whatever sexual activity Plaintiff claims she engaged in. + +Second, the Complaint fails to establish that there was a “scheme, plan, or pattern” to cause Plaintiff to believe that she would be seriously harmed or restrained. Indeed, the Complaint is devoid of specific factual allegations concerning threats of physical harm, as discussed above. And, with respect to physical restraint, the Complaint alleges that Plaintiff traveled freely within the United States and abroad, and was provided with living quarters of her own on the Upper East Side of Manhattan as well as a car service and cellphone. Cplt. ¶¶ 49, 51, 57. Plaintiff alleges that, when Plaintiff was in South Africa, where she held citizenship and where her parents resided, Epstein and Maxwell told her that “she would not be permitted to return to the United States to receive her promised education unless she lost weight.” Plaintiff does not explain how any of the defendants would have any ability to deny her entry to the United States. Plaintiff has not alleged that any of the defendants held her travel documents or had any power to affect her ability to travel to the United States. To the contrary, the Complaint alleges that she traveled to and from the United States as she wished. Indeed, she admits that + +![](_page_9_Picture_13.jpeg) + +“she refused to perform the recruitment assignment” allegedly “demanded” by Epstein to find young females to serve in “sexual servitude.” Cplt. ¶ 51. Yet, she was able to come back to the United States. Moreover, there is no showing of any threatened “serious harm” had she chosen to remain in South Africa. There is simply no “threat of serious harm” alleged. In any event, this isolated allegation does not establish the existence of a “scheme, plan or pattern” at all, much less a “scheme, plan or pattern” which would cause Plaintiff to believe she would be in serious harm or physical restraint if she did not engage in commercial sexual activity. Cplt. ¶ 5. + +Third, a withdrawal of support to gain admission to FIT or refusal to provide living quarters on the Upper East Side of Manhattan or a car service does not constitute “threats of serious harm.” A withdrawal of such support would simply mean that Plaintiff would no longer have the desired life style or assistance for potential educational advancement as to which she had neither a legal right nor moral entitlement. + +Similarly, the supposed threat by Maxwell and Epstein that “they had the ability to make sure that they would obtain no formal education or modeling agency contracts if she failed to provide sexual favors” is no threat at all. Cplt. ¶ 38. Plaintiff is not alleged to be a gullible person with diminished capacity, or uneducated or inexperienced socially. It is implausible for Plaintiff or any other reasonable person to perceive this as a realistic threat or to believe that defendants had such omnipotent ability. The pleading standard is not lowered simply because Epstein is alleged to be “rich and powerful.” + +Fourth, the Complaint does not allege that the Defendants engaged in any “abuse or threatened abuse of the law or legal process” required by the statute. + +#### **C. The Complaints Fails to Plead a Causal Link** + +The Complaint fails to plead that the Defendants’ alleged fraudulent and coercive conduct “caused” the Plaintiff to engage in a commercial sex act, as required under Section 1591. *United States v. Marcus*, 487 F.Supp.2d 289, 306-07 (E.D.N.Y. 2007), rev’d on other grounds, 538 F.3d 97 (2d Cir. 2008) (a violation of Section 1591 requires that a “commercial sex act ... be a product of force, fraud or coercion.”) The Complaint fails to establish any linkage between the alleged promises of admission to FIT and criticism about the Defendants’ weight and appearance, and any sexual act performed by the Plaintiff. + +Indeed, the clear implication of the Complaint is exactly the opposite. The Complaint can be fairly read to evidence that the Plaintiff, then a 22 year old adult woman, was engaged in a consensual sexual relationship with Epstein, an unmarried adult man, on her own accord, which she was free to terminate at will. Her allegations of receiving financial support amount to nothing more than the claims of an adult girlfriend who received financial support from someone with whom she was in a romantic relationship. When she became dissatisfied with that relationship and decided to terminate it, as would properly be expected of any similar relationship, the financial support she received based on that relationship terminated as + +Brad , Esq. May 15, 2017 Page 10 + +well. Whatever unfulfilled promises about an education at FIT and unwelcome criticism Plaintiff claims to have experienced, the Complaint makes clear that her sexual acts were not specifically the product of those two events. + +Finally, the sex acts alleged in the Complaint are not "commercial sex" acts, much less sex acts in violation of Section 1591. If they were, a significant percentage of the population likely would have engaged in commercial sex and violated the statute. + +In short, Plaintiff fails to establish the required causal link between the alleged fraud and coercion and her sexual conduct. She also fails to establish that she engaged in "commercial sex." + +## D. The Complaint Fails To Allege Knowledge Against Groff + +The Complaint fails to allege facts which establish that Groff engaged in any conduct "knowing that force, fraud, or coercion ... will be used to cause [the Plaintiff] to engage in a commercial sex act," as required in Section 1591. Here, there are no specific factual allegations showing that Groff knew that the Plaintiff was engaged in a sexual relationship with Epstein, much less that Groff knew that Plaintiff was engaged in commercial sex caused by fraud or coercion. At best, the allegations show that Groff performed legitimate secretarial functions such as making travel arrangements. Cplt. ¶¶ 48. The conclusory allegations against Groff are insufficient to show that she had the "knowledge" required for liability under Section 1591. + +## E. The Complaint Fails to Specify the Particular Statutes Allegedly Violated + +The Complaint is also defective because it fails to specify the particular statutes and sections which were allegedly violated. Rather, it lumps together Sections 1591 through 1594, without specifying which of these particular statutes were violated and without providing factual bases for the alleged violations of the particular statutes. For example, while Section 1592 prohibits unlawful conduct with respect to immigration documents, the Complaint is bereft of any allegation concerning Plaintiff's immigration documents or status. Moreover, Sections 1593 and 1593A do not prohibit any conduct, let alone conduct that would give rise to a Section 1595 claim. Rather, those sections provide for the remedy of restitution and the penalty of a fine or imprisonment. + +These failings should result in a dismissal of the Complaint. v. Grubman, 568 F.3d. 329, 336 (2d Cir. 2009) (dismissing Complaint for failure to specify the particular sections of the statutes claimed to have been violated, explaining that such a failure "obstructed any analysis of whether plaintiffs' pleading stated a claim under Georgia's securities statute, insofar as the complaint tracks several of the statute's provisions"). At a minimum, the Complaint must specify the particular statutes and sections claimed to have been violated and the factual basis for the alleged violations which are necessary predicates for a civil recovery under + +![](_page_11_Picture_12.jpeg) + +Section 1595. Defendants are entitled to know this basic information, so as to be able to analyze whether Plaintiff has stated a claim under the different sections of the statutes. *Id.* + +**F. The Complaint Fails to Meet the *Twombly/Igbal* Standard** + +The Complaint not only fails to meet the heightened pleading standards applicable to fraud based claims, it also fails to meet the more relaxed pleading standards set forth by the United States Supreme Court in *Bell Atlantic Corp. v. Twombly*, 127 S.Ct. 1955 (2007) and *Ashcroft v. Igbal*, 129 S.Ct. 1937 (2009). These two decisions set forth the basic requirements for pleading a claim. As explained and applied by the Second Circuit: + +To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face. A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. The plausibility standard is not akin to a probability requirement, but it asks for more than a sheer possibility that a defendant has acted unlawfully. Where a complaint pleads facts that are merely consistent with a defendant's liability, it stops short of the line between possibility and plausibility of entitlement to relief. + +[REDACTED] 328 Fed.Appx. at 747 (quoting *Igbal*, 129 S.Ct. at 1949). Here, at best, the Complaint merely parrots the statutory elements of a Section 1595 claim regarding fraud and coercion without specifically alleging the factual basis for those elements. As described in more detail, above, the Complaint fails to meet the *Twombly/Igbal* pleading standard. The Complaint, taken as a whole, does not plead a plausible claim that Plaintiff was a victim of sex trafficking in violation of criminal statutes entitling her to civil relief pursuant to Section 1595. Instead, the Complaint as a whole presents the Plaintiff as a consenting adult engaged in a voluntary relationship with Epstein which provided the Plaintiff with a remarkably comfortable life style and the prospects of help with her FIT application. This is hardly the sort of relationship that this sex trafficking statute was designed to address. + +Moreover, the Complaint does not allege that Plaintiff was a minor, that she was uneducated or that she was inexperienced in the world. Rather, the absence of such allegations shows that Plaintiff was an educated adult who was experienced in the world and who freely chose to engage in the alleged sex acts set forth in the Complaint. Plaintiff's allegations of fraud and coercion are simply not plausible, and, as a result, the Complaint fails under the *Twombly/Igbal* pleading standard. + +![](_page_12_Picture_12.jpeg) + +## II. The Claim Is Barred by the Statute of Limitations + +Plaintiff's claim is time-barred under either (a) the four-year statute of limitations applicable to claims that arose before the 2008 statutory amendment that extended the limitations period to ten years or (b) even the current ten-year statute of limitations period. + +Plaintiff's claim is barred by the four-year statute of limitations. According to the Complaint, the conduct giving rise to the claim allegedly occurred between October 2006 and April 2007, and Plaintiff "left the United States" in May 2007 and "did not return." Cplt. ¶¶ 33, 57. This action was not commenced until January 27, 2017, more than four years after any of the events alleged in the Complaint occurred. Plaintiff's claim is therefore time-barred. *Abarca v. Little*, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in *Abarca*, a claim under Section 1595 had a four-year of statute of limitations when originally enacted. The statute was amended in December 2008 and the limitations period was extended to ten years. *Id.* However, "Congress did not expressly state or otherwise indicate that the [statute's] limitations period applies retroactively." *Id.* The plaintiff in *Abarca*, like Plaintiff here, filed the Section 1595 claim after the statute was amended to provide for a ten-year statute of limitations. Applying the well-established presumption against retroactive legislation, the Court in *Abarca* determined that the ten-year statute of limitation did not apply because the alleged wrongful conduct occurred before the statute of limitations was amended. *Id.* at 1069. The Court therefore applied the four-year statute of limitations and dismissed the Section 1595 claim because it was filed more than four years after the alleged wrongful acts. *Id.* + +Here, all events alleged in the Complaint ended in 2007, before the 2008 amendment extending the limitations period from four to ten years was enacted. As a result, the four-year statute of limitations applies. Plaintiff's claim, filed in January 2017 and more than four years after the events described in the Complaint, is time-barred. + +Even if the ten year statute of limitations applies, Plaintiff's claim is still time-barred. Plaintiff admits in her Complaint that, when she traveled to South Africa in January 2007, she no longer trusted the Defendants. In fact, Plaintiff alleges that she knew she was being asked to recruit "female models" from South Africa who would not be placed in legitimate positions, but would instead "be forced into sexual servitude." Cplt. ¶ 51. Plaintiff has expressly acknowledged in the Complaint that, as of January 2007, "she did not believe that the requested model would be placed in a legitimate position of employment with Defendant Epstein but would, instead, be forced into sexual servitude." *Id.* Clearly, by January 2007, Plaintiff could no longer claim to be reasonably relying on Defendants' representations about, for example, gaining admission to FIT. Because Plaintiff's claim admittedly turns on whether she was defrauded and coerced, the statute of limitations period on her Section 1595 claim commenced to run no later than January 2007 and expired before the Complaint was filed on January 27, 2017. + +Moreover, since Plaintiff left the United States in January 2007 and went to South Africa, where she held citizenship and where her parents reside, any arguable coercion terminated at that + +![](_page_13_Picture_11.jpeg) + +time. Cplt. ¶ 53. There is nothing to support the contention that the Defendants engaged in coercion to procure sexual acts from the Plaintiff. Plaintiff was under no compulsion whatsoever to return to the United States or to continue her alleged association with Defendants. In fact, she admits that she freely “refused to perform the recruitment assignment” alleged “demanded” of her to find females to serve in “sexual servitude.” Cplt. ¶ 51. By her own admission, whatever “coercion” defendants might have had on Plaintiff ceased at that time. Moreover, she could have chosen to stay in South Africa. Her alleged further association with Defendants when she returned to New York in February 2007 was purely the voluntary action of an adult, as were all of her other actions. Significantly, Plaintiff alleges no threat to her since February 2007 when she returned from South Africa. She merely alleges that she “knew” what Maxwell and Epstein might do, not what Maxwell or Epstein actually said or did. Cplt. ¶ 54. Since no act of coercion occurred within ten years before the lawsuit was filed on January 27, 2017, Plaintiff’s claim is time-barred. + +The assertions that Defendants defrauded her or coerced Plaintiff into commercial sex when she returned to the United States in February 2007 are wholly insufficient as a matter of law. Although the Complaint repeats some of the same conclusory and vague allegations relating to the earlier period outside of even the 10-year statute of limitations, it again provides none of the specific factual allegations necessary to establish what Epstein or Groff actually did during that limitations period to violate the statute. + +### **III. The Court Does Not Have Jurisdiction Over Defendants** + +The Complaint alleges without elaboration that Defendants are residents of New York. Cplt. ¶¶ 4, 8. However, the Complaint alleges no facts to support this assertion. In fact, as you know, you cannot support these allegations of ties to New York. As we believe you know, Epstein is domiciled in the U.S. Virgin Islands and Groff is domiciled in Connecticut. Indeed, you attempted to serve Groff at her residence in Connecticut, not New York. As a result, personal jurisdiction over the Defendants would have to be based on tortious conduct allegedly committed in New York. CPLR 302(a)(2). As explained below, however, there are insufficient allegations of tortious conduct during the limitations period upon which Plaintiff can base personal jurisdiction, even if the ten year limitations period were to apply, which Defendants maintain it does not. + +Because the Complaint was filed on January 27, 2017, all of the conduct alleged to have occurred before February 2007 falls outside of even the ten year limitations period. The Complaint, however, does not allege conduct after Plaintiff left for South Africa in January 2007 that can be fairly said to be subject to a Section 1595 claim, as discussed in detail above. Cplt. ¶¶ 53-56. Indeed, the Complaint does not mention Groff at all after Plaintiff left for South Africa in January 2007. Moreover, there are no allegations regarding the whereabouts of the Defendants during that time period. The allegations concerning this period merely track the statutory language but without providing the necessary factual support. The Complaint, therefore, fails to establish that the Court has personal jurisdiction over Epstein and Groff. + +Brad May 15, 2017 Page 14 + +![](_page_14_Picture_2.jpeg) + +### IV. Venue Is Improperly Laid in the Southern District of New York + +For the same reasons that the Court lacks personal jurisdiction over the Defendants, the Southern District of New York is not the proper venue for this action. The applicable venue statute, 28 U.S.C. § 1391(b)(2), requires that "a substantial part of the event or omission giving rise to the claim occurred" within the Southern District of New York. This fundamental element is not met here. The conduct alleged occurred outside of the statute of limitations period and cannot form the basis of either a claim or venue. + +For all of the reasons set forth, above, this case lacks merit and should be dismissed no matter where it is filed. Having said that, and as you know, Epstein resides in the U.S. Virgin Islands, where the court has personal jurisdiction over him. Moreover, the other Defendants are all located in states other than New York and no significant part of the events within the statute of limitations period occurred in New York. 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sha256:d27409b51059118ff84b9eb83b8a23e1436538f1a599105de25052a3a9fa2aab +size 3265 diff --git a/marker2/court-jane-doe-43/EFTA02819831/EFTA02819831.md b/marker2/court-jane-doe-43/EFTA02819831/EFTA02819831.md new file mode 100644 index 0000000000000000000000000000000000000000..3ebf6cefea3af80df81cad34f969c4713cc9a16a --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819831/EFTA02819831.md @@ -0,0 +1,29 @@ +## EXHIBIT D + +ehe New Mork ititco https.//nyti.ms/2jvHgf5 + +Opinion LETTER + +## How David Boies Saved Me + +NOV. is, 2017 + +To the Editor: + +Re "David Boies's Egregious Involvement With Harvey Weinstein" (Op-Ed, nytimes.com, Nov. 9): + +Having read the article by Prof. Deborah L Rhode criticizing the lawyer David Boies, I doubt that she has any firsthand experience with how Mr. Boies deals with rape and abuse victims. + +I do, because I am one. When I was in the depths of despair from having been trafficked by very powerful, wealthy people, I was unable to find anyone who would take my abuse seriously. Mr. Boies heard me and came to my rescue. He examined my experiences, sorted out the factual wheat from the confusing chaff, and filed my case. Everything he and his colleagues did was the very opposite of intimidation or silencing. + +They have protected me right from the beginning, as it was fear of being harmed that kept me from coming forward many years ago. For the first time in 10 years I finally feel safe because of David Boies and his colleagues. + +What's more, his firm did not charge me legal fees. Like many other victims he represents, I will be forever grateful to him for bringing the abuse I suffered to the attention of the courts and the public. + +BARCELONA, SPAIN + +The writer is the plaintiff in Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, + +, Lesley Groff and NatalyalM. + +2017 The New York Times Company \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819831/EFTA02819831.metadata.json b/marker2/court-jane-doe-43/EFTA02819831/EFTA02819831.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1d5860ec5b74df1a8f1568880d654d37413428b3 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819831/EFTA02819831.metadata.json @@ -0,0 +1,177 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819831.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 1428, + "elapsed_seconds": 0.79, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "EXHIBIT D", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 170.13600000000002, + 281.5112609863281 + ], + [ + 448.3228759765625, + 281.5112609863281 + ], + [ + 448.3228759765625, + 333.16168212890625 + ], + [ + 170.13600000000002, + 333.16168212890625 + ] + ] + }, + { + "title": "How David Boies Saved Me", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 70.38, + 200.07 + ], + [ + 412.10107421875, + 200.07 + ], + [ + 412.10107421875, + 233.49188232421875 + ], + [ + 70.38, + 233.49188232421875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 3 + ], + [ + "Line", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "Line", + 29 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 8 + ], + [ + "PageHeader", + 6 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819831" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819834/EFTA02819834.md b/marker2/court-jane-doe-43/EFTA02819834/EFTA02819834.md new file mode 100644 index 0000000000000000000000000000000000000000..a825f0b46692d02a37c66bb1ad4c3ad241998640 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819834/EFTA02819834.md @@ -0,0 +1,496 @@ +# EXHIBIT E + +Document comparison by Workshare Compare on Monday, June 05, 2017 6:18:32 PM + +### Input: + +| Document 1 ID | file://CAUsersIpparker1Desktop101 Complaint.pdf | +|---------------|-------------------------------------------------| +| Description | 01 Complaint | +| Document 2 ID | file://CAUsers1pparker1DesktoplFirst Amended | +| Description | First Amended Complaint | +| Rendering set | Steptoe - Standard | + +### Legend: a + +### insertion + +### Deletion- + +### Moved-from + +### Moved to + +### Style change + +### Format change + +### Moved-deletion- + +### Inserted cell + +### Deleted cell + +### Moved cell + +### Split/Merged cell + +### Padding cell + +### Statistics: + +| | Count | +|----------------|-------| +| Insertions | 333 | +| Deletions | 225 | +| Moved from | 0 | +| Moved to | 0 | +| Style change | 0 | +| Format changed | 16 | +| Total changes | 574 | + +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK + +**COMPLAINT** + +CASE NO.: 1:17-CV-00616 + +JANE DOE 43, + +**J** +**U** +**R** +**Y** + +**T** +**R** +**I** +**A** +**L** + +**D** +**E** +**M** +**A** +**N** +**D** +**E** +**D** + +Plaintiff + +2 + +VS. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, +[REDACTED], LESLEY GROFF, +AND NATALYA [REDACTED], + +Defendants. + +\_\_\_\_\_/ + +FIRST AMENDED COMPLAINT + +claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, , Lesley Groff, and Natalya alleges upon personal knowledge with respect to her own acts and status, and upon personal knowledge, information and belief as to all other matters, as follows: + +1. This cause of action arises under federal statutes and jurisdiction is proper under 28 U.S.C. \*section 1331. + +2. Plaintiff files this Complaint under a pseudonym in order to protect her identity because this Complaint makes allegations of a sensitive sexual nature anEltAe disclosure of Planniff-s-name-publiely-wil4which, in association with her name, would cause further harm to her. + +### 1 + +3. At all times material to the events alleged in this cause of action the Plaintiff was a citizen of South Africa residing in New York, New York. + +4. At all times material to this cause of action Defendant Jeffrey Epstein had multiple residences, including in New York, New York (within the Souther,' District of New York) and the United States Virgin Islands. He is currently a citizen of the United States and claims to be a resident of-New-31-04E-aftd the U.S. Virgin Islands. + +5. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in 1953. + +6. At all times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York and was a citizen of Great Britain and France. + +7. At all times material to this cause of action [REDACTED] was a United States citizen, residing in New York, New York, and, on information and belief, was a citizen of the United States (within the Southern District of New York). + +8. At all times material to this cause of action Lesley Groff was residing a United States citizen, employed by New York based company and regularly conducting business in New York, New York and, on information and belief, was a citizen of the United States (within the Southern District of New York). + +9. At all material times, Natalya [REDACTED] was residing in New York, New York and, on information and belief, was a citizen of the United States. + +9. 10. Including because A substantial part of the acts, events, and omissions giving rise to this cause of action occurred in the Southern District of New York; venue is proper in that District. 28 U.S.C. § section 1391(b)(2) + +2 + +10. 11. At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, [REDACTED], and Lesley Groff, and Natalya [REDACTED] owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional, criminal, fraudulent, or tortious illegal acts against her, including any acts in violation of 18 U.S.C. § 1595, + +11. -1-2,At all times material to this cause of actiona Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is knownwidely recognized as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes and to employ and conspire with a group of numerous others, including each of the named Defendants, to senspice-and-assist in committing those crimes and additional torts as well as to pr-eteet-afiel-conceal bisthe crimes and torts of the Epstein sex trafficking group from being discovered. + +a 4-3:Defendant Epstein displays his enormous wealth, power and influence to his employees; to the victims procured for sexual purposes; and to the public in order to advance and carry out his crimes and torts. At all relevant times, Defendant Epstein owned and continues to own, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats and one or more helicopters. For example, he owned and-ewnsidirectly or indirectly) a Boeing aircraft (of make and model B-727-31H with tail number N9083E) and a Gulfstream aircraft + +### 3 + +(of make and model G-1159B with tail number a909JE). He also owned numerous properties and homes, including a 51,000-square-foot mansion in Manhattan; a \$30 Million, 7,500-acre ranch in New Mexico; a 70-acre private island formerly known as Little St. James in or near St. M, U.S. Virgin Islandsa + +3 in Paris, France; and a mansion in Palm Beach County, Florida. The allegations herein primarily concern the defendant's conduct while at his townhouse in New York; on one or more of his private airplanes; and on his private island in the United States Virgin Islands. Epstein used all of the real and personal property described in this paragraph to facilitate the illegal sex trafficking venture and enterprise described in this Complaint and enterprise, + +U. 4-47Defendant Epstein has a compulsive sexual preference for young females as young as 13 and as -':old"": as 25. Through information and belief Defendant hed-sex-viith-yeung-females-viFtualtyriateln engages in sexual acts with this age range every day and through the employment of and conspiracy with the other Defendant; a sex trafficking sehemeventure and enterprise designed to fulfill his sexual desires: and conceal the operation of the venture and enterprise and conduct of its participants. As part of the venture and enterprise, Epstein also provided young females for sexual purposes to his friends in order to secure social, business, and other contacts as well as other things of value. + +14, 4-5:Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise. She herself recruited young, including underage, females; oversaw and trained other recruiters on how best to recruit girls for sex; developed and executed schemes designed to recruit young females; and ensured that all participants of the Defendants' sex trafficking scheme + +acted in certain specific ways in order to advance the purposes of the scheme-and eeneeal-it, including nrovidin¢ voung females to Enstein a daily basis, and concealing these activities from law enforcement. + +IS 4-6:Defendant recruited young females for Epstein for sexual purposes, brought gifts to females in order to entice those females to commit sex acts with Epstein and to assist in concealing the illegal sexual conduct of the venture and enterprise, and maintained Epstein's sex schedule in order to ensure that he was not without the-semeal-favers-ayoung females for any extended period of time. Defendant also handled travel arrangements for the-various females being exploited for sexual purposes. + +4 Defendant was an integral part of the sex trafficking venture and enterprise and reported directly up the enterprise's line of authority to Defendan4Defendants Maxwell and Epstein. + +16. -I-7,Defendant Epstein employed many recruiters of young females. The nature of the Defendants' sex trafficking sehenieventure and enterprise enabled victims themselves, suell-as-Defendant-Nilttlyshevi to elevate their status to that of a paid recruiter of other victims. + +Recruiters were taught by Defendants Epstein-and, Maxwell to inform targeted victims that Epstein possessed extraordinary wealth, power, resources and influence; that he was a philanthropist who would help female victims advance their + +careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact, however, these representations were fraudulent. The vest—majecity—ef girlsyoung females were actually required to perform intimate sexual acts at the Defendants' direction and the Defendants did not help ernor intend to help advance the victims' careers. Victims were also paid to bring Epstein other young females for sex and were told by Defendants Epstein, Maxwell, and that those young females who brought other females would further benefit from bringing other girls, + +17. 1-grDefendant Groff was an integral part of the illegal venture and enterprise,Groff coordinated schedules between Defendant Epstein and the various young females used for sex; made travel arrangements for the girlsyoung females; tended to theirthe living needsand-eemmunteated-w+th-dieni-wher-der--te-nianita their of those females; communicated and coordinated with Defendants Epstein, Maxwell and to assist in facilitating young females being available in locations where the other Defendants were traveling; and she carried messages to the young females from the other Defendants including false representations in order to maintain the young females' compliance with the rules of behaviorsexual compliance imposed upon-thee-by this structured sex-trafficking group. Groff was aware of + +the enteff)riseactivities of the venture and enterprise, including the fraudulent representations and other coercion that was being applied to secure the females' compliance with demands of sex. + +a -1-97The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled EpsteitiZs compulsive need for sex with young females by preying on their + +s personal, psychological, financial, and related vulnerabilities. The Defendants' tactics included promising the victims money, shelter, transportation, gifts, employment, admission into educational institutions, educational tuition, ➢rotection, and other things of value in exchange for sex. Defendants also took possession of the victims' passports to coerce compliance with their demands, Defendants also trafficked young females to Epstein's friends and acquaintances in order to secure financial and other benefits as well as social, educational, and business connections, + +24Defendants' sex trafficking venture and enterprise operated in a hierarchal structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top-awl underlings-below Defendants Epstein and Maxwell operated the sex trafficking scheme dating back to at least the mid-nineties, and over the years perfected their roles and the roles of others, both in terms of the ability to increase the volume of young females recruited for sex and in insulating the enterprise from criminal investigation or prosecution. Defendant Groff conspired with Defendant Epstein and Maxwell + +### 2 + +since at least 2002 and continues to work for Defendant Epstein today, Defendant began working with the Epstein-run sex trafficking venture and enterprise as early as 2001 and her role in their venture and enterprise was well-defined and primarily consisted of conspiring in the commission and cover-up of sex crimes. Underlings included the other named Defendants as well as unnamed co- conspirators such as various housekeepers and butlers; an airplane pilot; and various employees, assistants and associates. Wittingly and unwittingly, such underlings performed their respective roles with the purpose and effect of insuring that the enterprise supplied young females to Defendant Epstein and others for sexual purposes. At all times materials to this complaint, the venture and enterprise was a group of two or more individuals associated in fact and deed. + +20. 2-1-Defendants Epstein and Maxwell, with help from assistants, associates and underlings, recruited and procured hundreds of girls over the decades of the operation of their scheme. Such recruitment and procurement included fraud, coercion, threats, intimidation, fear, the threat of coercion, and a combination of these and similar tactics. Following the Defendants' recruitment and procurement of the young females to join Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent + +6 promises, coercion, and threats of coercion in order to entice youngand coerce at females into sex and, once sexual activities ensued, to cause them to remain in the enterprise. The Defendants also transported females in + +interstate and foreign commerce and in ways that affected interstate and foreign commerce. The sex acts were commercial in nature, because the Defendants promised to provide financial and other compensation to the females in + +21. 22. Defendants specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females to join the Defendants' enterprise provide sex for Epstein. + +22. 23. Additionally, Defendants always made clear to every young female that they were wealthy, well-connected and could either help or hurt the females depending on their degree of cooperation. In fact, Defendants Epstein and Maxwell have been known to threaten young females with physical harm. It is unknown exactly how long Defendant Epstein and Maxwell's aforementioned the Defendants' criminal and illegal venture and enterprise operated, although it was at least continuously and actively in operation from the mid-1990's through and including the calendar year 2007. + +23. 24. Defendant Epstein has continued the venture and enterprise and enspiracy up to the present time in some form or another and with additional co-conspirators and participants. + +24. 25. In 2005, Defendant Epstein and numerous co-conspirators within the venture and enterprise were the subjects of a Palm Beach, Florida Police Department criminal investigation which revealed that Defendant Epstein had engaged in sexual activities with dozens of young teenage school children. Each child identified in that particular investigation was lured into Defendant Epstein's Palm + +Beach mansion with a promise that she would receive money for providing him with a body massage, although once there, each childyoung female was made to engage in a sex actsexual acts in order to receive the promised compensation. + +7 Several were also made to engage in sex with another of Defendant Epstein's female semeal-traveliateenipatlienstraveling sex companions who Epstein referred to as his lesbian sex slave and bragged about purchasing her from her family when she herself was underage. + +a67In 2006, the Palm Beach Police Department investigation was turned over to the FBI and the United States Attorney's Office for the Southern District of Florida. The United States Attorney's Office investigated Defendant Epstein and his co-conspirators for their violations of numerous federal statutes, including 18 U.S.C. \*Section 1591, one of the statutory bases for this complaint. + +26. 2-7,The United States Attorney!'s investigation continued from 2006 through September 2007, at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office deferring federal prosecution of Defendant Epstein and his numerous co-conspirators, including Defendants and Groff, each named by the Federal Government as co- conspirators, for identified federal sex crimes against more than 30 minors. + +22, 2&From late 2006 through September 2007, Epstein's team of lawyers negotiated with the federal government in an effort to avoid the-filing-of-then fiftythree-page draftfederal felony indictment afrom being filed against Epstein. During these + +negotiations, Defendant Epstein decamped from Palm Beach to New York and the U.S. Virgin Islands in order to convey an image to prosecutors that he and his coconspirators had stopped committing sex crimes. + +28. 297Remarkably, however—as this case will highlight—Defendant Epstein and his co-Defendants, including the other defendants named herein, did + +S not abandon their sex trafficking venture and enterprise even while they were under state and federal investigation for crimes committed in violation of 18 U.S.C. \*section 1591, among other laws, and even as Defendants and their attorneys were busy arguing Epstein•) innocence and publicly defaming his victims as liars. Rather, Defendants merely changed their stylelocation. Instead of targeting local Palm Beach Florida high-school girls, the Defendants transported young females from other places in the U.S. (including the Southern District of New York) and abroad and brought them to Defendant Epstein!'s mansion in New York City and his private island in the Virgin Islands. + +a 304n June of 2008, Epstein pleaded guilty to Florida state felony sex offenses for procuring a minor for prostitution and soliciting prostitution by minors\_and registered as a Sex Offender for Life. + +30. 3-)-Defendants Epstein and Maxwell developed and implemented a sophisticated system designed to insulate them from criminal and civil liability by protecting them from potential testimony of knowledgeable subordinates. + +Defendants and Groff adapted to the system and also carried it out for years in exchange for significant pay, benefits, and protection from agreements eever-ing-eivil-awribarring disclosure of criminal activity; maintaining records of underage females who were abused by Epstein; requiring subordinates and victims to refrain from speaking with law enforcement officials; requiring them to notify Defendant Epstein's lawyers in the event they (subordinates and victims) were contacted by law enforcement officials; requiring them to accept the representation of attorneys paid for by Defendant Epstein; requiring them to invoke the Fifth Amendment in + +9 response to questions they might be asked by investigators and prosecutors; requiring them to invoke the Fifth Amendment in order to refuse to turn over incriminating and non-incriminating evidence to law enforcement officers; requiring them to destroy evidence or refuse to reveal knowledge of destroyed evidence; and requiring them generally to refuse all cooperation with law enforcement officials or investigations. + +32,In 2005, Defendant Epstein and other co-conspirators, aware that law enforcement officials were preparing imminently to execute a search warrant ecru his home, removed computer systems that logged information about Epstein and his co-conspirators' illegal and criminal conduct; the identities of witnesses; nude + +### 12 + +photographs of young females; scheduling books; message pads; tangible items such as vibrators and toys; and other incriminating matter. + +32. The sex recruiting and trafficking venture and enterprise designed to procure young females for sexual purposes and to conceal those activities was developed andfine-tuned over time, and each of the named Defendants had a well-defined role and improved in his/her role over time. with practice and + +Defendant had years of experience perfecting methods of coercion, understanding Epstein's requirements, and becoming more loyal to the continuance and survival of the venture and enterprise. All of the Defendant's knew about the activities of the venture and enterprise and worked in concert for the goals of the venture and knowingly benefitted, financially and by receiving things of value, from their participation in the venture and enterprise. + +33. A typical way the Defendants procured young females for sex with Defendant Epstein was to make false promises of a modeling opportunity, offer a better life, offer payment for a formal education, or offer other money or consideration. + +34. 33. Commencing Beginning in approximately October 2006 and continuing through April 2007, Defendants recruited Plaintiff into their sexual enterprise by fraudulently + +13 + +promising to use their connections and resources to secure her admission to an institution of higher education at the expense of Defendant Epstein. + +35. 34. Defendant [REDACTED] was working as One of the enterprise's many recruiters of, Natalya [REDACTED], was working to recruit young females for Epstein for sex when she approached and recruited Plaintiff. + +44 + +3-57Defecidant. informed Plaintiff that she would introduce Plaintiff to Defendant Epstein, whom she described as a wealthy philanthropist who regularly used his wealth, influence and connections to help financially poor females like Plaintiff achieve their personal and professional goals and aspirations. + +3-64Defendant- reported to her superiors, Defendants =, Groff and Maxwell, and was paid for her recruitment of young females, including-the memitment-ef Plaintiff + +37.Defendant introduced Plaintiff to Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology; (known as "F.I.T." ;1 in New York City; or into a similar institute of higher learning offering a curriculum of fashion industry training. Between October 2006 and May 2007, Defendants Maxwell, = and Groff each also confirmed and reiterated this promise to Plaintiff many times-Leach telling Plaintiff that Epstein would use his wealth and connections to advance Plaintiffs education. More specifically, each of the Defendants last verified this information that Epstein was using his connections to ensure Plaintiff was admitted + +14 + +into F.I.T. in exchange for Plaintiff's continued sexual cooperation with Epstein in March or April of 2007, + +Epstein with body massages in order to reap the benefits of his and Maxwell's connections. + +40. All Defendants, including Maxwell, Epstein, Groff and a, knew that Plaintiff was actually being recruited for sexual purposes, and each knowingly and deliberately made false representations to ensure that Plaintiff would cooperate in fulfilling Ea sexual desires. These false and fraudulent representations included Defendants' telling Plaintiff that Epstein would use his connections to have her admitted into F.I.T. or a similar institute, college, university or school of higher learning and provide her with employment opportunities. Plaintiff reasonably relied on these representations and had a credible basis for such reliance, including the credible representations of Epstein and the other Defendants that they possessed extensive political, business, financial, social, and educational influence and connections. Epstein and the other Defendants represented to Plaintiff in manners that were persuasive, credible, and reasonable to Plaintiff, as they would have been to any other person similarly situated, that they had the political, business, financial, social, educational, and other influence and + +connections sufficient to arrange for and insure her admission into FIT, or a similar school of higher learning\_ + +to advance her education and career, they also had the ability to make sure that shePlaintiff would not obtain ne-formal education or modeling agency contracts if she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein, Grote and Maxwell. + +42. 3-9TPlaintiff reasonably believed that her compliance with Defendants' demands was crucial to her physical, psychological, financial, and reputational well-being and survival. + +43. 40:Defendant Maxwell instructed Plaintiff how to massage Epstein using the techniques that heMaxwell knew that Epstein preferred. During Plaintiff's first massage, Defendant Epstein converted it into a sexual act and made it known to Plaintiff that further sex would be required in order for her to obtain the assistance he promised her and to avoid Defendants' threatened retaliation against her if Plaintiff did not perform as demanded. + +44,Defendents—Maxwell and Epstein informed Plaintiff that other young females in Defendant-Epstein's company were there net-enly-te-previde-massages; but-also pzo perform sexual acts:for Epstein and his friends. Groff ausa helped to secure the presence of the other young\_ females for these nurooses. + +11 + +4&Plaintiff was instructed dozens of times to provide body massages to Defendant Epstein, both at his townhouse in New York and on his private island in the U.S. Virgin Islands. Each time she was so instructed she was also required to + +perform a sexual act with **Defendant** Epstein. The Defendants all participated in arranging for Plaintiff to be transported—**Plaintiff** in interstate and foreign commerce, and affecting interstate and foreign commerce, for these sexual purposes. **The Defendants Epstein, Maxwell, and [REDACTED] used possession and control of Plaintiff's passport to induce and coerce Plaintiff into performing sexual acts with Epstein and others.** + +46. **43.** During many sexual encounters, Defendant Epstein gave Plaintiff no option, opportunity, or choice not to participate in the prescribed sexual acts. + +12 + +47. **44.** Defendant Maxwell frequently controlled the assignment, or “rotation,” of Plaintiff and the other young females concerning the time, place and manner of the sex acts they were told to provide to Defendant Epstein. **Defendant Maxwell also gave instructions on how to perform certain sexual techniques on Epstein.** Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with other females. + +48. **45.** Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaintiff with serious harm, as well as serious + +17 + +sexual activity demanded by Defendants. + +49, 4670n one occasion, after suffering verbal abuse and threats by Defendants Epstein, Maxwell, and = Plaintiff attempted to escape from Defendant Epstein's private island. A search party led by DecendantDefendants Epstein and Maxwell located her and physically returned her to the main house on the island. Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind. Defendants further used possession and control of Plaintiff's passport, without lawful consent or authority, to restrict Plaintiff's liberty and thereby force her to provide sex to Epstein, + +50. 47Defendant Epstein's wealth, influence, power and connections were used by Defendants Maxwell,and Groff, both as an inducement to provide sex (in exchange for promises of support to Plaintiff); and as a means of threatening punishment (sheuklin the event Plaintiff refuserefused to comply with Defendants' instructions to provide sex to Epstein and others). + +a 4871n addition to Plaintiff's being trafficked on Defendant-Epsteints private platie&glane, Defendants Groff, Maxwell and =, with the knowledge of and instruction by Defendant Epstein, arranged Plaintiffs living accommodations, private car travel, + +and commercial air travel on numerous occasions for the purpose of causing Plaintiff to commit commercial sex acts. These Defendants worked in concert with one another to recruit, procure, entice, and otherwise cause many other females to engage in commercial sex acts, through their use of threats, fraud, and coercion. Among these means of coercion were the Defendant's possession and control of the females' passports and other immigration documents. This coercion was most salient, and especially effective, while the females, including Plaintiff, were on Epstein's island. + +52, 49,In furtherance of their venture and enterprise, Defendants provided living quarters for Plaintiff at 301 East 66th Street, New York, in the Southern District of New York; a car service for Plaintiff to use as needed; a cell phone; and other valuable consideration in order to maintain Plaintiffs sexual compliance. Each of the Defendants told Plaintiff she would obtain the benefits of a place to live and phone and transportation as long as she remained compliant with their demands that she service Epstein sexually. Each of the Defendants also told her that if she was not compliant, these benefits would be taken from Plaintiff, + +51. 50:The relationship between Plaintiff and Defendants Epstein and Maxwell was defined and characterized by Defendant Epstein's and Defendant Maxwell's frequent and persistent fraudulent representations that they would provide Plaintiff with a formal education and career advancement if she provided sex to Defendant + +Epstein and others in the times, places and manners demanded by Defendants. Defendants Groff and each also told Plaintiff that Defendant Epstein would advance Plaintiff's education and career in order to coerce Plaintiff into sex. Defendant told Plaintiff that Epstein had done the same for her career. As a result of these and other representations by Defendants, Plaintiff reasonably relied on thosethese representations. In fact, however, thesethese representations were knowingly false, were not acted upon by Defendants, and were made by Defendants Epstein, Groff. and Maxwell solely for the purpose of maintaining + +44 Plaintiffs financial dependence on, emotional vulnerability to, and sexual compliance with DcfcndantsDefendant Epstein-and-Maxwell-and-theiCs demands. The other Defendants intentionally repeated thosethese representations and intentionally ottecoi3tedmade statements desi' n • a to convince Plaintiff that the representations were true and could be relied upon. These representations and statements were made to Plaintiff in furtherance of the sex trafficking venture and enterprise for which they were each employed, 54. As part of the venture and enterprise, Defendants Epstein, Maxwell, and took possession of Plaintiff's passport when she was being trafficked by them, including when she travelled to Epstein's island in the U.S. Virgin Islands. The Defendants took possession of Plaintiff's passport in the course of sexually trafficking Plaintiff and with the intent to violate laws against sex trafficking., including 18 U.S.C. 1591 et. seq. The Defendants used their control of Plaintiff's + +passport in order to coerce compliance with their demands, including their demands that Plaintiff have sex with Epstein and others, + +55, 54,In January 2007, as part of their illegal venture and enterprise, Defendants sent Plaintiff from the-gaite&StatesNew York City, in the Southern District of New York, to South Africa-in-part to recruit, for a promised fee, one or more aspiring female models supposedly for Defendant-Epstein-te-use-as-awaIleged persehal-assistah#Epstein to use as a personal assistant. The Defendants did not care whether the prospective female was qualified to work as a personal assistant because each knew that the female recruit would he immediately • vulnerable nosnion• • intiff and the dozens of other victims of the sex trafficking enterprise) and mould he induced and coerced into being used for sex through fraudulent representations and other means. + +56, Defendants Epstein and Maxwell continuously and frequently demanded that Plaintiff fulfill this task of bringing another female back to the United States and Defendants' control as a condition of herPlaintiff's receiving the education, career and related benefits promised by Defendants Epstein and Maxwell. Based upon Plaintiff's experience with Defendants, however, she did-net-beheve ' knew that the requested female model would not be placed in a legitimate position of employment with Defendant Epstein but would, instead, be forced into sexual servitude. Plaintiff also knew that this objective was the only purpose of Defendants= Groff, Maxwell and Epstein's demand for Plaintiffs recruitment efforts. As a result, Plaintiff deliberately refused to perform the recruitment assignment. + +57. 42. As part of their ongoing scheme, Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts with Epstein and others. While Plaintiff was in South Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be permitted to return to the United States to receive her promised education unless she underwent a diet and lowered her body weight from 57 kilograms + +4-5 (approximately 125 pounds) to 52 kilograms (approximately 114 pounds). Epstein and Maxwell promised Plaintiff that, if she complied, she would receive her promised education. Defendant Groff monitored Plaintiffs progress in losing weight and continued to communicate with Plaintiff about Plaintiffs application to be admitted into F.I.T. as part of the Defendants' ruse to coerce Plaintiff to return to the United States for sex. Defendant Groff was aware of the coercion Epstein and Maxwell were applying to Plaintiff and acted to help further that coercion. Believing she had no practical choice in the matter, Plaintiff attempted to comply with the order but, given her physical height and body structure and her already existing-lew body weight, the diet imposed upon her placed her in serious physical jeopardy, including kidney malfunction and extreme emotional and psychological distress. + +22 + +58, 5-3,As Dart of their scheme. Defendants Epstein and Maxwell called Plaintiff) parents in South Africa to tell them that Defewlantsnefendant Epstein would take good care of Plaintiff when she returned to the United States, and that theyDefendants Maxwell and Epstein would use their connections and influence F.I.T. or another well-regarded fashion school or school of higher learning. + +59. As part of their scheme, Epstein and Groff told Plaintiff that she should fill out an application for admission to F.I.T., and supporting essay, and send it to Epstein for his review. Pursuant to these instructions, Plaintiff completed an application, and supporting essay, and sent it to Epstein. As part of his scheme, Epstein told Plaintiff that he had reviewed these materials. His statements were intended to convince Plaintiff, and had the effect of convincing plaintiff (as they would have convinced any reasonable person), that her admission to F.I.T. was a "done deal" if she would comply with his instructions. Groff also made the same representations to plaintiff on Epstein's behalf. Plaintiff reasonably relied on these representations by Epstein and Groff, + +60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had contacts at F.I.T. and at modeling agencies who could ensure her admission to F.I.T. and advance Plaintiff's career. As part of their scheme, Epstein and Maxwell told Plaintiff about Epstein's vast wealth and specifically identified him as a billionaire. Epstein and Maxwell told Plaintiff that they had extensive + +23 + +contacts, in addition to those identified above, throughout New York City and elsewhere. + +fat 34-In February of 2007, in reliance on promises made by the Defendants, Plaintiff returned to New York City, in the Southern District of New York, and + +Defendants Maxwell. rmff and Epstein each fraudulently promised herPlaintiff again that her sexual compliance would be rewarded with admission to F.I.T. or a comparable college, a promise which they knew-te-be-falseeach knew to be false. In fact all four Defendants had for years worked solely to recruit females for sex and to conceal the operation of the sex scheme, and in 2007 were under Federal investigation for their conspiracy to engage in Federal sexual crimes like thosesommitted againstilaintiff. Plaintiff knew that if she did not comply, Defendants Maxwell and Epstein would use their power, influence and connections in order to ensure that Plaintiff was unable to gain admission to F.I.T. or a comparable school, and that they would destroy her career, lust as they had destroyed the careers of others who had failed to comply with their demands. + +62, 55:Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiff) continued compliance with Epstein!) + +44 sexual demands; however, they failed and refused to perform their promises to help Plaintiff be admitted to F.I.T. or another school, or to provide financial support for + +L4 + +college admission or on-going education, false promises they repeatedly made in order to coerce her into commercial sex acts. + +II 5.6:Defendants Epstein and MaxwcIlia! sexual demands on Plaintiff continued while she was in New York OEether-geegFaph+eCity, in the Southern District of New York, or in other locations in close proximity to the Defendants. + +In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, each of the Defendants continued to pressure her to lose excessive amounts of body weight and offered her no opportunity to decline or resist their instructions. + +SaIn May, 2007, Plaintiff left the United States and did not return. Between returning from South Africa in February 2007 and leaving in May 2007, Defendants =, Groff, and Maxwell each continued to repeatedly make false representations to Plaintiff, including false and fraudulent representations that she would be admitted to F.I.T. if she continued to engage in sex with Epstein. Defendant Epstein continued to make similar false and fraudulent promises in order to have sex with Plaintiff, + +65. In and after May 2007, Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females, D f ndant' cover- up included efforts to intimidate witnesses who might provide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done. + +66. 5-8,Unknown to Plaintiff, Defendants' representations and promises to Plainti were all false and fraudulent. Their-threats-were-eensfdered-byPlaintiff reasonably relied on the representations and promises of the Defendants. Plaintiff also considered the Defendants' threats against the current and future well-being and safety of Plaintiff to be real and credible. All such representations, promises, and threats were made solely for the purpose of coercing and otherwise + +inducing Plaintiff into prolonged sexual compliance. Defendants knowingly benefitted financially and received things of value as a result of their coercing and inducing Plaintiff into sexual compliance and otherwise participating in their illegal venture and enterprise. + +**COUNT I CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO +18 U.S.C. +§ 1595** + +67. 59. Plaintiff adopts and realleges paragraphs 1 through 5866 above. + +17 + +68. 60. Defendants individually and together, within the special maritime and territorial jurisdiction of the United States, in interstate and foreign commerce, and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, maintained, patronized, solicited, threatened, forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by Defendants were undertaken with knowledge and/or reckless disregard of the fact that their threats of force, fraud, coercion, and combinations of such means would + +26 + +be used, and were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In so doing, Defendants violated 18 U.S.C. §§1591-through-1594 and §1591, + +passport and associated immigration documents, in the course of violating 18 U.S.C. § 1591, and with the intent of violating 18 U.S.C. § 1591, and to prevent, restrict, attempt to restrict, without lawful authority, Plaintiff's liberty to move or travel, in order to maintain the sexual services of Plaintiff, while Plaintiff was a victim of a severe form of sex trafficking, as defined in section 103 of the Trafficking Victims Protection Act of 2000, enacted in 22 U.S.C. § 7102. In so doing, Defendants violated 18 U.S.C. § 1592. These Defendants also obstructed, and attempted to obstruct and to interfere with the enforcement of 18 U.S.C. § 1592. + +70. Additionally, Defendants knowing benefitted, financially and by receiving things of value, from participating in a venture (the Epstein sex traffickingventure enterprise)which had n ed in acts in violation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in such violations. In so doing, Defendants violated 18 U.S.C. § 1593A. + +71. Additionally, Defendants attempted to violate 18 U.S.C. § 1591. In so doing, Defendants violated 18 U.S.C. § 1594(a), + +2/ + +72. Additionally, Defendants conspired with each other, and with other persons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants violated 18 U.S.C. § 1594(b). + +Defendants violated 18 U.S.C. § 1594(c). + +74. By virtue of their violations of 18 U.S.C. §§ 1591, 1592, 1593A, and 1594, +Defendants are subject to civil causes of action under 18 U.S.C. § +1595.61. Defendants additionally profited from the sex trafficking of Plaintiff; +obstructed investigations of the violations; attempted and conspired to violate, and +succeeded in violating, 18 U.S.C. §§ 1591 through 1595, by the commission of the +torts and crimes described in this complaint 1595 by Plaintiff, who is a victim of +their violations. + +75. 62. Certain property of Defendant Epstein's was essential to the commission of +the federal crimes and torts described herein, including the use of multiple private +aircraft including a Boeing aircraft (of make and model B-727- 31H with tail number +N908JE) and a Gulfstream aircraft (of make and model G- 1159B with tail number +N909JE). Such aircraft, along with other of Defendants' + +48 property, were used as means and instruments of Defendants' tortious and +criminal offenses and, as such, are subject to forfeiture. + +76. 63. Additionally, Defendant Epstein's New York mansion, located at 9 East +71st Street, New York, New York, in the Southern District of New York, and his +private island located in the United States Virgin Islands, were used as means and + +71, 647As a direct and proximate result of Defendants' commission of the aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 ot.scq.1591, 1592, 1593A, and 1594, and the associated civil remedies provided in § 1595, Plaintiff has in the past suffered and will continue to suffer injury and pain; emotional distress; psychological and psyebi—ariepsychiatric trauma; mental anguish; humiliation; confusion; embarrassment; loss of self- esteem; loss of dignity; loss of enjoyment of life; invasion of privacy; and other damages associated with Defendants' actions. Plaintiff will incur further medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to these losses, Plaintiff has incurred attorneys' fees and will be required do so in the future. + +WHEREFORE, Plaintiff demands judgment against Defendants for compensatory and general damages, attomey!'s fees, punitive damages and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury. + +Dated: Jaftwily-26r20-1-7June 5, 2017, + +JAFFE. WEISSING. FISTOS, LEHRMAN, P.I,. + +425 N. Andrews Ave., Suite + +2 Fort Lauderdale, FL + +73301(9541-524-282Q + +Fax: (954)-524-2822 Email: + +bradpathtojustice.com + +PRO HAC Vi(t; + +BOIES, SCHILLER & FLEXNER + +LLPBy: hl David Boies\_ David + +Beies- + +Boies Schiller & Flexner LLP + +333 Main Street + +Armonk, New--Yefik]!ft 10504-T + +(9\_19) 749-8200 + +Ear (914) 749-82-% + +Edbeies@bsflireee + +Alex-Beies-Beies-Sehillef-8e-Fiextær-~ + +10022—T÷(212)-446 2300 E: 8300 Email: + +dboies@bsfllp.com + +Sigrid McCa./ + +Meredith + +Boies Schiller & Flexner LLP 401 East + +Las Olas Blvd., Ste. 1200 Fort + +Lauderdale, Florida 33301 (954) + +356-0011 EENi: + +smccawley@bsfllp.com + +titsmschultz@bsfllp.com PRO + +HAC VICE-le-be-filed + +Paul C O~11 + +S.J. Quinney College of Law at the University of Utah + +383 S. University Street + +Salt Lake City, UT + +84112-0730 (801)-585-5202 + +Fax: (801»585-2750 Email: + +rassellp(klaw.utah.edue + +PRO HAC VICE + +20 + +\* This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation + +30 + +CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on the 5th day of June, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF, + +STEPTOE & [REDACTED], LLP Michael C. [REDACTED], Justin Y.K. [REDACTED] +mmiller@steptoe.com, cjenkins@steptoe.com, pparker@steptoe.com +jchu@steptoe.com, cjenkins@steptoe.com, pparker@steptoe.com, psafirstein@steptoe.com + +Attorneys for Defendants +Jeffrey Epstein & Lesley Groff + +ALSTON & BIRD, LLP John E. Stephenson, Jr. +Alexander S. Lorenzo +alexander.lorenzo@alston.com, autodocket-nyc@alston.com, +managingclerksoffice-nyc@alston.com, +john.stephenson@alston.com + +Attorneys for Defendant [REDACTED] + +By: /s/ [REDACTED], J. [REDACTED], Jaffe, +Weissing, [REDACTED], Fistos & Lehrman, P.L. +425 North Andrews Ave., Ste. 2 Fort +Lauderdale, Florida 33301 T: (954) +524-2820 +E:-brad@pathtojustice.com +Pro Hac Vice to be filed + +J. Stanley Pottinger +J. 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I am an attorney at the law finn of Steptoe & LLP, counsel for Defendants Jeffrey Epstein and Lesley Groff ("Defendants"). I submit this declaration in support of Defendants' motions to dismiss, or, in the alternative, to strike a portion of the First Amended Complaint, and to require Plaintiff to proceed in her own name. + +2. Attached hereto as exhibits are true and correct copies of the following: + +Exhibit A The First Amended Complaint filed in this action. + +Exhibit B The Complaint filed in this action. + +Exhibit C A letter I wrote to Plaintiff's counsel of May 15, 2017. + +Exhibit D A letter Plaintiff wrote to the New York Times and published on November 16, 2017. + +Exhibit E A blackline comparison of the Complaint. + +Dated: November 21, 2017 + +int and the First mended Michael C. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819871/EFTA02819871.metadata.json b/marker2/court-jane-doe-43/EFTA02819871/EFTA02819871.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3fe001e9a231ad760803d649af87368fdd5420fc --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819871/EFTA02819871.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819871.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1059, + "elapsed_seconds": 0.89, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 76.14 + ], + [ + 292.4401550292969, + 76.14 + ], + [ + 292.4401550292969, + 103.863037109375 + ], + [ + 68.544, + 103.863037109375 + ] + ] + }, + { + "title": "DECLARATION OF MICHAEL C", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 184.212, + 307.79999999999995 + ], + [ + 373.32, + 307.79999999999995 + ], + [ + 373.32, + 322.4830627441406 + ], + [ + 184.212, + 322.4830627441406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 29 + ], + [ + "Text", + 16 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819871" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819872/EFTA02819872.md b/marker2/court-jane-doe-43/EFTA02819872/EFTA02819872.md new file mode 100644 index 0000000000000000000000000000000000000000..59d9b64aa30b90635f24d1c0a31387afba28b08d --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819872/EFTA02819872.md @@ -0,0 +1,61 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT NEW YORK + +x + +JANE DOE 43, + +17-cv-00616-.KiK + +Plaintiff, + +vs. + +JEFFREY EPSTEIN GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +Defendant. + +-x + +## DEFENDANT NOTICE OF MOTION TO DISMISS + +PLEASE TAKE NOTICE that upon the annexed Memorandum of Law, and the accompanying Declaration of John E. 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GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +Defendant. + +x + +## MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT MOTION TO DISMISS + +John E. Stephenson, Jr. (admitted pro hac vice) Jonathan D. Parente (pro hac vice forthcoming) ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, Georgia 30309 (404) 881-7000 john.stephenson@alston.com jonathan.parente@alston.com Alexander S. Lorenzo ALSTON & BIRD LLP 90 Park Avenue New York, New York 10016 (212) 210-9400 alexander.lorenzo@alston.com + +## TABLE OF CONTENTS + +| INTRODUCTION | 1 | +|----------------------------------------------------------------|------------------------------------------------------------------| +| BACKGROUND | 1 | +| APPLICABLE LAW | 4 | +| ARGUMENT | 5 | +| I. Plaintiff has failed to state a claim that | violated Section 1591. 5 | +| A. | The Act does not cover the type of consenting-adult relationship | +| alleged. | 6 | +| B. | The Amended Complaint fails to meet the Twomblyllqbal pleading | +| standards. | 7 | +| C. Plaintiff cannot plausibly allege that | had the requisite | +| knowledge under Section 1591 | 10 | +| II. The Amended Complaint does not state a Section 1592 claim. | 14 | +| III. The claims against | are all time-barred. 15 | +| IV. This Court is not a proper forum for Plaintiff's action. | I 7 | +| CONCLUSION | 17 | + +#### TABLE OF AUTHORITIES + +| CASES Abarca v. Little, | Page(s) | +|-------------------------------------------------------------------------------|---------| +| 54 F.Supp.3d 1064 (D. Minn. 2014) Am. Sales Co. v. AstraZeneca AB, | 16, 17 | +| No. 10 Civ. 6062, 2011 WL 1465786 (S.D.N.Y. Apr. 14, 2011) Ashcroft v. lqbal, | 8 | +| 556 U.S. 662 (2009) Atuahene v. City of Hartford, | passim | +| 10 F. App'x 33 (2d Cir. 2001) Bell Atl. Corp. v. Twombly, | 9 | +| 550 U.S. 544 (2007) See Allison v. Round Table Inv. Mgmt. Co., LP, | 4, 13 | +| 447 F. App'x 274 (2d Cir. 2012) Elias v. City of New York, | 1 | +| No. 10-CV-5495, 2010 WL 5475809 (E.D.N.Y. Dec. 30, 2010) Greenberg v. Christ, | 9 | +| 198 F.Supp.2d 578 (S.D.N.Y. 2002) Harris v. Mills, | 12 | +| 572 F.3d 66 (2d Cir. 2009) Kelsey v. Goldstar Estate Buyers Corp., | 5 | +| No. 3:13-CV-00354-HU, 2014 WL 1155253 (D. Or. Mar. 21, 2014) | 8 | +| No. 10-CV-4124, 2013 WL 6816174 (W.D. Ark. Dec. 24, 2013) | 14 | +| Lentell v. Merrill & Co., | | +| 396 F.3d 161 (2d Cir. 2005) Lunkes v. Yannai, | 4 | +| 882 F. Supp. 2d 545 (S.D.N.Y. 2012) v. City of New York, | 7 | +| No. 07 Civ. 7834, 2008 WL 1826483 (S.D.N.Y. Apr. 23, 2008) | 9 | + +0 & G Carriers, Inc. v. 799 F. Supp. 1528 (S.D.N.Y. 1992) 8 Oluch v. Orina, 101 F.Supp.3d 325 (S.D.N.Y. 2015) 16. 17 Rosner v. Bank of China, No. 06 CV 13562, 2008 WL 5416380 (S.D.N.Y. Dec. 18, 2008) 10 San Leandro Emergency Med. Grp. v. Philip Morris Co., 75 F.3d 801 (2d Cir. 1996) 10 St. Louis v. Perlitz, No. 3:13-CV-1132, 2016 WL 1408076 (D. Conn. Apr. 8, 2016) 5 United States v. Corley, No. 14-1709, 2017 WL 549021 (2d Cir. Feb. 9, 2017) 7 United States v. 621 F.3d 101 (2d Cir. 2010) 7 United States v. Todd, 627 F.3d 329 (9th Cir. 2010) 14 Velez v. M, 693 F.3d 308 (2d Cir. 2012) 15 Weinstein Co. v. Smokewood Entm't Grp., 664 F. Supp. 2d 332 (S.D.N.Y. 2009) 8 ex rel. U.S. v. Applied Research Assocs., Inc., 328 F. App'x 744 (2d Cir. 2009) 11 + +# RULES + +Fed. R. Civ. P. 8 8 Fed. R. Civ. P. 9(b) 11 Fed. R. Civ. P. 12(b)(6) 4 Fed. R. Civ. P. 12(f) 3 + +## STATUTES + +Victims of Trafficking and Violence Protection Act of 2000, 18 U.S.C. § 1591, et seq passim 18 U.S.C. § 1591 passim + +| 18 U.S.C. § 1592..... | 14 | +|-------------------------|-------| +| 18 U.S.C. § 1593A ..... | 15 | +| 18 U.S.C. § 1594..... | 14 | +| 18 U.S.C. § 1595..... | 5, 16 | + +## OTHER AUTHORITIES + +#### INTRODUCTION + +The Amended Complaint represents Plaintiffs second (unsuccessful) attempt to state a claim that Jeffrey Epstein's personal assistant—violated federal sex-trafficking laws. As contemplated by the Court's directives, sent a pre-motion letter that identified and discussed the initial Complaint's fatal flaws. Plaintiff responded with her Amended Complaint, presumably in an effort to cure its shortcomings. But the Amended Complaint remains legally deficient—failing for all the same reasons as the initial Complaint. + +Among other problems, the Amended Complaint's allegations (i) stem from a consensual, adult relationship that is beyond the scope of the Victims of Trafficking and Violence Protection Act, 18 U.S.C. § 1591, et seq., (ii) are insufficient to state a claim against personally because, among other defects, they fail to plausibly allege that had the requisite actual knowledge for a statutory violation, (iii) highlight that any theoretical claim that Plaintiff might have otherwise had is barred by the applicable statute of limitations, and (iv) reveal that this Court is not the proper forum. Plaintiff has no legally viable claim, and especially no claim against . Having failed twice to state a claim, the case against must be dismissed. + +## BACKGROUND' + +In October 2006, Plaintiff met Defendant Jeffrey Epstein. (Am. Compl. I 34.) Plaintiff was then an adult woman over the age of 18. There are no allegations that she was uneducated, inexperienced in the world, or had anything less than full mental capacity. Epstein was older than her—already in his mid-fifties. (Id. 1 11.) He was unmarried. And he was wealthy (a successful hedge-fund manager worth more than a billion dollars). (Id. TI 11, 60.) + +For purposes of this motion only, the factual allegations in the Amended Complaint are accepted as true. See Allison v. Round Table Inv. Mgmt. Co., LP, 447 F. App'x 274, 275 (2d Cir. 2012). + +Soon after they met, the two entered into a consensual relationship. (Am. Compl. 1 43.) Epstein agreed to provide—and did provide—Plaintiff with a cell phone, a car service, and an apartment in the Upper East Side of Manhattan. (Id. 1 52.) They engaged in sexual acts "dozens of times" at his "townhouse in New York and on his private island in the U.S. Virgin Islands." (Id. 1 45.) + +According to the Amended Complaint, Epstein "confirmed" to Plaintiff "that he would use his wealth and influence to have [her] admitted into the Fashion Institute of Technology (known as `F.I.T.') in New York City or into a similar institute of higher learning offering a curriculum of fashion industry training." (Am. Compl. 1 38.) Other defendants, including some of Epstein's employees, allegedly "confirmed and reiterated this promise." (Id.) Plaintiff further claims that Epstein and Defendant Ghislaine Maxwell told her that "they also had the ability to make sure that she would obtain no formal education or modeling agency contract if she failed to provide the sexual favors desired." (Id.1 41.) + +In January 2007, Plaintiff left New York and flew to South Africa. (Am. Compl. 1 38.) That is where she is originally from (id. 1 3) and where her parents lived (id. 1 58). According to the allegations, Plaintiff was there on a "recruitment assignment" to find a South African model that Epstein could hire as an assistant, but she chose not to complete that assignment. (Id. 11 55- 56.) By her own account, "based upon Plaintiffs experience," she "did not believe the requested model would be placed in a legitimate position of employment of Defendant Epstein." (Id. 1 56.) + +In February 2007, Plaintiff nevertheless decided to return to New York. (Am. Compl. 1 61.) Epstein and Maxwell allegedly confirmed again their commitment to "help Plaintiff be admitted to F.I.T. or a comparable college." (Id.1 61.) But according to the Amended Complaint, they "failed and refused to perform" that promise. (Id.1 62.) 2 + +By May 2007, Plaintiff had once again left the United States—this time for good. (Am. Compl. 1 64.) + +Nearly a decade later, on January 26, 2017, Plaintiff brought this lawsuit under the Victims of Trafficking and Violence Protection Act. (Dkt. No. I.) Claiming that false promises "induce[d] and coerce[d]" her to have sex with Epstein, the Amended Complaint asserts human-trafficking claims against Epstein, Maxwell, and four other individuals. (Am. Compl. 1 68.) Among the named defendants is Epstein's former personal assistant maintained Epstein's schedule and also handled various travel arrangements, which allegedly included flights for Plaintiff on commercial airlines and Epstein's private jet. (Id. fl IS, 51)3 + +2To be sure, Plaintiff does not allege that she applied to F.I.T. (or a similar institute), that she was qualified for admission, or—if she did apply—that her application was denied. + +3joins Defendants Epstein and Groff's request that paragraphs 11-33 of the Amended Complaint should be stricken under Rule 12(f). (See Dkt. No. 80, at pp. 3-4.) Those paragraphs assert scandalous, harassing, and immaterial allegations about unrelated proceedings, including Epstein's earlier guilty plea in Florida. The claims there involved events leading up to a 2005 criminal investigation in that State. By contrast, the allegations here took place in 2006 (not before 2005), relate to an adult relationship (no allegations about a minor), and occurred in New York and the Virgin Islands (not Florida). For these same reasons, Plaintiff's initial Complaint acknowledged that she did not claim to be a victim in connection with the Florida criminal proceedings. (See, e.g., Dkt. No. 1, 1 29.) + +On May 15, 2017, sent a pre-motion letter identifying the many deficiencies in the initial Complaint. (Declaration of John E. Stephenson, Exhibit A.) In response, on June 5, 2017, Plaintiff elected to file her Amended Complaint, which is the subject of this motion to dismiss. + +## APPLICABLE LAW + +### A. Standard of Review + +To survive a motion to dismiss under Rule 12(bX6), "a complaint must contain sufficient factual matter, accepted as true, to 'state a claim to relief that is plausible on its face.'" Ashcroft v. 'ghat, 556 U.S. 662, 678 (2009) (quoting Bell Ad. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). "A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 556). There must be more than the "mere possibility of misconduct" (Iqbal, 556 U .S. at 679): The allegations must "nudge[] the[] claims across the line from conceivable to plausible." Twombly, 550 U.S. at 570. + +Courts will draw reasonable inferences in the plaintiff's favor but need not accept as true "conclusions of law or unwarranted deductions of fact." Lenten v. Merrill & Co., 396 F.3d 161, 174-75 (2d Cir. 2005). "A pleading that offers 'labels and conclusions' or a 'formulaic recitation of the elements of a cause of action will not do.'" lqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 555). "Nor does a complaint suffice if it tenders 'naked assertion[s]' devoid of 'further factual enhancement.'" Id. + +## B. The Victims of Trafficking and Violence Protection Act + +The Victims of Trafficking and Violence Protection Act of 2000, 18 U.S.C. § 1591, et seq., criminalizes certain activities related to an enterprise that engages in commercial sex trafficking of children or deceived adults. In particular, broken down into elements, the applicable version of Section 1591(a)(1) declares that: + +[1] Whoever [2] knowingly -- [3] in or affecting interstate or foreign commerce . . [4] recruits, entices, harbors, transports, provides, or obtains by any means [5] a person; [6] knowing that [7][a] force, fraud, or coercion . . . will be used to cause the person to engage in a commercial sex act, or [b] that the person has not attained the age of 18 years and will be caused to engage in a commercial sex act, [8] shall be punished as provided in subsection (b). + +18 U.S.C. § 1591(a)(1) (2006).4 + +Section 1595 gives a sex-trafficking victim the right to bring a civil action against the perpetrator who violated the Act's criminal provisions. 18 U.S.C. § 1595(a). + +## ARGUMENT + +# I. Plaintiff has failed to state a claim that violated Section 1591. + +The sex-trafficking case against tails to state a claim, for at least three reasons: First, the consensual, adult relationship at issue is outside the scope of conduct meant to be regulated by the Victims of Trafficking and Violence Protection Act. Second, the allegations fall short measured against the Twomblyllqbal pleading standards. Third, Plaintiff cannot plausibly allege that possessed the actual knowledge that would be required for a sex-trafficking claim under Section 1591. + +Plaintiffs claims stem from alleged conduct in 2006 and 2007, so the statute in effect at that time governs the analysis here. Applying later amendments to this statute impermissibly risks expanding defendants' liability for past conduct. See St. Louis v. Periitz, No. 3:13-CV-1132, 2016 WL 1408076, at \*3 (D. Conn. Apr. 8, 2016). + +#### A. The Act does not cover the type of consenting-adult relationship alleged. + +Plaintiff and Epstein, as consenting adults, voluntarily engaged in sexual activity. Their private relationship and the ultimate differences they encountered are beyond the aims of the Victims of Trafficking and Violence Protection Act—falling outside the scope of conduct that Congress intended to regulate and prohibit. + +incorporates by reference—and expressly adopts—the arguments on this point from Defendants Epstein and Groff s November 21, 2017 Memorandum of Law. (See Dkt. No. 80, at pp. 6-8.) In short, Congress passed Section 1591 of the Act to "combat trafficking in persons, a contemporary manifestation of slavery whose victims are predominantly women and children." H.R. Conf. Rep. 106-939 (2000). It is about ending trafficking and forced commercial sex acts by women who were lured into the United States by means of fraud. Id. + +That is not this case. Plaintiff already lived in New York City before she met Epstein, apparently having moved there for reasons completely unrelated to these Defendants. Plaintiff was not a victim "lured" into this Country by human traffickers. She voluntarily entered into a relationship with Epstein among other reasons because—in her estimation—it might bring the advantage of helping her get into college. There were other benefits, too: "living quarters ... a car service for Plaintiff to use as needed; [and] a cell phone." Plaintiff was not "caused" to engage in commercial sex acts by way of "fraud." Her relationship with Epstein had the hallmarks of the not uncommon arrangement in which an older male offers support to a younger female companion. (Declaration of John E. Stephenson, Exhibit B.) That Epstein allegedly did not deliver on one promise as quickly as Plaintiff might have preferred cannot turn this into a violation of federal sextrafficking laws.5 + +# B. The Amended Complaint fails to meet the Twomblyllqbal pleading standards. + +Plaintiffs purported claims do not meet the Twotnblyfiqbal pleading requirements. The allegations lack necessary factual support and improperly lump all five Defendants together. + +Focusing on the allegations that can be construed as directed at , many simply recite Section 1591's legal conclusions and statutory buzzwords. For instance, in Paragraph 51, the Amended Complaint appears to allege that Defendants Groff, Maxwell, and "worked in concert with one another to recruit, procure, entice, and otherwise cause many other females to engage in commercial sex acts, through their use of threats, fraud, and coercion." (Am. Compl. 1 51.) By way of further illustration, Paragraph 20—which should not have been included in the first place, and relates only to the criminal proceedings in Florida that, as Plaintiff admits, have no connection to her—asserts that "Defendants Epstein and Maxwell, with help from assistants. + +5 A survey of decisions involving the Victims of Trafficking and Violence Protection Act confirms that the allegations here bear little resemblance to the facts in those cases. See, e.g., United States v. 621 F.3d 101, 103 (2d Cir. 2010) (defendant "induced a fourteen-year old ninth-grader to work for him as a prostitute"; when "using two eighteen-year old girls as prostitutes," he "raped both of them" and "held them against their will and exploited their addiction to heroin"); Lunkes v. Yannai, 882 F. Supp. 2d 545 (S.D.N.Y. 2012) (defendant allegedly lured victims "using websites designed to match women seeking work as au pair with families in need of such workers" and "deceived them into illegally entering the United States, where he proceeded to effectively imprison them in his house, sexually abuse them, and demand unpaid domestic services"); United States v. Corley, No. 14-1709, 2017 WL 549021 (2d Cir. Feb. 9, 2017) (defendant recruited minors to work for him as prostitutes, advertising the victims online). + +associates and underlings, recruited and procured hundreds of girls" and that "such recruitment and procurement included fraud, coercion, threats, intimidation, fear, the threat of coercion, and a combination of these and similar tactics." (Id.i 20.) These assertions "do not allege facts": "They are simply a regurgitation of [Section 1591's] wording woven together with conclusory statements." Kelsey v. Goldstar Estate Buyers Corp., No. 3:13-CV-00354-HU, 2014 WL 1155253, at \*5-6 (D. Or. Mar. 21, 2014). Plaintiff's formulaic recitation of the elements— "[n]aked assertions devoid of further factual enhancement" (Iqbal, 556 U.S. at 678)—will not do. See also Weinstein Co. v. Smokewood Entm't Gip., 664 F. Supp. 2d 332, 338 (S.D.N.Y. 2009) ("The tenet that a court must accept as true all of the allegations in a complaint is inapplicable to legal conclusions.") (quoting Ighal). + +At the same time, the Amended Complaint repeatedly and improperly lumps all Defendants together. Plaintiff alleges, for example, that "Defendants recruited Plaintiff into their sexual enterprise." (Am. Comp!. 1 34.) Later, she alleges that "Defendants all participated in arranging for Plaintiff to be transported" (id. 1 45); "Defendants further used possession and control of Plaintiff's passport" (id. 1 49); and "Defendants provided living quarters for Plaintiff . . . a car service . . . a cell phone" (id. 1 52). Such group-pleading runs afoul of Rule 8, which requires "'specification' as to the particular activities by any particular defendant .. . ." Am. Sales Co. v. AstraZeneca AB, No. 10Civ.6062, 2011 WL 1465786, at \*5 (S.D.N.Y. Apr. 14, 2011); 0 & G Carriers, Inc. v. , 799 F. Supp. 1528, 1538 (S.D.N.Y.1992) (dismissing claims because of "repeated undifferentiated grouping of defendants so that it is impossible to tell what each individual defendant is accused of doing"). + +To survive a motion to dismiss, Plaintiff must "indicate clearly the defendants against whom relief is sought and the basis upon which the relief is sought against the particular defendants." v. City of New York, No. 07 Civ. 7834, 2008 WL 1826483, at \*1 (S.D.N.Y. Apr. 23, 2008). But that did not happen. Instead, Plaintiff asserts allegations generally against all Defendants—betraying the pleading standard's purpose to put on notice as to the specific allegations she need defend against. See Atuahene v. City of Hanford, 10 F. App'x 33, 34 (2d Cir. 2001) (holding that allegations "failed to differentiate among the defendants, alleging instead violations by 'the defendants"); Elias v. City of New York, No. 10-CV-5495, 2010 WL 5475809 (E.D.N.Y. Dec. 30, 2010) (plaintiff failed to give defendants fair notice of claims where complaint "attribute[d] discrimination, retaliation, and disparate treatment generally to 'Defendants"). + +Plaintiffs lumping of Defendants is not only impermissible but also implausible. Taken literally, her allegations would claim that all five Defendants recruited Plaintiff to have sex with Epstein, and that each of the five then provided her an apartment, a driver, and a mobile phone. It does not make sense. Plus, some of the allegations that refer broadly to "Defendants" are later clarified and narrowed so as to specifically exclude . For instance, the Amended Complaint first states that "Defendants recruited Plaintiff' (Am. Compl. 1 34), but the next paragraph details how it was Defendant Natalya that allegedly "approached and recruited Plaintiff." (Id.1 35.) While Plaintiffs allegations suggest that the "Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts" (id. 1 57), the surrounding lines elaborate that this portion of the Amended Complaint relates to only some of the Defendants—having nothing to do with alleged conduct by + +Plaintiff's allegations lack factual detail, state little more than legal conclusions, and impermissibly lump "Defendants" together. Because the Amended Complaint falls short under Twomblyfiqbal, Plaintiff has failed to state a claim. + +#### C. Plaintiff cannot plausibly allege that had the requisite knowledge under Section 1591. + +The Amended Complaint does not plausibly allege that had the requisite knowledge. For this reason alone, any potential claim against is subject to dismissal. + +To state a claim under 18 U.S.C. § 1591, Plaintiff must allege that performed one of the enumerated trafficking acts while "knowing" that "force, fraud, or coercion" would be used to cause Plaintiff to engage in a commercial sex act. The upshot? Even if Plaintiff could allege that "transported" her, and even if we assume that it was for purposes of a "commercial sex act," Plaintiff would still need to allege that knew that "force, fraud, or coercion" would cause her to have sex with Epstein. This she has not done.\* + +## I. The purported "fraud" claim. + +Plausible actual-knowledge allegations demand factual content. See Rosner v. Bank of China, No. 06 CV 13562, 2008 WL 5416380, at \*5 (S.D.N.Y. Dec. 18, 2008), ard, 349 F. App'x 637 (2d Cir. 2009) ("[W]hile the element of actual knowledge may be alleged generally, the plaintiff still must accompany that general allegation with allegations of specific facts that give rise to a strong inference of actual knowledge regarding the underlying fraud"); see also San Leandro Emergency Met Grp. Profit Sharing Plan v. Philip Morris Co., 75 F.3d 801, 812 (2d Cir. 1996) ("[P]laintiffs allege no facts supporting their assertion that defendants had knowledge...[n]or do plaintiffs offer anything but conclusory allegations to support their + +6 In the alternative, Section 1591 allows for liability where a defendant instead acts "knowing" that the person who "will be caused to engage in a commercial sex act" has "not attained the age of 18 years." But that portion of the statute's text cannot apply here: Plaintiff is, and at all relevant times was, over the age of 18. + +contention that defendants knew"). And yet Plaintiffs assertions here are conspicuously void of specific facts. For context, in the initial Complaint, there were no allegations (express or implied, plausible or not) that knew that the other Defendants might use force, fraud, or coercion to cause Plaintiff to engage in commercial sex with Epstein. After pointed out the deficiency in her May 15, 2017 pre-motion letter, Plaintiff elected to file the Amended Complaint. In the revised pleading, Plaintiff now alleges that "knew that Plaintiff was actually being recruited for sexual purposes" and "knowingly made false representations to ensure that Plaintiff would cooperate in fulfilling Epstein's sexual desires." (Am. Compl. 40.) But Plaintiff cannot solve the problem by adding the conclusion that "knew" that fraud would be used to make Plaintiff perform sex acts, or weaving in the blanket statement that "knowingly." all the while acted + +At most, the allegations might support an inference that Plaintiff was "being recruited for a sexual purpose" and that would have known that "confirmed and reiterated" promises about Epstein's ability to help with Plaintiff's education. (Am. Compl. IN 38, 40.) But that still would not make for a plausible inference that knew that any fashion-school-related representations might have been false. Said another way, there is no basis (alleged, or otherwise) to infer that acted knowing of others' fraudulent intent—that Epstein or others never meant to make good on promises to help Plaintiff gain admission into FIT or a similar school' + +7 To the extent the Amended Complaint can be construed as asserting that herself "repeated" false representations, Plaintiff has failed to plead fraud with the requisite particularity required by Rule 9(b). See Fed. R. Civ. P. 9(b). She does not allege when, where, or how allegedly "confirmed and reiterated" or "repeated" others' alleged fraudulent promises to Plaintiff. Nor are there allegations to detail the statements attributed to a rel. U.S. v. Applied + +And the allegations that have been made are such that the only plausible inference is that expected Epstein to follow through on his commitments. The few specific allegations in the Amended Complaint confirm that understanding would have been that Epstein intended to keep any promises of assistance. Plaintiff's allegations confirm that Epstein provided Plaintiff with a cell phone, car service, and even an Upper East Side apartment. (Am. Compl. 52.) He supposedly "continued to provide Plaintiff with things of value" as their relationship progressed. (Id.1 62.) This establishes that Epstein made good and delivered on earlier promises. How could know whether Epstein intended to deliver on these first three promises, but not his fourth? The Complaint does not say.' + +That Epstein did not ultimately follow through on this last commitment is not sufficient to show that the alleged representations about F.I.T. were false when made, and certainly insufficient to show that knew of any falsity or fraudulent intent. See Greenberg v. Christ, 198 F.Supp.2d 578, 583 (S.D.N.Y. 2002) ("[F]ailure to fulfill a promise to perform future acts is not grounds for a fraud action" and "fraudulent intent cannot be inferred merely from the nonperformance of a party's representations"). Slapping a "knowing" label here and there throughout the Amended Complaint does not cure its deficiencies. There is no mention of a conversation, agreement, or any significant interaction between Epstein and on the subject of the alleged + +Research Assocs., Inc., 328 F. App'x 744, 747 (2d Cir. 2009) ("[I]n alleging fraud or mistake, a party must state with particularity the circumstances constituting fraud or mistake."). + +8Plaintiff also alleges that told Plaintiff that Epstein had used his wealth and influence to advance =Is own career. (Am. Compl. I 53.) But Epstein did help . This makes it even less plausible that had reason to think that anyone was using "fraud" to force Plaintiff to engage in a commercial sex act. + +fraud. Plaintiff herself concedes that certain so-called "underlings" participated in the alleged "scheme" "wittingly and unwittingly." (Am. Compl. 1 19) (emphasis added). The "mere possibility of misconduct" is decidedly not enough. lqbal, 556 U.S. at 679. + +There are no allegations to "nudge" Plaintiff's knowledge-based claim against "across the line from conceivable to plausible." Twombly, 550 U.S. at 570. In the end. had no reason to know whether Epstein or others subjectively intended to fulfill the educational promise to Plaintiff. + +## 2. The purported "coercion" claim. + +Nor are there plausible allegations that knew that some "coercion" would be used to cause Plaintiff to have sex with Epstein. The purported coercive statements are attributed primarily to "Epstein and Maxwell." name is not uttered in connection with any of those claims. For example, Paragraph 41 states that "Maxwell and Epstein also threatened Plaintiff that, while they had the ability to advance her education and career, they also had the ability to make sure that she would obtain no formal education or modeling agency contract if she failed to provide the sexual favors desired." (Am. Comp1.1 41.) is not alleged to have participated in or been aware of such "threats." Again in Paragraph 48, "Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance . . . and [to) continue performing the demanded commercial sex activity." (Id. 1 48.) Only "these Defendants" (id.1 48)—not IIM—are mentioned as having alleged involvement in the so-called coercion. + +Plaintiff does not allege that repeated or confirmed the alleged threats, or that she knew that any threats might be used to cause Plaintiff to engage in a commercial sex act. Thus, where the fraud-based allegations against are deficient for lack of knowledge, the allegations about coercion are even worse. + +Plaintiff cannot invoke the civil remedy under Section 1595 since she does not and cannot plausibly allege that knew that "force, fraud, or coercion" would be used to cause Plaintiff to engage in a commercial sex act. Without the requisite knowledge, Plaintiff might be able to allege that engaged in conduct that other people might not look favorably upon, or possibly even conduct that is prohibited by some other statute. But she cannot state a claim for relief under this statute. See United States v. Todd, 627 F.3d 329, 335 (9th Cir. 2010) ("Where a defendant engages in sex trafficking without the use of force, fraud, or coercion, or where children are not involved, his conduct is criminalized by a different set of statutes."); see also Kolbek v. Twenty First Century Holiness Tabernacle Church, Inc., No. 10-CV-4124, 2013 WL 6816174, at •16 (W.D. Ark. Dec. 24, 2013) (dismissing Section 1595 civil claim where defendants may have violated other sex-related statutes but not Section 1591). Without knowledge, there is no Section 1591 claim against 9 + +# H. The Amended Complaint does not state a Section 1592 claim. + +Section 1592 makes it unlawful to "knowingly destroy, conceal, remove, confiscate, or possess any actual or purported ... government identification document, of another person" during the commission of trafficking activities. 18 U.S.C. § 1592(a). Plaintiff parrots back the language from this statute. Indeed, for the first time in the Amended Complaint, Plaintiff makes conclusory statements that Defendants "took possession of Plaintiffs passport" and "used possession and + +9 For similar reasons, Plaintiffs effort to add a claim that Defendants violated Section 1594(a) (Am. Compl. q 71)—separately prohibiting "attempted" violations of Section 1591—must also fail. + +control of Plaintiffs passport" to coerce her into performing sexual acts. (Am. Compl. II 45, 49, 54, 69.) + +Here again, Plaintiff fails to provide any specific facts to make a plausible claim. When did the Defendants take her passport? Did they take it from her without her knowledge? With force? Or did she willingly hand it over? What was the purported reason for which they had her passport? How long did they hold her passport? And how did the Defendants "use possession and control" of the passport to cause her to perform sexual acts? The allegations give no answers. Instead, they merely state conclusions pulled directly from the language of the statute. See Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009) ("[T]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.") (quoting lqbal). + +To the extent Plaintiff means to plead a Section 1592 violation, any such claim is inadequate as a matter of law.10 + +## HI. The claims against are all time-barred. + +Plaintiff has no claim against for the reasons outlined above. In all events, any theoretical cause of action against would be barred by the applicable statute of limitations. + +In 2008, the Act was amended to give victims ten years, rather than four years, to bring a private action against perpetrators under the civil-remedy provision. See 18 U.S.C. § 1595(c)(1) + +1° Nor can them be any claim based on Section 1593A. (Am. Comp1.1 70.) That provision has no application here since it was first enacted in December 2008, after all of the alleged acts had been completed. Velez v. . 693 F.3d 308, 325 (2d Cir. 2012) (describing "well-established presumption against" retroactive amendments). Regardless, them are no plausible allegations that violated Section 1593A, which today criminalizes those who knowingly participate in or benefit from a venture in contravention of Section 1592 and 1595(a). + +(as amended in 2008) ("No action may be maintained under this section unless it is commenced not later than ... 10 years after the cause of action arose"). Here, the alleged events had all ended by 2007—before the 2008 amendment—so the four-year period still applies. See Abarca v. Little, 54 F.Supp.3d 1064, 1068 (D. Minn. 2014) (holding that four-year limitations period applies where Section 1595 claim stems from pre-2008 conduct); but see Oltsch v. Orina, 101 F.Supp.3d 325, 330 (S.D.N.Y. 2015) (applying amendment retroactively). Since Plaintiff filed suit well outside of the four-year window, this action is time-barred. + +But even if the ten-year statute of limitations applied, the claims against would still be barred. There is no allegation that committed any of the statute's enumerated acts (e.g., recruiting, transporting) that constitute "trafficking" since January 26, 2007—the start of the tenyear period leading up to this lawsuit. That should end the inquiry. + +In reality, the limitations period on Plaintiff's Section 1595 claim commenced no later than January 2007 and expired before the Complaint was filed on January 26, 2017. hereby incorporates by reference and adopts the arguments in Defendant Epstein and Groff s November 21, 2017 Memorandum of Law addressing this issue. (See Dkt. No. 80, at pp. 21-23.) + +In short, January 2007 marks when Plaintiff first left the United States." The allegations confirm that, by then. Plaintiff's eyes were open: She was aware of and had already realized the Defendants' so-called fraudulent "scheme." That is why Plaintiff "deliberately refused to perform the recruitment assignment" in South Africa—i.e., "she knew that the requested female model would not be placed in a legitimate position of employment with Defendant Epstein." (Am. Compl. 1 56.) Plaintiff thus cannot claim to have been relying on any fraudulent representation + +Notably, there is no allegation to suggest that this occurred on or after January 26, 2007. + +about FIT that came after January 2007. Plus, by this point, she was at home with her parents in South Africa. She was on another continent, thousands of miles away, and beyond the reach of the Defendants, so any alleged coercion over her also necessarily ended in January 2007. See, e.g., Abarca, 54 F. Supp.3d 1064, 1070 (holding that Section 1595 claim arose when plaintiff traveled home to Mexico during "extended absences from defendants" with "physical freedom to seek legal advice and assistance"); Oluch v. Orina, 101 F. Supp. 3d 325, 330 (S.D.N.Y. 2015) (Section 1595 claim accrued when plaintiff first exited the defendant's home). By any measure, this action is time-barred because Plaintiff filed suit more than ten years after her cause of action arose. + +# IV. This Court is not a proper forum for Plaintiffs action. + +Even if Plaintiff could somehow articulate a viable and timely claim—again, she cannot this case should not proceed in the Southern District of New York. The allegations are insufficient to establish that this Court has personal jurisdiction over the Defendants. And for similar reasons, this District is an improper venue. For brevity, and to avoid duplication, incorporates by reference—and expressly adopts—Defendants Epstein and Groff's arguments on these two issues. (See Dkt. No. 80, at pp. 23-24.) + +## CONCLUSION + +For these reasons, the claims against should be dismissed in their entirety. + +Dated: Atlanta, Georgia November 21, 2017 + +> By: /s/John E. Stephenson, Jr. John E. Stephenson, Jr. (admitted pro hac vice) Jonathan D. Parente (pro hac vice forthcoming) ALSTON & BIRD LLP 1201 West Peachtree Street + +Atlanta, Georgia 30309 (404) 881-7000 john.stephenson@alston.com jonathan.parente@alston.com + +Alexander S. Lorenzo ALSTON & BIRD LLP 90 Park Avenue New York, New York 10016 (212) 210-9400 alexander.lorenzo@alston.com + +Counsel or Defendant \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819874/EFTA02819874.metadata.json b/marker2/court-jane-doe-43/EFTA02819874/EFTA02819874.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c5194301ef2eaac6a10ba4ecd8a058487ad1169b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819874/EFTA02819874.metadata.json @@ -0,0 +1,1436 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819874.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 23, + "chars": 38361, + "elapsed_seconds": 2.87, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 87.51599999999999, + 71.28 + ], + [ + 296.70001220703125, + 71.28 + ], + [ + 296.70001220703125, + 100.10302734375 + ], + [ + 87.51599999999999, + 100.10302734375 + ] + ] + }, + { + "title": "MEMORANDUM OF LAW IN SUPPORT OF \nDEFENDANT MOTION TO DISMISS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 147.49200000000002, + 320.76 + ], + [ + 464.89208984375, + 320.76 + ], + [ + 464.89208984375, + 350.9830322265625 + ], + [ + 147.49200000000002, + 350.9830322265625 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 239.29200000000003, + 71.28 + ], + [ + 374.5343933105469, + 71.28 + ], + [ + 374.5343933105469, + 86.2330322265625 + ], + [ + 239.29200000000003, + 86.2330322265625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 228.88800000000003, + 72.08999999999999 + ], + [ + 383.5578918457031, + 72.08999999999999 + ], + [ + 383.5578918457031, + 86.2330322265625 + ], + [ + 228.88800000000003, + 86.2330322265625 + ] + ] + }, + { + "title": "RULES", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 86.29199999999999, + 507.06000000000006 + ], + [ + 126.6891098022461, + 507.06000000000006 + ], + [ + 126.6891098022461, + 523.4830322265625 + ], + [ + 86.29199999999999, + 523.4830322265625 + ] + ] + }, + { + "title": "STATUTES", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 86.29199999999999, + 636.66 + ], + [ + 144.67135620117188, + 636.66 + ], + [ + 144.67135620117188, + 652.4830169677734 + ], + [ + 86.29199999999999, + 652.4830169677734 + ] + ] + }, + { + "title": "OTHER AUTHORITIES", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 87.51599999999999, + 179.01 + ], + [ + 200.53773498535156, + 179.01 + ], + [ + 200.53773498535156, + 194.5670166015625 + ], + [ + 87.51599999999999, + 194.5670166015625 + ] + ] + }, + { + "title": "INTRODUCTION", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 255.204, + 72.08999999999999 + ], + [ + 356.9616394042969, + 72.08999999999999 + ], + [ + 356.9616394042969, + 86.2330322265625 + ], + [ + 255.204, + 86.2330322265625 + ] + ] + }, + { + "title": "BACKGROUND'", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 257.03999999999996, + 484.37999999999994 + ], + [ + 352.51199999999994, + 484.37999999999994 + ], + [ + 352.51199999999994, + 500.2330322265625 + ], + [ + 257.03999999999996, + 500.2330322265625 + ] + ] + }, + { + "title": "APPLICABLE LAW", + "heading_level": null, + "page_id": 8, + "polygon": [ + [ + 247.86, + 153.89999999999998 + ], + [ + 363.220458984375, + 153.89999999999998 + ], + [ + 363.220458984375, + 169.10302734375 + ], + [ + 247.86, + 169.10302734375 + ] + ] + }, + { + "title": "A. 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GA 30109-3424 + +404.881.7000 + +Fax: 4O4.881.7777 + +www.alston.com + +John F. Stephenson. Jr. + +## VIA EMAIL AND U.S. MAIL + +Brad , Esq. + +Jaffe, Weissing, + +Fistos & Lehrman, P.L. + +425 North Andrews Ave., Suite 2 + +Fort Lauderdale, FL 33301 + +Direct Dial: 404.881.7697 + +May 15, 2017 + +Email: johnstepliensonValsion.com + +Re: Doe 43 v. Epstein, et at, No. 1:17-CV-00616 (S.D.N.Y.) + +Dear Brad: + +As contemplated by the Court's directives at the initial conference, and in accordance with the parties' May 12, 2017 stipulation, I write on behalf of defendant to identify what we believe are deficiencies in the Complaint. The claims against should be dismissed for the reasons outlined below. + +At the outset, the entire Complaint—including all claim' against all Defendants—is subject to dismissal based on the defects described in Michael letter dated today. That correspondence was sent on behalf of defendants Jeffrey Epstein and Lesley Groff, but the many grounds for dismissal set out in the letter also apply to any claim against + +- The Complaint's allegations improperly lump together all "Defendants" and also improperly lump together various statutory provisions ( Letter at 6, 10-11); +- The purported "fraud"-based claims under 18 U.S.C. § 1591 are legally insufficient: These allegations fall short under the heightened standards applicable under Rule 9(b), and Plaintiff has failed to adequately allege the requisite "fraudulent intent" or "reasonable reliance" (id. at 3-6); +- Section 1591 was never intended to address or regulate the type of consentingadult relationship at issue in the allegations (id. at 7); +- Plaintiff also has not pleaded a legally viable theory under Section 1591's "coercion" prong (id. at 8-9); +- The Complaint fails to plausibly allege the requisite "commercial" sex act—much less one "caused" by "force, fraud, or coercion" (id. at 9-10); + +May 15, 2017 Page 2 + +- The Complaint merely parrots back various statutory elements and does not state a plausible claim that Plaintiff—an adult of sound mind who voluntarily entered into a consensual relationship—was the victim of a criminal sex-trafficking offense (id. at I I); +- **Plaintiff's claims are all barred by the applicable statute of limitations under Section 1595 (id. at 12-13); and** +- **The allegations highlight independent jurisdictional and venue defects that are alone fatal (id. at 13-14).** + +**Mr. letter effectively details and gives notice of these and other deficiencies, so for the sake of efficiency, we join in his entire letter and incorporate by reference the arguments, authorities, and citations that he sets out more fully.' Beyond that, however, I write separately to emphasize a few select issues that apply with particular force in the case of given the specific allegations that have (and have not) been made against her.** + +## **The Complaint fails to state a claim against EM** + +**The lack of factual content in the allegations and improper lumping of Defendants underscores that Plaintiff has not and cannot, state a claim against my client. There are hardly any allegations about MEM She is identified by name only a handful of times in the 20 pa e Com laint. And most of the allegations that could even arguably be construed as directed at simply recite Section 1591's legal conclusions and statutory buzzwords—e.g., "recruited," "procured," "fraud," or "coercion." (See, e.g., Comp. 1 21; see also Kelsey v. Goldstar Estate Buyers Corp., No. 3:13-CV-00354-HU, 2014 WL 1155253, at \*5-6 (D. Or. Mar. 21, 2014) ("They do not allege facts. They are simply a regurgitation of [Section 1591's] wording woven together with conclusory statements . . . .").) One allegation vaguely references some "verbal abuse and threats" that seem to be attributed to several individuals, including but the Complaint does nothing to describe who said what or what the alleged comments might have related to. (Id. 1 46.) That is not enough to state a plausible claim that violated the criminal sex trafficking provisions at issue. See Ashcroft v. lqbal, 556 U.S. 662, 678 (2009) ("A pleading that offers 'labels and conclusions' or a 'formulaic recitation of the elements of a cause of action will not do.").** + +**The dearth of facts and allegations directed toward makes the Complaint's repeated and improper lumping of all "Defendants" together particularly egregious. Plaintiff alleges, for example, that "Defendants recruited Plaintiff' (Compl. 1 33) and later that "Defendants provided" Plaintiff with an apartment, a car service, a cell phone, and other consideration (id. 1 49). This type of group pleading runs afoul of Rule 8, which requires "specification" as to "the particular activities by any particular defendant" See Am. Sales Co. v. AstraZeneca AB, No. 10Civ.6062, 2011 WL 1465786, at \*5 (S.D.N.Y. Apr. 14, 2011). Courts routinely dismiss claims that "fail[] to differentiate among the defendants, alleging** + +I also fully agree with Mr. position that paragraphs 12 through 32 contain a host of allegations that are unproven, irrelevant, and prejudicial in this action. They should be removed or stricken under Rule 12(f). + +May 15, 2017 Page 3 + +instead violations by 'the defendants' (Atuahene v. City of Hartford, 10 F. App'x. 33, 34 (2d Cir. 2001)), and that "attribute" alleged acts "generally to 'Defendants." Bias v. City of New York, No. 10—CV-5495, 2010 WL 5475809 (E.D.N.Y. Dec. 30, 2010). + +The lumping of all Defendants is not only impermissible but also implausible: Taken literally, the allegations would claim that all five Defendants recruited Plaintiff and that each of the five then provided her with an apartment, a phone, and a car. Plus, certain allegations that refer to acts of 'The Defendants" collectively are later narrowed by Plaintiff in a way that specifically excludes (Compare Compl. 1 34 with 1 35.) As currently drafted, the Complaint fails to put on sufficient notice of the allegations against her. + +The Complaint also fails to state a claim against under Section 1595 because Plaintiff has not alleged—much less plausibly alleged—that had the requisite knowledge under the underlying criminal provisions. lqbal, 556 U.S. at 678 ("a complaint must contain sufficient factual matter, accepted as true, to 'state a claim to relief that is lausible on its face."). Section 1591 requires that Plaintiff allege, among other things, that (i) "recruit ed , entice[d], harbor[ed], transport[ed], provide[d], or obtain[ed)" Plaintiff and (ii) that did so "knowing that force, fraud, or coercion ... w[ould] be used to cause [Plaintiff] to engage in a commercial sex act." 18 U.S.C. § 1591(a) (effective July 26, 2006). Even assumin that Plaintiff has alleged the other elements—again, she has not the claims against would still fail because the Complaint does not allege that knew that force, fraud, or coercion would be used to cause Plaintiff to engage in a commercial sex act.2 + +Plaintiff's allegations about involvement in the purported fraud are impermissibly vague and in all events insufficient. The Complaint alleges only that "confirmed" the promise of others that Mr. Epstein could use his influence to get her into a fashion institute. (Compl. 1 37.) The allegation is woefully deficient under Rule 9(b), and more generally, it is not at all clear what it means for la to have allegedly "confirmed this promise." Either way, there are no allegations that knew that the alleged promises might have been false—i.e., that some other individual(s) did not subjectively intend to perform and make good on their alleged educational promise. The absence of this critical knowledge allegation is especially problematic because, by Plaintiff's own allegations, Mr. Epstein had consistently followed through on various other alleged promises to Plaintiff. (Compl. 1 49.) The allegations as pleaded are not enough to "nudge[' the[] claims across the line from conceivable to plausible." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). + +As far as the alleged coercive conduct, the Complaint does not even mention IMI name or otherwise attempt to connect to the alleged intimidation or threats made by other individuals that sup sedl "coerced [Plaintiff] into sexual compliance." (Compl. 1 45.) It is not alleged that re ted or confirmed such coercive threats. There is no reason alleged (or otherwise) why would have had the requisite + +2 For the avoidance of doubt, as discussed above and as described in Mr. letter, among other things. Plaintiff has not sufficiently alleged (i) fraud, (ii) coercion, (iii) a "commercial" sex act, or (iv) the requisite causal link that fraudulent or coercive conduct produced the alleged sex acts. + +May 15, 2017 Page 4 + +knowledge of the alleged coercive statements. See lqbal, 556 U.S. at 679 (explaining that the "mere possibility of misconduct" is not enough). + +Without knowledge, there is no claim against + +Plaintiffs claims are time-barred. + +Any theoretical claim that Plaintiff might have against would be barred by the applicable statute of limitations. The alleged events, as relating to any of the Defendants, took place in 2006 and 2007. Because Plaintiff did not file suit until January 26, 2017—more than four years after the alleged events-this entire action is time barred. See Abarca v. little, 54 F. Supp. 3d 1065 1068 (Minn. 2014) (holding that four-year statute of limitations applies because the alleged unlawful conduct occurred prior to the 2008 amendment of Section 1595). + +Even if Plaintiff could claim the benefit of the ten-year limitations period Plaintiffs claim against would still be barred. First, each of the allegations about took place in the 2006 calendar year before Plaintiff first left for South Africa. Even accepting the allegations as true, the Complaint shows that did not do anything in 2007—i.e., within the ten-year period leading up to the filing of this lawsuit. + +As important, Plaintiff cannot plausibly allege that any alleged fraud or coercion attributable to any of the Defendants caused her to engage in sex acts after she left the United States in January 2007. By that time, she was at home with her parents in South Africa thousands of miles away, and by her own allegations, she was already alert as to the alleged fraud and coercion and had refused to perform the acts demanded of her. (Compl. 1 51.) + +If you would like to discuss any of these issues, please do not hesitate to reach out. + +Sincerely, + +John E. 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Most of the men are looking for fit, sexy women, and most of the women want nice guys who can make them smile and laugh. But if eHarmony or Match.com is a chatty social mixer, Seeking Arrangement is a down-and-dirty marketplace where older moneyed men and cute young women engage in brutally transactions. They're not searching for longtime soul mates; they want nostrings-attached "arrangements" that trade in society's most valued currencies: wealth, youth and beauty. In the cheesy lexicon of the site, they are "sugar daddies" and "sugar babies." + +There's the 18-year-old from France asking for \$5,000 to \$1o,000 a month from "a mentor who can provide me with the finer things in life and keep me happy!" And the 49-year-old investor from upstate New York willing to pay \$5,000 a month for a "daytime playmate" for "intense connection without commitment." Critics say the site is at best a convenience store for adulterers and at worst a virtual brothel, but Brandon Wade, Seeking Arrangement's 38-year-old founder and chief executive, is unperturbed by the criticism. "We stress relationships that are mutually beneficial," he says. "We ask people to really think about what they want in a relationship and what they have to offer. That kind of upfront honesty is a good basis for any relationship." + +The site now claims more than 300,000 registered members, far fewer than mainstream dating sites like Match.com, which has 1.5 million paying subscribers, but still a remarkable number. Sugar babies outnumber daddies to to 1. Wade says nrnvidinv what one sugar daddy called "the hest fishing hole + +9 Get 30% off for one year of The Time! Subscriber login + +This abundance of possibility is part of what the site is selling, along with fantasy. Some of these men — especially those shopping for women half their age — are digging deep into their pockets to pay for an illusion: that despite their receding hairlines and wattled skin, they're still enchanting enough to charm pretty young women. One image on the site features a dazed, graying man doted on by two barely clad attendants — a caricature of an already caricatured relationship. But this marketing spin doesn't capture the nuances of the relationships that often develop between the "daddies" and the "babies" who meet on the site — relationships that can turn out to be more complicated than even the members themselves expect. Men may use money as a way to buy themselves out of the normal obligations of romance, like accommodating a woman's emotional needs as much as their own. But despite the power and security that the money buys, it can also undercut the very ego it's intended to boost. + +Consider B. K., a fit finance executive in his early 4os, who, last October, began "dating" a 20-year-old engineering major at a college 90 minutes from his house. Like nearly half the sugar daddies on Seeking Arrangement, B. K. is married. (Neither B. K. nor any other user of the site would allow full names to be published — certain the revelation would infuriate wives or boyfriends, shock colleagues and repel friends or family — and agreed to use only their first names, nicknames or initials.) B. K. and his wife opted against separation, for the sake of the kids, and for now, they have a policy — at least in his mind — of don't ask, don't tell. Between pangs of guilt about cheating, B. K. views his secret dallying as a safety valve, letting him feel desired so he can return home and appreciate the many things he loves about his wife, even if they don't include giving him the attention he wants. + +And so, nearly each week, B. K. gets together with Lola, the young woman he met on the site, for a meal or a gym workout and a few hours at a hotel outside the Western city where he lives. Their visits are generally no longer than four or five hours because Lola, a senior, has a full course load and also works 4o hours a week at two low-wage jobs. With no money from her parents, she was in her Seeking Arrangement profile, saying she needed "immediate financial assistance." In B. K., she gets that in the form of \$too or \$150 stuffed in her bag each time they meet. He feels good about helping her with her tuition, encouraging her studies and romancing her, albeit in hotel rooms. Most of all, he's grateful that she doesn't want a commitment. At least he was at first. + +"It's very clear with this site that she's getting something out of this, hopefully emotional support and mentoring advice and fun in bed, but also something financial, so don't come back to me and say that you were used or that Ileft you high and dry," he said. "I like that aspect of it, but on the other hand, it would be nice not to have the money involved, because you always wonder: would she still want to be with me even without the money? Does the money make me more attractive than I really am?" + +ABOUT 30 PERCENT OF ARRANGEMENTS on the site involve the daddy paying an "allowance," usually a thousand or two amonth, though the site claims some reach \$10,000. The rest provide the baby with incidental cash, shopping sprees, gifts, travel or the fleeting illusion that theirs is ahigh-end, easy life. "I get flown to whatever city I want," wrote aNorth Carolina college student, who goes by the name gurinextdoor on the site's blog, a mix between an online support group and a kaffeeklatsch. "He pays for it, takes me shopping, we talk, laugh, go out to eat and do whatever we want to do for our days together... . I don't bring up mundane problems about my home life, and he does the same.... If I wanted someone to talk to about my life problems, I'd get a boyfriend or a therapist." + +Like B. IC's companion, Lola, many women on the site are in their 20S, though plenty of others are in their 3os, 4os and 5os. Some are looking for attention, some have financial problems and some are seeking refuge from romantic pain. On the blog and in conversations with me, still others said benefactors provide away to get the extras they want — the Fendi bags, the todie-for shoe collection or the breast enhancement. A surprising number of babies say on the blog that they don't need the money at all, either because they have decent-paying jobs or bottomless credit cards from their parents. What appeals to them about the arrangements are the expensive gifts — "I just LOVE being spoiled," gushed one 19-year-old woman on the blog — because those gifts make them feel valued, as if the money spent measures just how desirable they are. + +Other women on the site would happily forfeit conspicuous prizes and go for the cash instead, especially for tuition. One woman's profile says, "That you can help me get through school and achieve financial stability through support and mentoring is more important than wowing me with diamonds and Prada." In fact, Seeking Arrangement pays to have its ads pop up on search engines whenever + +someone types in "student loan," "tuition help," "college support" or "help with rent." Lola was one of many to stumble on the site that way, when — behind on her rent and tuition and down to one meal a day — she Googled "student loan." What popped up was hardly what she expected, but she was willing to try almost anything to stay in school. + +Her first sugar daddy, a man in his early 5os, turned out to be a terrible kisser and too dominating in bed. "I had to grit my teeth every time we met," she told me. In four visits, she earned \$550, enough to cover the rent, and then dropped him. A month later, she connected with another sugar daddy, a man in his late sos who lived in Louisiana. The only thing he wanted, he told her, was that she do well in school. He insisted she send her transcript, and once satisfied, he sent her nearly \$5oo a month. Though they never met, never even talked on the phone, he wrote her long letters by hand encouraging her studies and advising her on finances and sent her novels, newspaper clippings and a J. K. Rowling commencement address for inspiration. He never once mentioned sex. + +Six months later, the man in Louisiana had to cut back on expenses, so Lola began looking for a new source of income to supplement the \$8 an hour she earned working in a lab and the cash she picked up cleaning houses and selling her plasma. Last October, Lola and B. K. had their first date. + +Though petite, Lola seems older than she is, maybe because she is so matterof-fact in her manner. On the day I met her, on her way to meet B. K., she was wearing jeans, a striped T-shirt and no makeup. Her hair was pulled back, nononsense style, making her look more as if she were about to go camping than rendezvous with her sugar daddy. She brought along a textbook and her GRE vocabulary flashcards, in case B. K. was late. + +"At first, it was a job, then it became a pleasant job and then it was getting together with a friend," she said, describing her relationship with B. K. "With him, I don't feel like a prostitute, though maybe I am. It's not just the sex with us. We care about each other, we talk, there's a connection, not just business." + +Whether sugar relationships amount to prostitution is hotly debated among the site's members. "Let's get real here," wrote GoldenGate on the blog. "I'm with a guy who's old enough to be my dad, short and balding. Not to mention his other shortcomings, ahem. But he gives me a great big fat allowance every month. If that wasn't there, we wouldn't be together." + +Others on the blog were shocked, saying they could never be with a man, even a rich one, if they weren't somehow attracted to him. Indeed, most go to considerable effort to distinguish between "sugar" and prostitution. (Legally, at least, they are right; since the 1970s, courts have ruled that as long as the woman is paid for some service besides sex — housecleaning, companionship — the arrangement is not the equivalent of prostitution.) They say being a sugar baby is no more an occupation than dating is, especially when the goal of dating is to find a rich boyfriend or a wealthy husband. They routinely turn down creeps interested in nothing but sex. + +Some sugar babies also insist that wives who stay in miserable marriages for an American Express black card, mansion or country-club membership are more like prostitutes than they are. And yet the blatant financial transactions leave many uneasy. Even Seeking Arrangement's chief executive uses a fake name his legal one is Brandon Wey — partly because he's afraid his association with the site might dampen his chances of raising capital for a more mainstream enterprise in the future and partly because he thought the name Brandon Wade sounded more Hugh Hefneresque. + +In interviews and on the blog, the site's members parse the nuances of the sex and money transactions. "I read on a post about asking iok if you're model material.. . so because I ask for so little, am I 'on sale'?" wrote one woman. "I don't think I can accept more than ik a month plus gifts, because then I will start feeling compelled to do ANYTHING for him." + +E. C., a 23-year-old sales-and-marketing coordinator in Toronto, says she already earns \$40,000 a year as well as commission and the use of a company car. But having grown up in a wealthy family, her current salary doesn't allow her to live in the manner to which she's accustomed. So E. C. dined with a banker from the site who was charming and attractive. His breath, however, was so bad she decided he wasn't sugar-daddy material. + +Then she met a charming 43-year-old businessman from the site with nice breath. She tried to steer their conversations to the question of an allowance, unsuccessfully. On their third date, they slept together. Afterward, she was glad no money had changed hands. "If he'd given me money after that, I would have felt he was paying me for the sex," she said. "And if he'd paid me beforehand, I would have felt I owed him something, and the whole thing would have gone from charming to being bought." Instead of paying her, he takes her to swank restaurants and penthouse suites in Niagara Falls. "He shows me off to the whole place, and it makes me feel good." + +Her parents, she added, would be appalled if they knew she was on such a site — except if they thought it increased her chance of meeting an eligible and rich young doctor. + +MOST PEOPLE WOULD LIKELY BE appalled to learn that a daughter — or father — was using SeekingArrangement.com. Beth M, a Temple University historian of courtship, said that her first reaction to the site was "revulsion." But when she reconsidered it within the historical context of dating, she had a somewhat different response. + +Heterosexual relationships, including marriage, have long involved economic transactions, but points out that when men provided financial security, they traditionally did so in exchange for a woman's sexual virtue (and potential to bear and rear children), not for sexual thrills. For that, they often turned to prostitutes and mistresses, involving a more money-for-sex exchange. It's only in the last century that money has been traded — albeit indirectly — for sexual attention from "respectable" unmarried women. In the early 19oos, courtship shifted from girls' porches or parlors to a commercial venture: a date. Etiquette manuals of the time were explicit — boys were to pay for meals, entertainment and transportation, and in return, girls were to provide wellgroomed company, rapt attention and at least a certain amount of physical affection. His money bought not only companionship but also her indebtedness. + +"It made a lot of people uneasy, because if men's money was central to the dating relationship, what distinguished it from prostitution?" says. Seen in this context, argues, Seeking Arrangement "is a piece of contemporary society. It's simply more explicit and transparent about the bargains struck in the traditional model of dating." + +Though one-quarter of the site's sugar daddies (including married ones) are looking for male "babies" and t percent of the site's members are "sugar + +mommies," they still tend to fall into traditional roles, where the one who is paid supplies sex, admiration, comfort and the kind of status conferred by any other expensive consumer good. The "baby" is the one who regulates her appearance, schedule, behavior and emotions to make the payer feel special. + +Still, a 22-year-old named Mercedes told me, "I don't see how people can view this as exploitation." Mercedes is a junior who pays her own tuition at a Georgia university. She has had six sugar daddies in the past year to supplement her wages busing tables and washing dishes at a bar. "I could go out and work three jobs and still go to school and probably make decent grades, but is that really what I want to do? I make more money this way, and I have a lot more fun because I get to go out to concerts, go shopping, see movies and make money off of it. If instead of this I was just dating a rich guy, it'd he almost the same thing, and society wouldn't look down on that. You know with a sugar daddy that they're spending a lot of money on you and they clearly want something in return, but is that really any different than how it is with a boyfriend?" + +BRANDON WEY GOT THE IDEA for the site from his own dissatisfying love life as an M.I.T. student and then as a well-off but awkward tech executive. Traditional dating Web sites were no help. "It was difficult to advertise the assets I had compared to hundreds of thousands of guys who had better looks or better pickup lines," says Wey, now married to a woman 13 years younger than he is, whom he met before the site went live. "I needed to find a way to put myself at the front of the line." + +Wey unveiled SeekingArrangement.com in 2006 and aimed to keep the site well stocked for his wealthy customers. Babies can join free, while daddies pay \$44.95 a month — and an optional \$5 to ensure the site's name doesn't show up on credit-card statements. For another \$1,200 a year, a sugar daddy can become a Diamond Club member, with his income and net worth verified and his profile featured at the top of the home page. + +B. K. joined the site about a year ago, swapping flirtatious e-mail messages with potential sugar babies, taking a few out to dinner and romancing one for a few months before he found Lola. He was drawn, he said, to her independence and intellect, her humility, her academic determination and, of course, her looks. He loved their time together — dancing, snuggling, the whole bit — and, at times, feared he was falling in love. + +From the start, Lola was clear that her heart lay elsewhere. Her boyfriend of four years lives 1,000 miles away, and though they see each other only a few times a year, Lola maintains that she is deeply in love with him. When B. K. asked Lola what gift she wanted for Christmas, she demurred, but when pressed, she asked if he would pay for plane fare to visit her boyfriend. B. K. said yes — and felt great about it. "Isn't that what love is?" he told me later. "It's not about trying to own someone." + +While Lola was gone, B. K. sent her e-mail and text messages virtually every day but heard nothing back. Pining, he began trolling the site, window shopping, and noticed Lola had logged on. He feared that she was looking to replace him. "I was like, What the hell is this?" He e-mailed her, asking why she was on the site, but got no answer. "Maybe I'm the needy one," he mused. He wondered if Lola was trying to end their relationship or if her boyfriend had found out. "The nostrings-attached assumption is hard on my heart sometimes, but I don't think she will just disappear." + +RELATIONSHIPS BETWEEN RICH men and kept women have been around for a very long time, of course, but the Internet makes hunting for such arrangements easier. Quickly and privately, a well-off man can find a young woman wherever in the world he wants. And he can find someone who fits his needs, however unconventional they may be. + +One sugar daddy whose screen name is ■ **has tried long-term girlfriends, mistresses, prostitutes and a brief marriage. Now single, the 39-year-old entrepreneur has found the arrangement that suits him best: a monogamous business-associate-with-benefits deal in which he pursues an entrepreneurial project with a young, beautiful, intelligent woman. He provides financial backing, mentoring and networking; she provides sex, fun and, inevitably, a bit of worshiping, all of which make him feel virile and influential. In between vacations using his private jet, both work hard on the project. They don't tend to see each other much, as he travels frequently for his work.** + +**profile on Seeking Arrangement is audacious. He advertises for a woman who is "drop-dead beautiful, sexy, fun and elegantly mannered in a fancy setting. She must turn heads ... and make me the envy of the crowd." He wants no tattoos, no cosmetic implants, no vegetarians and no Gen Yers who begin their e-mail-message sentences with lowercase letters.** + +When I asked to chat in person, ■ **suggested meeting at CORE, a private Manhattan club where membership is by invitation only and costs \$65,000 the first year and where assent was required before I could be admitted. Sitting alone at a long conference table in a room set aside for him, he looked utterly unremarkable, a man of average height with a buzz cut and an aloof air. But once got talking, he became affable and witty, especially as he described his unorthodox history with women. He started college when most kids his age were still in middle school. "When you go to college at that age, you're pretty undatable," he said. "I was somewhere between a curiosity, a mascot and a friend. I tutored freshman physics and calculus so I could at least be near women. Of course, all they'd do is talk about their boyfriends."** + +**He has an almost mathematical approach to assessing relationships, and once even computed the costs for a girlfriend, mistress, prostitute and wife mistresses turn out to be most expensive by the hour; wives, by the year; girlfriends are cheapest all around. But he's not as calculating as he seems. In fact, he concluded there's little correlation between cost and quality. Still, he is relentlessly searching for an algorithm that will predict relationships' success.** + +■ **is also more determined than most to try separating a sugar baby's affection and the money she's paid to provide it. In his arrangements, he says, he establishes a trust in the woman's name that pays a monthly stipend of at least \$5,000 for the length of their contract. If the woman decides to quit sleeping with him at any point, he may quit serving as adviser and pamperer, but the stipend continues regardless. "If I didn't do that, then it's like a leash I'm putting on somebody, and that seems really unfair," he said. "Besides, then I'd never know what the relationship was really about."** + +**runs these relationships with an explicit business plan, a set budget, measurable goals and quarterly reviews. From the outset, the contract has an end date. It's a brilliant, if contrived, way to protect his pride. The contract specifies that the romance and sex are to end by the preset date, so there's no break up, no rejection, no bruised ego. She's not dumping him; the gig's just over.** + +**He was involved in three relationships this way, helping the women establish a school overseas, start a tech company and help run a nonprofit, he told me. He declined to put me in touch with the women but said each had been successful. He is like Pygmalion, smitten with his own creations.** + +He found those three women through word of mouth, long before he discovered Seeking Arrangement and its rush of possibilities. Between November and shortly after I met him in mid-January, he had winnowed down 14o candidates to four finalists. "It feels so good to have so many people paying attention to me," he said. He met all four, interviewed them extensively, coached them on their business plans and took two of them on multiday outings. In each case, he told them he preferred to put off sex until he'd settled on a candidate, though he did end up sleeping with one of them — but only, he says, because she so aggressively pursued him. + +NOR ARE MEN THE ONLY ONES seeking relationships within particular parameters. A. B. was 18 when she first went on the site, in 2006, looking for extra money. She had started college at 15 but quit when her money ran out. She was soon contacted by a well-to-do, married filmmaker whom she liked immediately. He encouraged her ambition to become a professor of art or philosophy. For a few months, they saw each other frequently, visiting museums, discussing Camus and Nietzsche, taking in films, sharing their poetry and artwork and sometimes romping in bed. He gave her \$500 each time they met, whether or not they had sex. In between visits, he sent her money for art supplies. He said if she got a part-time job, he'd pay the tuition and living expenses she couldn't cover. + +Ecstatic, A. B. re-enrolled at her Southern college. Her sugar daddy flew her up to Pennsylvania to meet him a few times. But he became increasingly peeved that she also had a boyfriend at school. And though her boyfriend understood why she was in a relationship with a sugar daddy, A. B. felt compromised, as if she were leading two lives. She ended that Seeking Arrangement relationship. + +About two years later, A. B. met another sugar daddy from the site, a single father who seemed pleasant enough but unlikely to entangle her emotions. Still, after a few visits, he wanted nothing but sex, so she stopped seeing him. + +"When these sugar-daddy relationships go the way I think they should go, the lines are pretty blurry between that and a typical boyfriend-girlfriend relationship," she said. "And when they go the way I don't think they should go, the lines are blurry between that and sex work." + +In February, A. B. met a third benefactor. This one was a pleasant and clever psychologist in his 4os. He flew her to San Francisco. They went to jazz clubs and a tony restaurant, talked about philosophy and shared a bed but stayed on their own sides all night. But the next night, after they'd both been drinking, he pressured her into forgoing a condom during sex. "I yielded because I thought that if he came away from the weekend having enjoyed himself, he would be more likely to want to see me again and want to support me," she said. The experience soured her on flagrantly transactional relationships, because she realized the power dynamic would always be lopsided. She is done being a sugar baby, A. B. said, even if it means delaying her education even longer. + +AT TIMES, B. K. DEBATED WHETHER to turn off his Seeking Arrangement profile to honor his relationship with Lola. But whenever communication from her would go dark for a few days, he was glad that his profile was still active. The e-mail messages he got from women were an ego balm. After all, it's not often a man in his 4os is wooed by a former surfer in her 2OS or a 26-year-old model looking for the "finer things in life." + +During the two weeks over Christmas that Lola was incommunicado and B. K. worried that he'd just been dumped, he received a suggestive note from a woman close to his age from another state. She sent him long enticing messages, which boosted his morale. Unlike Lola, she was mercurial and dramatic, and he was drawn by her damsel-in-distress air. He loved feeling like her savior. Neither Lola nor his wife seemed to need saving, just help with tuition (in Lola's case) or with kids and chores (in his wife's case). + +Everything about the woman seemed enticingly dangerous, and B. K. became obsessed with her and told me their interactions were like the "thrill" of running through a burning building and making it out alive. And then it imploded: a combination of hotheadedness, different politics and her resentment that he wouldn't pony up a regular allowance. + +By then, Lola was back at school. She said she'd been out of touch during her visit with her boyfriend because her cellphone battery died. She told B. K. she hadn't bought a charger because she was out of money, even using Target gift cards she received at Christmas to pay for groceries. She reassured him that she wanted to keep seeing him but also reminded him that she had several looming deadlines at school and at the lab where she worked. Delighted that she was still + +in his life, B. K. turned off his Seeking Arrangement profile. But with Lola's packed schedule, their visits dwindled to every other week. It took days for her to respond to his e-mail messages. Even a text message he sent asking "Are you O.K.?" went unanswered for days. + +Eventually, she e-mailed him in her typically even-tempered way: "I am all right. When I don't respond it means I don't have time at the moment and then I forget because I'm running from one place to the next." + +Restless, B. K. switched his profile on. He got a Seeking Arrangement message from a graduate student in her mid-2os who lived just io miles from his office. They met for a quick coffee, long enough for the woman to grab B. K.'s hand and put it on her ripped abs, just to show him what she was made of. He was thrilled by her aggressiveness. Afterward, when he suggested by e-mail that he could pay her \$1,500 a month, she objected that she was worth much more. He decided to play it cool and wait for her to come begging. + +And then in the midst of all that, he got a message from Lola that she could meet him the following Sunday afternoon, after a study session. Upon getting her note, his message to me was effusive: "YAY!!! I'm almost giddy like a schoolboy!!" + +When they finally met in late February, B. K. asked Lola more about her boyfriend than he ever had before. Lola told him she loved her boyfriend and that she hoped he would propose after she graduates later this year. Once engaged, she added, she would stop being a sugar baby. B. K. felt devastated. + +Lola seemed particularly tender in that meeting, he told me. Moved by his deep affection for her, B. K. offered her an extra \$200 to see her boyfriend over spring break. Afterward, he was scared he would soon lose her and also scared at how much his feelings for her had intensified. If she asked him to leave his wife, he told me, he would seriously consider it. + +In the days after their meeting, B. K.'s moods shifted rapidly; he was dreamy one minute, testy or melancholy the next. Then, after weeks of silence, the graduate student with the taut abs e-mailed him, and they agreed to meet at a local bar. "I may be a fool for love, but I'm also practical," he said before going to meet her, adding that, then again, "maybe I am just a big wallet, and I'm getting played on all sides." + +On a weekday evening, B. K. sat in a back booth, waiting for his new potential sugar baby. She showed up in a tight, low-cut blouse and scooted up next to him, he told me, purring that it had all been a misunderstanding and that \$1,500 a month would be just fine. To his delight, she said none of the other men on Seeking Arrangement had impressed her the way he had. B. K. explained that his current sugar baby might soon get engaged and disappear from the scene. At that point, he assured her, he would want to pursue things. She snuggled in closer and told him that she would wait. And then she started kissing and nibbling on his ear. + +Ruth Padawer is an adjunct professor at Columbia University's Graduate School of Journalism. 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AND NATALYA + +Defendant. + +-x + +## DECLARATION OF JOHN E. STEPHENSON. JR. + +I, John E. Stephenson, Jr., declare as follows pursuant to 28 U.S.C. § 1746: + +I. I am an attorney-at-law duly admitted to practice pro hac vice before the Southern District of New York in this matter. I am a partner with the law firm of Alston & Bird LLP, which has an office at 90 Park Avenue, New York, NY 10016. I represent in the above-captioned case. + +2. I submit this Declaration based upon my personal knowledge, information, and belief, in support of Motion to Dismiss the Amended Complaint. + +3. Attached hereto as Exhibit A is a true and correct copy of the May 15, 2017 pre-motion letter that I sent to Plaintiff's counsel. That letter served to identify and discuss the deficiencies in the January 26, 2017 Complaint. + +4. Attached hereto as Exhibit B is a true and correct copy of the April 10, 2009 New York Times article titled "Keeping Up With Being Kept" The article can be accessed online at http://www.nytimes.com/2009/04/12/magazine/12sug,ardaddies-t.html. The last + +time that I accessed the article online was earlier today. + +I declare under penalty of perjury that the above facts are true and correct. + +Executed this 21st day of November, 2017. + +/s/ John E. Stephenson, Jr. John E. Stephenson, Jr. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819916/EFTA02819916.metadata.json b/marker2/court-jane-doe-43/EFTA02819916/EFTA02819916.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ce94c8c9970a8e7d2eec99b1d48565ef3d472441 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819916/EFTA02819916.metadata.json @@ -0,0 +1,143 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819916.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1450, + "elapsed_seconds": 0.81, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 88.12799999999999, + 71.28 + ], + [ + 296.29022216796875, + 71.28 + ], + [ + 296.29022216796875, + 100.10302734375 + ], + [ + 88.12799999999999, + 100.10302734375 + ] + ] + }, + { + "title": "DECLARATION OF JOHN E. 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[REDACTED] + 212 506 3955 + mmiller@steptoe.com + +1114 Avenue of the Americas + New York, NY 10036 + 212 506 3900 main + www.steptoe.com + +**Steptoe** + STEPTOE & JOHNSON LLP + +APPLICATION GRANTED + SO ORDERED + +*John G. Koeltl* + John G. Koeltl, U.S.D.J. + +11/22/17 + +November 22, 2017 + +**SUBMITTED UNDER SEAL** + +Hon. John G. Koeltl + United States District Court + United States Courthouse + 500 Pearl Street + New York, NY 10007-1312 + +Re: **Jane Doe 43 v. Jeffrey Epstein, et al.** +**Civil Action No. 17-cv-616** + +Dear Judge Koeltl: + +We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") in the above-referenced matter (the "Jane Doe Matter"). The Defendants filed yesterday a motion to dismiss the First Amended Complaint filed by Plaintiff Jane Doe ("Jane Doe" and "MTD"). For the reasons set forth, below, the Defendants respectfully request that they be provided with an opportunity to submit a supplemental MTD after the Court issues a confidentiality order in this matter. + +As we previously advised the Court, Jane Doe voluntarily gave deposition testimony and produced documents relating to the allegations in the [REDACTED] Doe Matter in a matter captioned *Giuffre v. Maxwell*, No. 15 Civ. 7433 (RWS) (the "[REDACTED] Matter") (the "Jane Doe Evidence"). The Jane Doe Evidence, given by Jane Doe shortly after she filed the Jane Doe Matter, was designated as Confidential pursuant to the Protective Order in the *Giuffre Matter* ("Protective Order"). Specifically, Jane Doe and the parties to the in the *Giuffre Matter*, the plaintiff, [REDACTED] and the defendant, Ghislaine Maxwell, all designated Jane Doe's deposition transcript as Confidential, and Jane Doe designated her document production as Confidential. Jane Doe and the plaintiff in the [REDACTED] Matter both subsequently withdrew their confidential designation of Jane Doe's deposition transcript "in its entirety," and objected to the confidential designation of that transcript by the defendant in that action. + +1 Jane Doe's more recent conduct is entirely consistent with her decision to withdraw this confidential designation and calls into question whether she should be permitted to continue to proceed in this matter behind a "Jane Doe" caption. Indeed, on November 15, 2017, Jane Doe (Continued...) + +Hon. John G. Koeltl +November 22, 2017 +Page 2 + +**Steptoe** +STEPTOE S LLP + +The Jane Doe Evidence, as it turns out, is dispositive of this action. In particular, the Jane Doe Evidence demonstrates that the sole claim asserted in the *Jane Doe Matter* is barred by the longest potentially applicable ten-year statute of limitations, the Court in the *Jane Doe Matter* lacks personal jurisdiction over Defendants, and Jane Doe cannot plead a legally sufficient amended complaint. + +On October 5, 2017, and pursuant to directions from this Court, the Defendants filed a motion before Judge Robert W. Sweet seeking a modification of the Protective Order to permit the Defendants to use *all* of the Jane Doe Evidence in support of the MTD ("Motion to Modify"). On October 19, 2017, Plaintiff responded to the Motion to Modify by agreeing to permit the use of only some, but not all, of the Jane Doe Evidence. Ghislaine Maxwell, the defendant in the *Giuffre Matter*, advised the Court that she took no position on the Motion to Modify and requested only that Jane Doe's deposition transcript be treated as confidential pursuant to a protective order to be issued in the *Jane Doe Matter*. + +Through Maxwell's submission, the Defendants learned for the first time that, on May 5, 2017, Jane Doe and Giuffre withdrew their confidential designations of Jane Doe's deposition transcript. Their withdrawal is memorialized in a joint letter filed by their joint counsel in the *Giuffre Matter* – the same lawyers who represent Jane Doe in the *Jane Doe Matter*. See Exhibit B attached. Surprisingly, Jane Doe never advised the Defendants of her and Giuffre's withdrawal of their confidential designations. On May 25, 2017, the *Giuffre Matter* was concluded and dismissed. + +On November 14, 2017, Judge Sweet issued a Sealed Opinion on the Motion to Modify. See Exhibit C attached. Judge Sweet noted that Jane "Doe and the Plaintiff [Giuffre] withdrew their confidential designation of the [Jane] Doe Evidence on May 5, 2017, but the Defendant Ghislaine Maxwell ... objected" to the non-confidential treatment. Opinion at 3. Judge Sweet then made the following rulings: + +First, Judge Sweet held that the Jane "Doe Evidence at issue" is no longer subject to the [Protective] Order." Opinion at 6. Judge Sweet explained that "the purpose of the Protective Order was to guide the confidentiality determinations during the discovery process, and not beyond this point." *Id.* at 7. As a result, the "Protective Order did not extend beyond the completion of discovery or the termination of this action." *Id.* + +Second, Judge Sweet held that "absent other arrangements a [REDACTED] upon regarding the disposal of the protected information, and this Court was informed of no such arrangements, on + +published a letter to the editor of the New York Times in her own name in which she identified herself as the plaintiff in the *Jane Doe Matter*. See Exhibit A attached. + +Hon. John G. Koeltl November 22, 2017 Page 3 + +![](_page_2_Picture_2.jpeg) + +May 25, 2017, all protected information, including the Jane Doe Evidence, was to be returned to the original party, parties, non-party, or non-parties who designated it as confidential." Opinion at 7-8. + +Lastly, Judge Sweet held that a "party or non-party is deemed a designator of confidentiality if, on the date of this matter's termination, i.e., May 25, 2017, that party or nonparty was deemed the confidentiality designator of ument, information, or piece of material." Opinion at 8. Since both Jane Doe and withdrew their confidentiality documents used during the deposition, is Maxwell. + +Counsel for Maxwell has now advised the Defendants that Maxwell agrees that Defendants need not return the deposition transcript, including the documents used during the deposition, and that this evidence may be used in the Jane Doe Matter, provided that this evidence is used pursuant to a confidentiality order. See Exhibit D attached. + +In order to comply with the seven-day filing deadline directed by the Court, Defendants have filed their MTD yesterday. This version of the MTD does not contain references to the lane pQeidepositinn.at relgted eiSsittsc we cict aot-yctitayeiticsOnigkeut4ty in crendapu will work siitigpntly proMptly submit a joint draft pOnfitigarpility order to the Court iti accordance with tho arcanc4Lent advanced by MaxWell and pcolpfscui with teses:I y Opinion. • We respectfully rpaiteat tb.,3t thp court Pm\*\* RPfendatSti t9 fifq g PuPPIciPenin). MTD whieft references the OCatte110 of flu Jane Oct dePasitina and dope eats used rthrhagtthat fleAs4j9P within niten (7) 0#Y8 f9119wtn8 nntrY 04 P0AfidCPtialikos nar su this mattex• + +We have attempted to contact counsel for lane Doe is Qat; to Ohtak his consent to this trAiierq, kit have not 49p,o4 Eck Huai, • + +apPectiralW stub + +Michael C. Coto\*, for Defendants Jeffrey Epsield'and Lesley Groff + +2 We will also attempt to reach agreement with Jane ppe.tesamlittg th\* balance (tithe • Jane Doe Evidence that was confidential but was pot-well at Jane Doe's deposition. ctir + +# EXHIBIT A + +![](_page_3_Picture_13.jpeg) + +![]()![](_page_4_Picture_20.jpeg) + +![](_page_4_Picture_21.jpeg) + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +# EXHIBIT B + +![](_page_7_Picture_26.jpeg) + +Meredith [REDACTED] Esq. +mschultz@bsflip.com + +May 5, 2017 + +VIA E-MAIL + +Laura Menninger, Esq. +HADDON, MORGAN AND [REDACTED], P.C. +150 East 10th Avenue +Denver, Colorado 80203 +menninger@hmflaw.com + +Re: [REDACTED] v. Maxwell +Case No. 15-cv-07433-RWS + +Dear Ms. Menninger, + +Pursuant to paragraph 3.1 of the Protective Order (DE 62), this letter hereby informs you of Ms. Guffre's withdrawal of her confidentiality designation of Ms. Ransome's deposition transcript in its entirety, as well as Ms. Guffre's objection to Defendant's confidentiality designation of Ms. Ransome's deposition transcript in its entirety. Ms. Ransome joins [REDACTED] in objecting to any confidentiality designations over her deposition transcript. + +Sincerely, + +Isl Meredith [REDACTED] + +Meredith [REDACTED], Esq. + +MS/akc + +DES SCHULTZ FLEXNER LLC + +# EXHIBIT C + +[Faint, illegible text lines] + +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK + +-----X +[REDACTED], + +Plaintiff, + +15 Civ. 7433 + +-against- + +SEALED +OPINION + +GHISLAINE MAXWELL, + +Defendant, + +-----X +APPEARANCES: + +Counsel for Virginia Ginfire + +BOIES, SCHILLER & FLEXNER LLP +401 East Las Olas Boulevard, Suite 1200 +Fort Lauderdale, FL 33301 +By: Sigrid S. McCawley, Esq. +Meredith L. [REDACTED], Esq. + +Counsel for Ghislaine Maxwell + +HADDON, MORGAN AND [REDACTED], P.C. +150 East Tenth Avenue +Denver, CO 80203 +By: Laura A. Menninger, Esq. +Jeffrey S. Pagliuca, Esq. + +Counsel for Jeffrey Epstein and Leslie Groff + +STEPTOE & JOHNSON LLP +1114 Avenue of the Americas +New York, New York 100036 +By: Michael C. Miller, Esq. +Justin Y.K. [REDACTED], Esq. +Michael A. Keaugh, Esq. + +Sweet, D.J. + +Third-Party Proposed Intervenors Jeffrey Epstein and Lesley Groff (the "Intervenors") have moved under Fed. R. Civ. P. Rule 24(b) to intervene in this action and to modify the protective order entered in this action on March 17, 2016 (the "Protective Order" or the "Order"). See Fed. R. Civ. P. 24(b); Order, ECF No. 62. Intervenors are two of the defendants in an action captioned *Jane Doe 43 v. Epstein*, No. 17 Civ. 616 (JGK), currently pending before the Honorable John G. Koeltl (the "Jane Doe action"). Intervenors seek through the instant motion to modify the Protective Order to permit Intervenors to use all evidence produced by Non-Party Jane Doe 43 ("Jane Doe" or "Doe") in this action concerning her alleged interactions with the Intervenors (the "Jane Doe Evidence" or the "Evidence"), including deposition testimony and documents, to assist them in preparing a Motion to Dismiss in the Jane Doe action. + +Based upon the conclusions set forth below, the motion to intervene is granted, and all documents, materials, and information subject to the Protective Order must be returned to the party who designated its confidentiality as of the date this action was dismissed. + +## I. Prior Proceedings + +This action was commenced on September 21, 2015 by [REDACTED] ("[REDACTED]" or the "Plaintiff"). On March 17, 2016, the Court entered into a Protective Order to maintain the privacy of the parties and deponents during the pendency of discovery. Pursuant to the Order, the parties and non-parties, including Doe, designated certain documents, materials, deposition testimony, and other information confidential. Doe was a fact witness and deponent in this action, and provided both deposition testimony and documents, which were designated confidential by the Plaintiff and Doe under the terms of the Protective Order; Doe and the Plaintiff withdrew this confidential designation of the Doe Evidence on May 5, 2017, but the Defendant Ghislaine Maxwell ("Maxwell" or the "Defendant") objected. See Maxwell Letter, Exs. A & B: This action was settled and dismissed with prejudice pursuant to a joint stipulation for dismissal entered into on May 25, 2017. + +On January 26, 2017, Doe filed the Jane Doe action against Jeffrey Epstein and others (the "Epstein Defendants") alleging commercial sex trafficking in violation of 18 U.S.C. § 1595. Intervenors plan to move to dismiss the Jane Doe action, and sought to use the Jane Doe Evidence, which had been [REDACTED] + +confidential pursuant to the Protective Order, in support of that Motion to Dismiss. Jane Doe sought to bar the use of certain material, and Judge Koeltl instructed the Intervenors to "make their application for relief from the Protective Order to the Judge in the case in which the Protective Order was entered," and to attempt to agree with Doe and [REDACTED] on the scope of the proposed modification. See Intervenors' Br. Ex. B. Jane Doe and [REDACTED] agreed to the release of Doe's deposition transcript and fifty-six (56) documents, but sought to bar the use of a collection of photographs and a series of 2016 email communications between Doe and a reporter, the status of which is now the subject of the instant motion. This motion was heard and marked fully submitted on November 8, 2017. + +## II. The Protective Order + +The Protective Order provided confidentiality for documents, materials and/or information so designated by the parties, together with procedures relating to the designations and any challenges to the designations among other provisions. See Order, FCF No. 62. The Order also provides that it would have no effect on the use of confidential information at trial. The Order stated, in relevant part: + +1. This Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. + +I. . . + +12. At the conclusion of this case, unless other arrangements are agreed upon, each document and all copies thereof which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL documents. Where the parties agree to destroy CONFIDENTIAL documents, the destroying party shall provide all parties with an affidavit confirming the destruction. + +13. This Protective Order shall have no force and effect on the use of any CONFIDENTIAL INFORMATION at trial in this matter. + +### III. The Motion to Intervene is Granted + +Pursuant to Fed. R. Civ. P. Rule 24(b), the Court may permit a non-party to intervene where the non-party has "a claim or defense that shares with the main action a common question of law or fact," and the court "consider[s] whether the intervention will unduly delay or prejudice the adjudication of the original parties' rights." Fed. R. Civ. P. 24(b); see also [REDACTED] v. Maxwell, November 2, 2016 Sealed Opinion on Motion to Intervene for Alan B. Bershowitz; [REDACTED] v. Maxwell, No. 15 + +Civ. 7433 (RWS), 2017 WL 1787934 (S.D.N.Y. May 3, 2017) +(granting permissive intervention for Michael Cernovich). + +The Jane Doe Evidence at issue relates directly to the facts alleged by Doe in both the Jane Doe action and this action relative to Doe's purported relationship with the Intervenors sufficient to satisfy the Rule 24(b) requirement. Accordingly, the motion to intervene is granted. + +**IV. All [REDACTED] Parties Subject to the Protective Order Must be Returned to the Designating Party or Destroyed** + +The Intervenors argue the Protective Order should be modified to permit their use of all Jane Doe Evidence in support of their Motion to Dismiss in the Jane Doe action. Doe and [REDACTED] contest this modification arguing the documents in dispute have no bearing on the Epstein Defendants' arguments in their Motion to Dismiss, and alleging that the Intervenors merely seek to use the Jane Doe Evidence in a public filing in order to publicly numiliate and intimidate Doe. While the parties dispute the reasons for and against modification of the Order and the scope of such a modification, the Doe Evidence at issue is no longer subject to the Order. + +The specific language of the Protective Order, as well as the underlying reasons for its issuance, establish that certain actions were to be taken "[a]t the conclusion of thi case" regarding the ultimate disposition of the protected information. See Order, 1 12. Paragraph 12 of the Order star lsi + +At the conclusion of the case, unless other arrangements are agreed upon, each document and all copies thereof which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL documents. Where the parties agree to destroy CONFIDENTIAL documents, the destroying party shall provide 411 parties with an affidavit confirming the destruction. + +Id. Moreover, paragraph la and the Otter's introductory language establish that the purpose of the Order was to guide OW444;:a4CCii4 Pitloe4i; and not beyond ttlie P9L4t, int 9rder, 1 la ("fag Protective Q shall have oo force and effect on the use of.any csma4pENTI INFORMATION et trial in this matter."). The Protective Orde4 did . • not extend key n4 the RIPEleciork pf 444c9YP,FY 8r beyond the termineciop of thla .74;49.q. + +Accordin9ly, ab4ent "other arrangements . . agreed upon" regarding fhf:dis?osal of the protected ;information, and this Court was informed of no such arrangements; on Hay 25,i 2017, all protecfeVAnfo#M4tion, tholudAngtheJane Doe ;•-t Evidence, was tg ht tet4rped to the original party, parties, + +• , . + +non-party, or non-parties who designated it as confidential.1 See id.; cf. *In re Agent Orange Prod. Liab. Litig.*, 821 F.2d 139, 145 (2d Cir. 1987) (holding that the court did not abuse its discretion, even where it modified a term of the settlement agreement, by lifting the protective order). + +A party or non-party is deemed the designator of confidentiality if, on the date of the matter's termination, i.e., May 25, 2017, that party or non-party was deemed the confidentiality designator of the document, information, or piece of material. Moreover, where a document, information, or piece of material, was deemed confidential by multiple parties, such as a deposition transcript, the protected information must be returned to all designators. + +#### V. Conclusion + +Based on the facts and conclusions set forth above, the Intervenors' motion to intervene is granted, and the motion to modify the Protective Order is denied. Pursuant to paragraph + +1 At the termination of the case, the parties also obtained permission, by way of paragraph 12 of the Order, to destroy any or all confidential documents. However, without any affidavits provided to the Court stating this effect, and in light of the present dispute, the Court infers that such action was not taken. + +12 of the Order, all documents, materials, and information subject to the Protective Order have been, or will be returned to the party who designated its confidentiality. + +It is so ordered. + +New York, NY +November 14, 2017 + +![]()REDESCRIBE W. SWEET +U.S.D.J. + +# EXHIBIT D + +![](_page_19_Picture_23.jpeg) + +HADDON +MORGAN +FOXEMAN + +Haddon, [REDACTED] and [REDACTED] rc +Jeffrey S. Pagliuca + +150 East 10th Avenue +Denver, Colorado 80203 +PH 303.831.7364 FX 303.832.2628 +www.hmflaw.com +jpog@uco@hmflaw.com + +November 21, 2017 + +VIA EMAIL + +Justin Y.K. [REDACTED] +Steptoe & [REDACTED], LLP +1114 Avenue of the Americas +New York, NY 10036 +jchu@steptoe.com + +Re: [REDACTED] v. Maxwell: Deposition Transcript of [REDACTED] +with Attached Exhibits + +Dear Mr. [REDACTED] + +As a result of Judge Sweet's order of November 14, 2017 we understand that Ms. Maxwell is the only individual that maintains the confidentiality designation of [REDACTED] deposition and the related exhibits. ("the Confidential Information"). You have requested that your clients be permitted to use portions of the confidential information in support of his Motion to Dismiss the Complaint in *Jane Doe 43 v. Epstein et al*, Case No. 17-cv-00616-JGK ("Jane Doe 43 v. Epstein"). + +We have no objection to the use of the confidential information under the following conditions: + +1. 1. Use of the confidential information by your clients is limited to the Motion to Dismiss, and any related reply in in *Jane Doe 43 v. Epstein*. +2. 2. Dissemination of the confidential information is restricted to the parties in *Jane Doe 43 v. Epstein*, the parties' lawyers who have entered their appearance in the action, and the Court. +3. 3. Any use of the confidential information in connection with the Motion to Dismiss in *Jane Doe 43 v. Epstein* will be under seal and not accessible to the public. You agree to redact any confidential information from any motions or pleadings and submit any portions of the confidential information used as an exhibit as sealed documents. + +Justin Y.K.E November 21, 2017 Page 2 + +- 4. Prior to your use of the confidential information you will request and obtain a Protective Order from the Court in Jane Doe 43 v. Epstein that limits and restricts the use of the confidential information to the terms in paragraphs 1-3 above. +- 5. We have no objection to any of the other panics using the confidential information in connection with the motion to dismiss the complaint in Jane Doe 43 v. Epstein if they so request, so along as the evidence is used pursuant to the terms stated above. +- 6. If the Jane Doe Matter proceeds beyond the motion to dismiss stage, we are open to permitting the use of the evidence for the remainder of the case, subject to an agreed upon Protective Order. + +If you have any questions or concerns t g this matter, please feel free to contact me. + +• + +Very Truly; Yours, • 4. •••• ...To. 4...••••• •••• ..,•••••••• •••.. • . + +. • • + +• + +• • • • I • f ez a ••••-••••• + +• o " • • • + +HA.4/W114 FQ.41.4A.V, + +3S + +• • • \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819918/EFTA02819918.metadata.json b/marker2/court-jane-doe-43/EFTA02819918/EFTA02819918.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e4af892cc78cfd7e201f31fc8830b4e0bd65f51d --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819918/EFTA02819918.metadata.json @@ -0,0 +1,963 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819918.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 21, + "chars": 21394, + "elapsed_seconds": 58.84, + "image_assets": [ + "_page_2_Picture_2.jpeg", + "_page_3_Picture_13.jpeg", + "_page_4_Picture_20.jpeg", + "_page_4_Picture_21.jpeg", + "_page_7_Picture_26.jpeg", + "_page_19_Picture_23.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "SUBMITTED UNDER SEAL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.154, + 230.84999999999997 + ], + [ + 224.72399999999996, + 230.84999999999997 + ], + [ + 224.72399999999996, + 244.61999999999998 + ], + [ + 68.154, + 244.61999999999998 + ] + ] + }, + { + "title": "EXHIBIT A", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 176.218, + 307.79999999999995 + ], + [ + 432.256, + 307.79999999999995 + ], + [ + 432.256, + 353.96999999999997 + ], + [ + 176.218, + 353.96999999999997 + ] + ] + }, + { + "title": "EXHIBIT B", + "heading_level": null, + "page_id": 6, + "polygon": [ + [ + 178.67399999999998, + 309.42 + ], + [ + 432.86999999999995, + 309.42 + ], + [ + 432.86999999999995, + 351.53999999999996 + ], + [ + 178.67399999999998, + 351.53999999999996 + ] + ] + }, + { + "title": "EXHIBIT C", + "heading_level": null, + "page_id": 8, + "polygon": [ + [ + 177.44599999999997, + 308.61 + ], + [ + 434.712, + 308.61 + ], + [ + 434.712, + 353.96999999999997 + ], + [ + 177.44599999999997, + 353.96999999999997 + ] + ] + }, + { + "title": "-----X APPEARANCES:", + "heading_level": null, + "page_id": 9, + "polygon": [ + [ + 96.39799999999998, + 328.05 + ], + [ + 241.916, + 328.05 + ], + [ + 241.916, + 340.2 + ], + [ + 96.39799999999998, + 340.2 + ] + ] + }, + { + "title": "I. 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b/marker2/court-jane-doe-43/EFTA02819939/EFTA02819939.md @@ -0,0 +1,47 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, + +LESLEY GROFF and + +NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +## NOTICE OF CHANGE OF FIRM AFFILIATION AND ADDRESS + +PLEASE TAKE NOTICE that counsel for the Plaintiff, J. is now a member of the firm of POTTINGER LW all future pleadings, memoranda, correspondence, orders, etc., shall be sent to the following address. + +> POTTINGER LLC 425 Nom ANDREWS AVENUE, SUITE 2 Fort Lauderdale, Fl 33301 Tel: (954)524-2820 FAX: (954)524-2822 Primary E-mail: ecf@epllc.com Secondary E-mail: brad@epllc.com Secondary E-mail: maria@eplIc.com + +Plaintiff's Counsel is no longer affiliated with the firm JAFFE WEISSING FISTOS & LEHRMAN. + +Dated: November 27, 2017 Respectfully submitted, + +POTTINGER LLC + +J. + +425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: brad@epllc.com Attorney for Plaintiff Jane Doe 43 + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on the 27th of November, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. + +Kimo S. Peluso Sher Tremonte, LLP 90 Broad Street, 23nd Floor New York, NY 10004 kpeluso@shertremonte.com + +Counsel for Haddon, P.C. + +Laura A. Menninger, Esq. Jeffrey Paglitifi as i HADDON, & 150 East 10 Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com , P.C. + +Michael C. 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoie.com Counsel for Defendants, Jeffrey Epstein and Lesley Groff + +/s/ \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819939/EFTA02819939.metadata.json b/marker2/court-jane-doe-43/EFTA02819939/EFTA02819939.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9e9d8a6636bfe9e6844a9d43647a29aa4d6833bb --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819939/EFTA02819939.metadata.json @@ -0,0 +1,170 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819939.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1806, + "elapsed_seconds": 0.95, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 190.94400000000002, + 73.71000000000001 + ], + [ + 416.2574768066406, + 73.71000000000001 + ], + [ + 416.2574768066406, + 104.2330322265625 + ], + [ + 190.94400000000002, + 104.2330322265625 + ] + ] + }, + { + "title": "NOTICE OF CHANGE OF FIRM AFFILIATION AND ADDRESS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 131.57999999999998, + 268.92 + ], + [ + 480.9340515136719, + 268.92 + ], + [ + 480.9340515136719, + 284.2330627441406 + ], + [ + 131.57999999999998, + 284.2330627441406 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 223.38, + 85.05 + ], + [ + 388.9223937988281, + 85.05 + ], + [ + 388.9223937988281, + 100.10302734375 + ], + [ + 223.38, + 100.10302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 16 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 30 + ], + [ + "Text", + 6 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819939" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819941/EFTA02819941.md b/marker2/court-jane-doe-43/EFTA02819941/EFTA02819941.md new file mode 100644 index 0000000000000000000000000000000000000000..ddbc95354f0609f5261fdaa763dabf955ca23671 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819941/EFTA02819941.md @@ -0,0 +1,35 @@ +![](_page_0_Picture_1.jpeg) + +![](_page_0_Picture_2.jpeg) + +Florida Office + +J. 'Of Seth M. Lehrman "I-Brittany N. Matthew D. Weissing + +> Honorable John G. Koeltl Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +POTTINGER LLC + +425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 + +Telephone (954)524-2820 Fax (954)524-2822 + +November 27, 2017 + +RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, a. Al Case No. No. 17 Civ. 00616 (JGK) + +Dear Judge Koeltl: + +New York Office J. Stanley Pottinger + +t Admitted in California 0 Admitted in District or f:olumbia • Admitted in Florida t Admitted in Na York I Pond C:cteicied Card Trial laa)cr + +This is a letter motion requesting permission for Plaintiff to telephonically appear for the conference, currently scheduled for Tuesday, November 28, 2017, at 3:00 pm. + +Thank you very much for your time and consideration. + +Very Truly Yours, + +POTTINGER LLC + +j. Edwards J. 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Seth M. Lehrman 111- Brittany N. Matthew D. Weissing •f •04 + +> Honorable John G. Koeltl Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +425 North Andrews Avenue + +Suite 2 Fort Iauderdale, FL 33301 + +Telephone (954)524-2820 Fax (954)524-2822 + +November 27, 2017 + +RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, et. Al Case No. No. 17 Civ. 00616 (JGK) + +Dear Judge Koeltl: + +New York Office + +J. Stanley Pottinger + +t Adadool in California 0 Admitted c Maks d Colundsia • Addicted in Rood, j Admitted in New You Baud Camila Onl Mai Lama + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC8 DATE FILED: I k I 2:3119-- + +This is a letter motion requesting permission for Plaintiff to telephonically appear for the conference, currently scheduled for Tuesday, November 28, 2017, at 3:00 pm. + +Thank you very much for your time and consideration. + +Very Truly Yours, + +POTTINGER LLC + +J. APPLICATION GRANTED BJE:mwk SO ORDERED + +John G. Koeltl, U.S.D.J. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819942/EFTA02819942.metadata.json b/marker2/court-jane-doe-43/EFTA02819942/EFTA02819942.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..922f93d299a2a4d05f74c528fb85b5b67669f313 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819942/EFTA02819942.metadata.json @@ -0,0 +1,64 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819942.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1035, + "elapsed_seconds": 1.09, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 101 + ], + [ + "Line", + 47 + ], + [ + "Text", + 22 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819942" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819942/_page_0_Picture_1.jpeg b/marker2/court-jane-doe-43/EFTA02819942/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..4b4832d733b736b7ec97ca3a06918627f543ca0b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819942/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9c3c47c3da84fc94763ed4b7efc21342477bfe82795fc250c225075a165a2d89 +size 6004 diff --git a/marker2/court-jane-doe-43/EFTA02819943/EFTA02819943.md b/marker2/court-jane-doe-43/EFTA02819943/EFTA02819943.md new file mode 100644 index 0000000000000000000000000000000000000000..0311253f0026925cdd8203b1c031daf636e545e7 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819943/EFTA02819943.md @@ -0,0 +1,69 @@ +![](_page_0_Picture_1.jpeg) + +Sigrid S. McCawley, Esq. Telephone: (954) 377-4223 Email: smccawley@bsillp.com + +November 29. 2017 + +## VIA ECF + +Honorable John G. Koeltl Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 + +> Re: Jane Doe 43. v. Epstein, a at Case No.: 17-CIV-00616 (JGK) + +Dear Judge Koeltl: + +We represent Plaintiff Jane Doe 43 in the above-referenced matter. The Defendants Jeffrey Epstein and Lesley Groff (hereinafter referred to simply as "Epstein") will shortly be filing a "supplemental" motion to dismiss, which will include materials from outside the complaint. These materials will be used to bolster the currently-pending motion to dismiss, which alleges (among other things) lack of personal jurisdiction over Epstein. While we believe that the motion to dismiss is meritless for reasons that we will explain in our response, we believe that the issues surrounding personal jurisdiction would be greatly simplified if plaintiff were allowed jurisdictional discovery from Epstein. In particular, Jane Doe 43 believes that if she could take a one-hour deposition (over the phone) of Epstein, the answers obtained in that deposition would immediately establish personal jurisdiction. Accordingly, we write to request such a deposition. + +Epstein has alleged in his currently-pending motion to dismiss that "the Court does not have jurisdiction over the defendants." DE 80 at 23 (capitalization altered). Epstein claims in his motion that that there is a lack of sufficient past or present connection to the Southern District of New York to establish jurisdiction over him. Id. at 23-24. Previously Epstein's counsel resented that Epstein has "no present connection to New York." Letter from Michael C. to Hon. John G. Kcal at 2 (July 14, 2017). + +We believe that a short deposition of Epstein would immediately establish such jurisdiction — including the fact that Epstein has a present connection to New York. For example, Jane Doe 43's First Amended Complaint alleges that Epstein maintains a residence within the Southern District of New York (DE 45 at 2 ¶ 4) and that Epstein used this residence "to facilitate the illegal sex trafficking venture and enterprise described in this Complaint and in furtherance of the venture and enterprise." DE 45 at 4 ¶ 12. A deposition of Epstein would, counsel believe, confirm the accuracy of these representations. + +This Court "has broad discretion to permit the plaintiff to conduct jurisdictional discovery." Tese-Milner v. De Beers Centenary A.G., 613 F. Supp. 2d 404, 417 (S.D.N.Y. 2009) + +Honorable John G. Koeltl November 29, 2017 Page 2 + +(citing Kiobel v. Dutch Petroleum Co., 2008 WL 591869, at \*9 (S.D.N.Y. Mar. 4, 2008)). Indeed, a district court has authority to allow "jurisdictional discovery" to proceed even while a motion to dismiss is pending. See, e.g., Daventree Ltd. v. Republic of Azerbaijan, 349 F.Supp.2d 736, 765 (S.D.N.Y. 2004). + +The jurisdictional discovery that Jane Doe 43 requests is simply for a one-hour deposition of defendant Epstein. The deposition could be conducted over the telephone to minimize inconvenience to Epstein. Jane Doe 43 intends to ask Epstein, among other things, the following questions — and proffers that she has a good faith basis for believe that she will receive the following answers from Epstein: + +| QUESTION | ANTICIPATED ANSWER | +|----------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------| +| Do you have a present connection with the Southern District of New York? | Either "yes" or invocation of Fifth Amendment. | +| Do you own or control corporations with locations in the Southern District of New York? | Either "yes" or invocation of Fifth Amendment. | +| Do you own apartments in the Southern District of New York? | Either "yes" or invocation of Fifth Amendment. | +| Do you currently own a residence in the Southern District of New York? | Either "yes" or invocation of Fifth Amendment. | +| Have you recently visited your residence in the Southern District of New York? | Either "yes" or invocation of Fifth Amendment. | +| Did you use your residence in the Southern District of New York to facilitate an illegal sex trafficking enterprise? | Either "yes" or invocation of Fifth Amendment. | +| How many girls and young women did you sexually trafficking in the Southern District of New York? | Either "dozens and dozens" or invocation of the Fifth Amendment. | +| Did you use your residence in the Southern District of New York to coerce Jane Doe 43 into having sex with you? | Either "yes" or invocation of Fifth Amendment. | +| Did you make threats to Jane Doe 43 to coerce her into have sex with you in your residence? | Either "yes" or invocation of Fifth Amendment. | +| Did you falsely and fraudulently promise things to Jane Doe 43 in order to obtain sex from her? | Either "yes" or invocation of Fifth Amendment. | +| Did you make false and fraudulent representations to Jane Doe 43 after January 31, 2017? | Either "yes" or invocation of Fifth Amendment. | +| Did you make any of the false and fraudulent | Either "yes" or invocation of Fifth | + +![](_page_2_Picture_1.jpeg) + +Honorable John G. Koeltl November 29, 2017 Page 3 + +| representations in your residence in the Southern District of New York? | Amendment. | +|----------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------| +| Please state with particularity the fraudulent representations you made to Jane Doe 43 to secure sex from her? | Either a particular description of the fraudulent representations or invocation of Fifth Amendment. | +| Do have information about how Ghislaine Maxwell is attempting to evade service of process in this case? | Either "yes" or invocation of Fifth Amendment. | + +These anticipated answers are based on counsel's current understanding of the situation. Of course, if our understanding on any of these points is inaccurate, Epstein can simply provide an affidavit — under oath — correcting our understanding. + +The answers to these questions will simplify the Court's task in ruling on Epstein's motion to dismiss. For example, with respect to personal jurisdiction, if Epstein provides the anticipated answers, the jurisdictional issue will disappear entirely. If he invokes the Fifth Amendment, of course the net effect is the same because an adverse inference arises against Epstein. See Baxter v. Paimigiano, 425 U.S. 308, 316-18 (1976). The answers will also be relevant to service of process issues that may appear before the Court again in connection with Ghislaine Maxwell. + +This approach will not burden Epstein. The deposition could be conducted over the telephone at a time mutually convenient to him and to all counsel. Nor will this approach delay this case. As the Court is aware, the final version of Epstein's motion to dismiss has yet to be submitted. The deposition of Epstein could easily be conducted within two weeks, thereby avoiding any delay of the proceedings. + +Counsel for Jane Doe 43 understands from earlier pleadings that defendant Epstein opposes the motion. + +Accordingly, for all these reasons, the Court should allow a one-deposition of Epstein on all issues associated with jurisdiction, including all questions regarding his residence in New York City and his use of that residence for sex trafficking of Jane Doe 43 and others, as well as information about Ghislaine Maxwell evading service of process. + +Sincerely, + +/s Sigrid McCawlev Sigrid S. 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KOELTL, District Judge: + +The plaintiff's time to serve defendant Ghislaine Maxwell is extended to January 5, 2018. By that date, the plaintiff will file either proof of service or a renewed application for alternative service. If the plaintiff files such an application, the defendant's response is due by January 21, 2018. + +If the plaintiff successfully serves Maxwell before January 5, 2018, the time to move or answer is thirty days after service is completed. If the plaintiff instead files a renewed application for alternative service, the time to move or answer is thirty days after the Court's decision on that motion. + +SO ORDERED. + +Dated: New York, New York November 29, 2017 + +John G. Koelti United States District Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819946/EFTA02819946.metadata.json b/marker2/court-jane-doe-43/EFTA02819946/EFTA02819946.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d1cf5d6983937a40213748707e5e3d917f85dabc --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819946/EFTA02819946.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819946.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 961, + "elapsed_seconds": 0.76, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 33 + ], + [ + "Text", + 15 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819946" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819947/EFTA02819947.md b/marker2/court-jane-doe-43/EFTA02819947/EFTA02819947.md new file mode 100644 index 0000000000000000000000000000000000000000..cfd8f632255be17eeb628d265e96abaa9ed04e8f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819947/EFTA02819947.md @@ -0,0 +1,111 @@ +![](_page_0_Picture_19.jpeg) + +Sigrid S McCawley, Esq +Telephone: (954) 377-4223 +Email: [smccawley@bsflip.com](mailto:smccawley@bsflip.com) + +November 29, 2017 + +**VIA ECF** + +Honorable John G. Koeltl +Daniel [REDACTED] Moynihan +United States Courthouse +500 Pearl Street +New York, NY 10007 + +*Application denied. The +Court will determine whether +any discovery is generated +after receiving all of the papers.* + +Re: *Jane Doe 43. v Epstein, et al.* +Case No.: 17-CIV-00616 (JGK) + +*solo ordered. +ver G/Koeltl +D W.S.D.S. 11/30/17* + +Dear Judge Koeltl: + +We represent Plaintiff Jane Doe 43 in the above-referenced matter. The Defendants Jeffrey Epstein and Lesley Groff (hereinafter referred to simply as "Epstein") will shortly be filing a "supplemental" motion to dismiss, which will include materials from outside the complaint. These materials will be used to bolster the currently-pending motion to dismiss, which alleges (among other things) lack of personal jurisdiction over Epstein. While we believe that the motion to dismiss is meritless for reasons that we will explain in our response, we believe that the issues surrounding personal jurisdiction would be greatly simplified if plaintiff were allowed jurisdictional discovery from Epstein. In particular, Jane Doe 43 believes that if she could take a one-hour deposition (over the phone) of Epstein, the answers obtained in that deposition would immediately establish personal jurisdiction. Accordingly, we write to request such a deposition. + +Epstein has alleged in his currently-pending motion to dismiss that "the Court does not have jurisdiction over the defendants." DE 80 at 23 (capitalization altered). Epstein claims in his motion that that there is a lack of sufficient past or present connection to the Southern District of New York to establish jurisdiction over him. *Id.* at 23-24. Previously Epstein's counsel represented that Epstein has "no present connection to New York." Letter from Michael C. [REDACTED] to Hon. John G. Koeltl at 2 (July 14, 2017). + +We believe that a short deposition of Epstein would immediately establish such jurisdiction - including the fact that Epstein has a present connection to New York. For example, Jane Doe 43's First Amended Complaint alleges that Epstein maintains a residence within the Southern District of New York (DE 45 at 2 ¶ 4) and that Epstein used this residence "to facilitate the illegal sex trafficking venture and enterprise described in this Complaint and in furtherance of the venture and enterprise." DE 45 at 4 ¶ 12. A deposition of Epstein would, counsel believe, confirm the accuracy of these representations. + +This Court "has broad discretion to permit the plaintiff to conduct jurisdictional discovery." *Tese-Milner v. De Beers Centenary A.G.*, 613 F. Supp. 2d 404, 417 (S.D.N.Y. 2009) + +BOIES SCHILLER FLEXNER LLP + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DJC# \_\_\_\_\_ +DATE FILED. 11-30-17 + +## BSF + +Honorable John G. Koeltl November 29, 2017 Page 2 + +(citing Kiobel v. Dutch Petroleum Co., 2008 WL 591869, at \*9 (S.D.N.Y. Mar. 4, 2008)). Indeed, a district court has authority to allow "jurisdictional discovery" to proceed even while a motion to dismiss is pending. See. e.g.. Daventree Ltd. v. Republic of Azerbaijan, 349 F.Supp.2d 736, 765 (S.D.N.Y. 2004). + +The jurisdictional discovery that Jane Doe 43 requests is simply for a one-hour deposition of defendant Epstein. The deposition could be conducted over the telephone to minimize inconvenience to Epstein. Jane Doe 43 intends to ask Epstein, among other things, the following questions — and proffers that she has a good faith basis for believe that she will receive the following answers from Epstein: + +| Ill./C3 1 lUiN | AIN Ill,Wil I CU AINJW P( I | +|-----------------------------------------------|----------------------------------------------------------------------------| +| Do you have a present connection with the | I Either "yes" or invocation of Fifth | +| Southern District of New York? | Amendment. | +| Do you own or control corporations with | i Either "yes" or invocation of Fifth | +| locations in the Southern District of New | I Amendment. | +| York? | I | +| Do | I you own apartments in the Southern I Either "yes" or invocation of Fifth | +| District of New York? | _a Amendment. --I | +| Do you | I currently own a residence in the Either "yes" or invocation of Fifth | +| Southern District of New York? | Amendment. | +| Have you recently visited your residence in | i Either "yes" or invocation of Fifth | +| the Southern District of New York? | I Amendment. I | +| Did you use your residence in the Southern | I Either "yes" or invocation of Fifth | +| District of New York to facilitate an illegal | I Amendment. | +| sex trafficking enterprise? | I | +| How many girls and young women did you | I Either "dozens and dozens" or invocation of | +| Did you use your residence in the Southern | Either "yes" or invocation of Fifth | +| District of New York to coerce Jane Doe 43 | Amendment. | +| Did you make threats to Jane Doe 43 to | Either "yes" or invocation of Fifth | +| coerce her into have sex with you in your | I Amendment. | +| Did you falsely and fraudulently promise ---1 | Either "yes" or invocation of Fifth | +| things to Jane Doe 43 in order to obtain sex | I Amendment. | +| Did you make false and fraudulent | I Either "yes" or invocation of Fifth | +| representations to Jane Doe 43 after January | I Amendment. | +| 31 2-- 2017? | | +| Did you make any of the false and fraudulent | Either ryes" or invocation of Fifth | + +BSF + +Honorable John G. Koeltl November 29, 2017 Page 3 + +| representations in your residence in the | I Amendment. | +|------------------------------------------------|-----------------------------------------------| +| Please state with particularity the fraudulent | -I—Either a particular description of the | +| representations you made to Jane Doe 43 to | I fraudulent representations or invocation of | +| secure sex from her? | I Fifth Amendment. | +| Do have information about how Ghislaine | Either "yes" or invocation of Fifth | +| Maxwell is attempting to evade service of | I Amendment. | + +These anticipated answers are based on counsel's current understanding of the situation. Of course, if our understanding on any of these points is inaccurate, Epstein can simply provide an affidavit — under oath — correcting our understanding. + +The answers to these questions will simplify the Court's task in ruling on Epstein's motion to dismiss. For example, with respect to personal jurisdiction, if Epstein provides the anticipated answers, the jurisdictional issue will disappear entirely. If he invokes the Fifth Amendment, of course the net effect is the same because an adverse inference arises against Epstein. See Baxter v. Palmigiano, 425 U.S. 308, 316-18 (1976). The answers will also be relevant to service of process issues that may appear before the Court again in connection with Ghislaine Maxwell. + +This approach will not burden Epstein. The deposition could be conducted over the telephone at a time mutually convenient to him and to all counsel. Nor will this approach delay this case. As the Court is aware, the final version of Epstein's motion to dismiss has yet to be submitted. The deposition of Epstein could easily be conducted within two weeks, thereby avoiding any delay of the proceedings. + +Counsel for Jane Doe 43 understands from earlier pleadings that defendant Epstein opposes the motion. + +Accordingly, for all these reasons, the Court should allow a one-deposition of Epstein on all issues associated with jurisdiction, including all questions regarding his residence in New York City and his use of that residence for sex trafficking of Jane Doc 43 and others, as well as information about Ghislaine Maxwell evading service of process. + +Sincerely, + +/s Sigrid McCawlev Sigrid S. 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JOHN G. KOELTL, + +District Judge + +## APPEARANCES + +PAUL G. CASSELL (via telephone) Attorney for Plaintiff + +POTTINGER LLC Attorneys for Plaintiff BY: STAN POTTINGER + +STEPTOE & , LLP Attorneys for Defendant Epstein BY: MICHAEL C. + +ALSTON & BIRD, LLP Attorney for Defendant BY: ALEXANDER S. LORENZO + +ALSO PRESENT: + +SHER TREMONTE, LLP Attorneys for Interested Party Haddon & , P.C. BY: KIMO S. PELUSO + +4 MR. CASSELL: Good afternoon, your Honor. This is Paul Cassell, from Salt Lake City, Utah, on behalf of , Jane Doe 43. + +5 THE COURT: Good afternoon. + +6 7 MR. POTTINGER: Good afternoon, your Honor. Stan Pottinger, also for plaintiff + +8 9 MR. PELUSO: Good afternoon, your Honor. Kimo Peluso, Sher Tremonte, for interested party Haddon, + +10 THE COURT: Hold on one second, please. + +11 (Pause) + +12 THE COURT: Thank you. + +13 Who else? + +14 15 MR. LORENZO: Good afternoon, your Honor. Alex Lorenzo, Alston & Bird, for defendant + +16 17 18 MR. : Good afternoon, your Honor. Mike from the law firm of Steptoe & , for Jeffrey Epstein and Lesley Groff. + +19 THE COURT: Jeffrey Epstein and? + +20 MR. : Lesley Groff, G-R-O-F-F. + +21 THE COURT: All right. + +22 23 24 25 You are all here because I received a letter from Mr. Peluso, on behalf of the Haddon firm, objecting essentially to the fact that I have approved alternative service on Ms. Maxwell by serving Haddon , and then I got + +(Case called) + +4 MR. PELUSO: Yes, your Honor. Thank you. + +5 6 THE COURT: You say that, as I read your papers, Ms. Maxwell can be served in London. Where in London? + +7 8 9 10 MR. PELUSO: I don't know, your Honor, that she can be served in London. The point as to her London residence was that plaintiffs are aware of at least one residence where they haven't attempted service, which goes -- + +11 12 THE COURT: I'm sorry? The plaintiffs are aware of what? + +13 14 15 16 17 18 19 20 MR. PELUSO: Plaintiff's counsel is aware of at least one residence where they hadn't even attempted service. But really the broader point is they hadn't attempted service at all. And we found the plaintiff's original ex parte application to your Honor was based on the representation that Ms. Maxwell was avoiding service and that service had been attempted; and, in actuality, plaintiff's counsel never attempted service. + +21 22 THE COURT: What is the address that you say they should have tried in London? + +23 24 MR. PELUSO: I don't know the address offhand, your Honor, but -- + +25 THE COURT: You must be able to get that. + +a letter memo in opposition by Mr. + +So what do the parties want to do at this point? + +Mr. Peluso? + +4 MR. PELUSO: Yes, your Honor, we can provide that. Plaintiff's counsel already has that, and I believe they have conceded they already have that, from discovery that was not confidential from the other action before Judge Sweet. + +5 6 THE COURT: I thought that they actually disputed that. + +7 8 9 10 11 12 13 14 15 16 17 18 MR. PELUSO: No, your Honor. I think there was some confusion. We may have cited to the wrong document on the docket. They disputed that there was any issue as to her New York home, which in fact had been sold. She could not be served in New York. They conceded in their papers that another issue that was subject to discovery was, I believe the way they put it, a flat in London associated with Ms. Maxwell. Their point was that the events that were relevant to the flat in London happened in 2001/2002. So it was too old for them to attempt service there. I don't really follow the argument, but that was the point. They were not disputing that they are aware of a residence associated with Ms. Maxwell in London. + +19 20 21 THE COURT: But so they are unaware of any address at which she could be served, then. You say that that is no longer a current address. + +22 23 24 25 MR. PELUSO: No, your Honor. They said that it is not a current address. I don't know where Ms. Maxwell lives today. I'm not here to report to the court that I know an address where she can be found. What we are here today on is our + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +application that her law firm, from the prior action, should not be inserted into the middle of this by accepting service. + +THE COURT: I understand that, but some of your arguments appear to be supportive of an effort avoid service. I know you say that they didn't really try very hard before making the application to me. Why don't I simply extend the time to serve for another 60 days or 30 days, a reasonable time? They appear to have been making a record, even if it wasn't made before the fact, of repeatedly asking your client's firm for a way to get ahold of Ms. Maxwell, all of that unsuccessful, even though your client has recently appeared on behalf of Ms. Maxwell before Judge Sweet. Right? + +MR. PELUSO: That is correct, your Honor. The case itself was settled, but there have been some post-judgment issues. + +THE COURT: Right. You relied on the fact that the case in which your client had represented Ms. Maxwell was over; and then, lo and behold, your client shows up representing Ms. Maxwell in this district, so still has the relationship with Ms. Maxwell, enough to be able to appear in this district. + +MR. PELUSO: Your Honor, we have never taken the position that the Haddon firm cannot reach Ms. Maxwell. Our point was they decline to accept service, which law firms are requested to accept service on behalf of their clients all the time. Often they say yes, often they say no. I don't + +4 5 THE COURT: They can't accept service if they are not specifically authorized by the client to accept service. + +6 MR. PELUSO: Correct, your Honor. + +7 8 9 10 11 THE COURT: On the other hand, if the court ordered for alternative service that they can be served and that that will be sufficient notice to the client of service, then they can accept service. In fact, they have to accept service, right? + +12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. PELUSO: Yes. If the court orders the law firm to, then the law firm becomes a vehicle of service. And it is not the passive kind, where the court orders publication or something like leaving it where the party who is attempted to be served is known to frequent. It is actually requiring the law firm to take affirmative acts. And that is the aspect of the order that we raise a strong issue with, especially in a case like this, your Honor, where this is the second plaintiff in a series of allegations that there are dozens of others, no defendant should be put to the choice of appearing in the first case and thereby de facto having an agent for service of process for all future cases. The conscription of the law firm of the party for that purpose carries with it some important implications, and that is why we are bringing this + +think the court would suggest any wrongdoing with either answer. But obviously a law firm can't accept service if their client won't authorize it. + +4 5 6 7 8 9 THE COURT: There would still have to be personal service, personal jurisdiction over the defendant. The only thing that service accomplishes is notifying the defendant of the existence of the lawsuit and providing the defendant with the opportunity to raise all defenses, including the lack of personal jurisdiction. The service should be fairly straightforward if it is reasonably calculated to give notice to the defendant. + +10 11 12 13 14 15 16 17 18 19 Now, I can understand your position that the plaintiff didn't act sufficiently diligently originally to get ahold of Ms. Maxwell and went too quickly to your firm, to your client. I can understand all of that. On the other hand, the plaintiff then puts in all of this correspondence in which they beg you, your client, to accept service, and they get stonewalled. And yet, lo and behold, they appear in this district on behalf of Ms. Maxwell and appear able to contact the client in order to take positions on the client's behalf. So one wonders whether all of this is simply a procedural delay. + +20 21 22 23 I realize from the papers that there have been lots of motions in the other case, and I suspect that there will be lots of motions before me, but this shouldn't be a difficult procedure in order to provide sufficient notice to Ms. Maxwell. + +24 + +25 MR. PELUSO: Your Honor, I think that the -- what I + +application. + +What am I missing? + +4 5 6 7 8 9 10 11 12 would push back against is the idea that the record they have developed shows diligence that warrants alternative service. What they have shown is they asked a law firm to accept service or provide the address information for their client. And they have put in a record now that they asked that many, many times. But that's all they did. They asked the same question many times, which lawyers are free to say no to. And I would submit that it would be an unusual extension of the CPLR provisions for alternative service to grant alternative service merely because a law firm declined to accept service and declined it several times. That is not the basis for the process that brings a party before the powers of the court. + +13 14 15 16 17 18 19 20 21 22 THE COURT: It is not only that, but they appear to have come up against a blank wall for an address for Ms. Maxwell. All of this presumably goes away if your client simply said, Here is an address, here is a physical address, here is an e-mail address, we would prefer that you contact the client directly rather than us. But there is nothing like that. Your client would be free to provide any of that information, but there is no indication here that your client has provided either a physical or an e-mail address for Ms. Maxwell, right? + +23 24 25 MR. PELUSO: I don't believe there is anything to that effect in the record before your Honor. I also don't believe there is any representation by plaintiff that they don't have + +an e-mail address for Ms. Maxwell. I don't know what they would say to your Honor about what information they have. But 4 we know that they have a London address that they didn't attempt service on. + +5 6 THE COURT: You say it is not a good address, I thought. + +7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 MR. PELUSO: No. I don't know. I do not know whether she is there today. My understanding is that they had -- my understanding is that either she doesn't have a permanent physical address in the United States or I can say that my client doesn't know one for her. They don't have a way -- they don't have a mailing address for her or physical address for her. I'm not denying that the Haddon firm can get in touch with her, but I don't know what the situation is in the London address. In the cases where courts allow alternative service, normally if you have an address, you go there, you attempt service, you talk to the neighbors, before skipping all of that and going to service through a law firm that has not been authorized to accept service by their client. And I don't think we would take issue with your Honor's suggestion of extending the time for them to attempt service in another way. Our application is to get the law firm out of it. The law firm should be free to decline accepting service without that being seen as somehow stonewalling. + +25 THE COURT: If I gave them another 30 days to make the + +4 5 6 7 record, why at the end of 30 days would I not authorize service on Haddon as, if no other address comes up, either a physical address or e-mail address, Haddon has shown an ability to contact the plaintiff and, quite recently, to appear on behalf of the plaintiff in the court. That would then appear to be reasonably calculated to give notice to Ms. Maxwell. Why wouldn't that be right? + +8 9 10 11 12 13 14 15 MR. PELUSO: That would certainly be a stronger application, your Honor, or service may be successful in other ways. But the notion of Haddon going along with service on the current record and potentially becoming the agent for service of process for this client for this district in however many cases they are going to bring is not something that makes sense for the law firm to accept without bringing this application for the court to reconsider the ruling. + +16 17 18 THE COURT: Okay. You have certainly diligently opposed the ruling, so let me listen to the plaintiff presumably. + +19 MR. PELUSO: Thank you, your Honor. + +20 21 MR. CASSELL: Yes. Thank you, your Honor. This is Paul Cassell on behalf of + +22 23 24 I know you have had a chance to review our pleadings, so let me just highlight a few things that I think are important here. + +25 First, it is important to understand that this + +4 posture that the motion comes to you on is a motion for reconsideration, and so it is the burden of Haddon to show some reason to change the outcome that is in play right now. + +5 6 7 8 9 10 11 12 We made two procedural points in our opposition, neither of which have been responded to. The first is that the court lacks standing to hear from Haddon as to why there is some defect in the service on defendant Maxwell. They don't have an interest, they haven't alleged any injury, certainly not a particularized injury of the kind that would be sufficient to create Article III standing, and so the motion to reconsider should be denied for that reason alone. + +13 14 15 16 17 18 19 A second concern is timeliness. Ordinarily we wouldn't make a point out of a few days, but I think your Honor has the sense of what's going on here. This appears to be a delay tactic designed to keep this case from getting off the ground, and not because there is some meritorious concern, but simply because there are procedural objections that could be raised for proceduralism's sake. + +20 21 22 23 24 25 We would call to your Honor's attention that you granted our motion for alternative service on September 29. We in fact served Haddon on October 9, and yet the opposition or the motion for reconsideration, I guess I should say, was not timely filed. it came in on October 30, and here we are, you know, four weeks later, or something, litigating. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +It is simply not timely, and the court should deny it for that procedural reason as well. + +But let me turn to the merits, and I think your Honor has already made many of the points that I would want to make. We have -- it wasn't simply a matter of developing a record. We were trying to avoid embroiling the court in any service issues which, as you know from the e-mails, we were told by Haddon Maxwell is not permanently settled. That's a direct quote. "I do not believe she has a permanent residence." Those were the representations that we were given. And so we ran into, as I think your Honor pointed out, a brick wall or blank slate. We didn't know how to proceed. + +Now we have heard from the other side there should have been a bunch of due diligence or prior attempts to serve. In our original motion to the court, we cited this court's decision in Securities and Exchange Commission v. HGI that says: Look, a plaintiff has to show a practicability of service, but there is no requirement of proof of due diligence or actual prior attempts to serve a party. That's a quote from a 1999 decision of this court. + +So I didn't hear anything this afternoon that suggested there was a lack of impracticability, which of course was the basis for the court granting our motion. The only thing we have heard about is that we should have gone hither and yon through London trying to serve Ms. Maxwell there. + +4 5 6 Interestingly, though, you will recall that the Haddon firm filed their letter motion and they cited a newspaper article that said Ms. Maxwell is a British socialite. Well, that same article -- again, this is what the other side was filing -- says that she has been based in the United States since 1999. + +7 8 9 10 11 12 13 14 15 16 17 Now, it is true that we are aware of a client who in 2001 was in a flat in London that appeared to be connected with Ms. Maxwell and was sexually abused, but that was 16 years ago. And I guess what the other side is suggesting is that we should go through the Hague Convention, follow procedures there, chase after this flat, and see if somehow that changes things. We cited in our papers that we provided to your Honor last week a previous decision from this court saying, look, going through the Hague Convention just takes so long and creates such significant expense of impracticable. that that in and of itself can be a showing + +18 19 20 21 22 23 24 25 So there isn't extending things for 30 London and spend what I any reason, I would submit, or 60 days to make us chase think would be thousands of for through dollars, if not tens of thousands of dollars, on foreign process service. Again, we would be willing to spend time and money and the court's time and energy if there was some substantive concern here, but this is all designed, as your Honor pointed out, to make sure that Ms. Maxwell knows about the lawsuit. Well, I + +think she was just a few doors down from where your Honor is 4 5 6 7 8 9 10 sitting right now with attorneys actually litigating an issue relating to confidentiality of documents in this lawsuit. So that provides, I would think, ample basis for the court to conclude that she already knows about the lawsuit. All we are trying to do is to simply effect service here, get the case moving forward, and then she can raise whatever concerns she wants. We submit that there has been no showing sufficient to justify the court reconsidering its earlier ruling on all these things. + +11 12 13 THE COURT: Mr. Cassell, a couple of things. You say that she was just a few doors down. Her lawyers were here. Any reason to believe that she was here? + +14 15 16 17 18 MR. CASSELL: No. I'm sorry if I said she was. She was there through counsel, and we would submit that that is effectively constructively appearing before your Honor, because the litigation in front of Judge Sweet involved confidentiality connected to this particular case. + +19 THE COURT: Yes, but that is stretching it just a bit. + +20 21 22 23 The other item is that it appeared -- and you can correct me if I am wrong -- that all of the e-mail correspondence about service was something that occurred after the Haddon firm was served, or was it before? + +24 25 MR. CASSELL: It is both before and after. It was back as far as February of this year that we were trying to + +4 5 6 7 8 9 10 work through the firm. We followed up again in March. If I have the chronology right, we followed up again in May. And then just as recently as November 7, we realize your Honor's time is valuable, we said, Look, we don't want to burden the court with this issue, if you can just give us something to follow up on. We sent that e-mail on November 7 and, to my knowledge, here we are three weeks later and have not received any response from the Haddon firm. So we have tried to do what we could to make contact through the Haddon firm. + +11 12 13 14 THE COURT: My problem here, Mr. Cassell, is simply not wanting to have the possibility of an error in service at the outset of the case when the error, it would seem to me, could be easily corrected if, in fact, there were error. + +15 16 17 18 19 20 21 22 23 The motion for reconsideration says, in essence, Judge, you didn't have a sufficient record before to you say that service was really impracticable. The plaintiff has attempted to come forward now with all of this subsequent information, none of which really was before you at the time. I plainly have the ability, irrespective of the standing of Haddon or the timeliness of the application, to reconsider my own order and to extend the time for service in a way that assures that there can't be any error. + +24 25 Now, Haddon has gone quite far, and you have gone quite far in showing the impracticability of service on + +4 Ms. Maxwell and indeed the stonewalling of efforts to find an address or an e-mail address for Ms. Maxwell, but none of that was in the record before me at the time that I authorized service on Haddon as an alternative means of service. + +5 6 7 8 9 10 11 Now, if Ms. Maxwell chooses to start the litigation this way before me, not a good way to begin litigation, but so be it. Motions over effective service are seldom made because so easily cured, and at the end of the day, the effect of motions like this is simply to chip away at parties' credibility. If any parties wishes to start this way, so be it. + +12 13 14 15 16 I want to make sure that everything I do in the case is right. I am somewhat persuaded by the argument that the showing of impracticability at the outset left something to be desired in view of everything that has been presented to me since then. + +17 18 19 20 21 22 23 You are welcome to respond to all of that. My inclination is simply to extend the time to serve on Ms. Maxwell until January 5, at which time the plaintiff can indicate that service has been made or apply for alternative service. If there is an application for alternative service, any response should be filed quickly, by January 12, and I will decide it on those papers. + +24 25 Haddon has already protectively sought an extension of time to move or answer for 60 days, so when does + +4 5 6 THE COURT: No reason that I shouldn't -- I assume that these procedural matters will be disposed of soon after January 12, so -- + +7 8 MR. CASSELL: Your Honor, could I be heard just briefly on the time frame that you are contemplating there? + +9 THE COURT: By all means. + +10 11 12 13 14 15 MR. CASSELL: I am not an expert in the Hague Convention but I am informed by others that a 60- to 90-day timeline is the minimum amount of time for service through the Hague Convention. The timeline that you are setting up might work if we were chasing after someone in Manhattan, but we are chasing after someone in a foreign country. + +16 17 18 19 20 21 22 23 24 25 A related point is the issue of cost. This is going to cost tens of thousands -- I'm sorry, thousands of dollars, if not tens of thousands of dollars, to attempt to do this and, as you know, lacks resources here. So I think your Honor was making a point that this is not a good way to start the litigation for Ms. Maxwell. I submit that they will be returning to their offices high-fiving because they have required someone who lacks resources to spend thousands and thousands of dollars simply attempting to effect service in a situation where, as of last week, they had lawyers in the + +that expire? + +MR. CASSELL: That expires, I believe, within -- after 21 days after this particular motion has been resolved. + +4 5 6 7 8 9 And related to that, Haddon obviously has contact information for Ms. Maxwell. They could be directed by your Honor to provide all the contact information that they have to us in an effort to minimize those costs. So those sorts of things, we would submit, should be considered by your Honor in looking at the motion to reconsider. + +10 11 12 13 14 15 16 17 18 19 20 21 22 We realize that we did not make as extensive a record as we could have in initial pleading, but I do think that our initial pleading said that it was implausible, here is why. We didn't burden the court with all of the e-mails and other things at that time. So if the question is whether the record was sufficiently developed, then I would submit it's much more developed today and you could simply deny the motion to reconsider based on the record that you have today; or if your Honor would feel more comfortable in terms of avoiding any error, you could give us the opportunity to re-serve Haddon now in light of the new record that we have developed, and you could grant the alternative service motion based on the record as it exists this afternoon. + +23 THE COURT: Mr. Peluso. + +24 25 MR. PELUSO: Yeah. Your Honor, I don't want to advise plaintiff on how to proceed, but I would suggest that they + +Southern District of New York actually litigating an issue related to the very issues that we are talking about. So we would ask that those factors be considered. + +4 5 6 7 8 examine the Hague Convention, they examine Article 10, they examine those countries that have opted in to Article 10 and determine whether service on a UK address can be accomplished by registered mail before making representations that this process will cost their client thousands of dollars and take 60 to 90 days. And if they look into those things and want to make those representations, they can. I suspect if they look into those things, they will not. + +9 10 11 12 13 14 15 16 17 18 I also just have to take issue with the suggestion that we had stonewalled them by refusing to provide an e-mail address. There was electronic discovery in the earlier case. They certainly have e-mails belonging to Ms. Maxwell. I don't think we heard any representation to the contrary. I don't know what those e-mail addresses are. I suspect plaintiff's counsel knows a lot more about Ms. Maxwell's e-mails than we do. No one is suggesting from my client any relief that will add months to this process or cost thousands of dollars to Ms. Maxwell by any means. + +19 20 21 22 23 24 25 THE COURT: Mr. Cassell, Mr. Peluso suggests, first, that there is an easier way of service under the Hague Convention in Great Britain, but that of course depends upon having an address in Great Britain. He suggests that you actually probably in discovery, which I believe you are able to access with the recent order of Judge Sweet, have access to electronic communications that were copied to Ms. Maxwell. + +4 5 6 7 8 9 10 Finally, what you were suggesting record of what could could be given to me month or before with have been given to me now can all be raised a renewed application of supplementing the at the outset or at the end of the for alternative service if in fact this matter has not been resolved before then. If in fact you are right that all of this information shows that it is impractical to serve Ms. Maxwell, then presumably there are alternative means of notice to Ms. Maxwell. Among those would possibly be Haddon service by an e-mail address. and + +11 12 13 14 15 Finally, I decide every motion in an effort to be right. It is the parties who have to deal with whether I am right or not. All I have to do is to decide every motion in the best way that I can and leave to all of you whatever the consequences of that are. + +16 17 18 19 20 21 22 23 24 25 It would be not the best way to start off the case for a plaintiff to say, well, we may not have made the showing to you that we could have or should have made, but blow through it, Judge, live with it. I don't do that. I try to decide every case in the best way that I can. And it seems to me clear that you won't have to spend thousands of dollars in order to effect service, but you do have to have made the diligent inquiries to attempt service before going to the alternative method of service. What that involves, I don't know at the moment, but that is really up to the parties. + +MR. CASSELL: Your Honor, perhaps could I ask one 4 5 question of opposing counsel? Because I think this might be one way of cutting through all this. Let me just tell you what the one question would be. Isn't it true that Ms. Maxwell already has notice of this lawsuit? + +6 7 THE COURT: Well, Haddon can answer if they want. + +8 9 10 MR. PELUSO: I honestly don't know, your Honor. I suspect someone at Haddon can answer that. I could find out, but I don't think that is service, your Honor. + +11 12 13 14 15 16 17 18 19 20 21 22 23 MR. CASSELL: That's the whole purpose of why we are here, your Honor. And, frankly, I think that is one of the reasons why Haddon is not appearing in front of you today, but has hired sort of a surrogate, if you will, so there is a plausible deniability, or whatever the phrase would be. Perhaps one way to proceed would be to ask Haddon that question through counsel that's here today and if they respond that, yes, Ms. Maxwell does indeed have notice of the lawsuit, at that point I would assume that that amply protects any record or shows that all of these hearings and motions and so forth are much ado about nothing, and we could then move with service through Haddon , since it accomplished the goal that it was designed to accomplish. + +24 25 THE COURT: That is not right, actually. The fact that the defendant has notice, if you will, of the lawsuit + +4 5 doesn't substitute for service of the summons and complaint. True that alternative service is meant to provide notice - and, again, the parties can correct me if I am wrong -- but it doesn't simply dispose of the requirement for service of the summons and complaint. + +6 7 8 9 10 11 12 13 14 15 16 17 18 MR. CASSELL: But our limited point, your Honor appreciate the clarification there, but our limited point was that the alternative service motion is designed to provide notice reasonably calculated under all of the circumstances to apprise interested parties of the pendency of the action. And if that apprisal function has already been accomplished, to even have to spend one additional dollar or one additional month tracking things down through London is energy and time and money being expended for no purpose whatsoever, particularly where -- I agree that the summons and so forth should be provided to Ms. Maxwell, but no one is disputing that that will take more than a few seconds on a keyboard for Haddon to forward it along to their client. + +19 20 21 22 23 24 25 THE COURT: Okay. Well, where I was was I will extend the time for service on Ms. Maxwell until January 5, at which point the plaintiff can either file proof of service or an application for alternative service. And just so that there is no question, the application for alternative service, whatever you believe is most appropriate for alternative service should also be filed, because they have appeared for a limited purpose + +on Haddon + +Any response can be filed by January 12. + +4 5 The time to move or answer is 30 days after service in response to the court's decision on service. That will not lose us much time. + +6 7 Any other deadlines or procedural tasks that I should deal with in this order? + +8 9 MR. Your Honor, Mike for Jeffrey Epstein and Lesley Groff. + +10 11 12 13 14 15 16 17 18 19 20 We are scheduled to file a supplemental motion to dismiss within seven days of the issuance of a confidentiality or protective order in this case. We have a draft of it that we will be circulating to the parties hopefully tomorrow or the day after. I guess the only question from a scheduling perspective is whether it makes sense to stay motion practice on the balance of the case until after the service issue is resolved. We are content to go either way, subject to the court's pleasure on the issue, but I just point that out. That could result in motion practice happening sequentially rather than simultaneously. + +21 22 23 THE COURT: Mr. Cassell, do you want the rest of the defendants to answer or move to dismiss without waiting for Ms. Maxwell? + +24 MR. CASSELL: Yes, your Honor. + +25 THE COURT: I thought that would be the response, + +4 Okay. + +5 6 7 8 9 10 MR. CASSELL: Mr. Pottinger may want to step in on this, but we would like to file a single response to all of the supplemental and various motions to dismiss coming in from the various defendants, so we would ask for an opportunity to respond with one single response 14 days after all of the new information comes in from the various defendants. + +11 THE COURT: I assume for everyone but Ms. Maxwell. + +12 MR. CASSELL: Yes, your Honor. + +13 14 15 THE COURT: It seems reasonable to me. Consolidated response by the plaintiff 14 days after the supplemental papers by the defendants. + +16 And then the reply? + +17 18 19 20 MR. : Your Honor, we respectfully request 14 days after we receive the response for the reply brief. And I say that without knowing how that lands in terms of holidays, towards the end of December. + +21 22 23 24 25 Could I suggest this? Rather than set dates right now for the response and the reply, I can tell you, on behalf of the clients I represent -- and I suspect it is true for the other defendants -- that we won't object to a briefing schedule that consolidates the motions other than Maxwell's, but perhaps + +MR. : That's fine, your Honor. + +THE COURT: -- that motion schedule stands. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +we could meet and confer on that issue and submit a proposed schedule to the court once we have a protective order issued from the court. + +THE COURT: That's fine by me. + +Mr. Cassell? + +MR. CASSELL: That sounds like an excellent approach. + +We agree. + +me. THE COURT: Okay. So submit the proposed schedule to + +Anything else? All right. Good afternoon all. + +MR. CASSELL: Thank you, your Honor. + +THE COURT: Sure. + +MR. 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"debug_data/EFTA02819950" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819975/EFTA02819975.md b/marker2/court-jane-doe-43/EFTA02819975/EFTA02819975.md new file mode 100644 index 0000000000000000000000000000000000000000..f940d1ac86a209f2d7c3719ce3308f596ee980ee --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819975/EFTA02819975.md @@ -0,0 +1,27 @@ +## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +USA / Plaintiff(s) + +Case No.: 17CV1789 + +JEFFREY EPSTEIN., ET AL + +Defendant(s) + +## NOTICE OF FILING OF OFFICIAL TRANSCRIPT + +Notice is hereby given that an official transcript of a ARGUMENT held 11/28/17 on has been filed by the court reporter/transcriber in the above-captioned matter. + +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting the transcript is a judge or a member of the public or media. + +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days. + +This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion. + +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. + +/s KRISTEN CARANANTE + +Court Reporter/Transcriber Date \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819975/EFTA02819975.metadata.json b/marker2/court-jane-doe-43/EFTA02819975/EFTA02819975.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d3334ead4aebad8db973319343de3780942c3c28 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819975/EFTA02819975.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02819975.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1442, + "elapsed_seconds": 0.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE UNITED STATES DISTRICT COURT \nFOR THE SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 154.224, + 66.42 + ], + [ + 418.71282958984375, + 66.42 + ], + [ + 418.71282958984375, + 96.363037109375 + ], + [ + 154.224, + 96.363037109375 + ] + ] + }, + { + "title": "NOTICE OF FILING OF OFFICIAL TRANSCRIPT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 168.3, + 307.79999999999995 + ], + [ + 448.52362060546875, + 307.79999999999995 + ], + [ + 448.52362060546875, + 322.4830627441406 + ], + [ + 168.3, + 322.4830627441406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 26 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02819975" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02819976/EFTA02819976.md b/marker2/court-jane-doe-43/EFTA02819976/EFTA02819976.md new file mode 100644 index 0000000000000000000000000000000000000000..80e5740f442b3b082a55b92426dd9ac33d9f91ec --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02819976/EFTA02819976.md @@ -0,0 +1,501 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x JANE DOE 43, + +Plaintiff, New York, N.Y. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +v. + +JEFFREY EPSTEIN, et al, + +Defendants. + +Before: + +x + +17 Civ. 616(JGK) + +November 28, 2017 3:45 p.m. + +HON. JOHN G. KOELTL, + +District Judge + +## APPEARANCES + +PAUL G. CASSELL (via telephone) Attorney for Plaintiff + +POTTINGER LLC Attorneys for Plaintiff BY: STAN POTTINGER + +STEPTOE & , LLP Attorneys for Defendant Epstein BY: MICHAEL C. + +ALSTON & BIRD, LLP Attorney for Defendant BY: ALEXANDER S. LORENZO + +ALSO PRESENT: + +SHER TREMONTE, LLP Attorneys for Interested Party Haddon & , P.C. BY: KIMO S. PELUSO + +4 MR. CASSELL: Good afternoon, your Honor. This is Paul Cassell, from Salt Lake City, Utah, on behalf of , Jane Doe 43. + +5 THE COURT: Good afternoon. + +6 7 MR. POTTINGER: Good afternoon, your Honor. Stan Pottinger, also for plaintiff + +8 9 MR. PELUSO: Good afternoon, your Honor. Kimo Peluso, Sher Tremonte, for interested party Haddon, + +10 THE COURT: Hold on one second, please. + +11 (Pause) + +12 THE COURT: Thank you. + +13 Who else? + +14 15 MR. LORENZO: Good afternoon, your Honor. Alex borenzo, Alston & Bird, for defendant + +16 17 18 MR. : Good afternoon, your Honor. Mike from the law firm of Steptoe & , for Jeffrey Epstein and Lesley Groff. + +19 THE COURT: Jeffrey Epstein and? + +20 MR. : Lesley Groff, G-R-O-F-F. + +21 THE COURT: All right. + +22 23 24 25 You are all here because I received a letter from Mr. Peluso, on behalf of the Haddon firm, objecting essentially to the fact that I have approved alternative service on Ms. Maxwell by serving Haddon , and then I got + +(Case called) + +4 MR. PELUSO: Yes, your Honor. Thank you. + +5 6 THE COURT: You say that, as I read your papers, Ms. Maxwell can be served in London. Where in London? + +7 8 9 10 MR. PELUSO: I don't know, your Honor, that she can be served in London. The point as to her London residence was that plaintiffs are aware of at least one residence where they haven't attempted service, which goes -- + +11 12 THE COURT: I'm sorry? The plaintiffs are aware of what? + +13 14 15 16 17 18 19 20 MR. PELUSO: Plaintiff's counsel is aware of at least one residence where they hadn't even attempted service. But really the broader point is they hadn't attempted service at all. And we found the plaintiff's original ex parte application to your Honor was based on the representation that Ms. Maxwell was avoiding service and that service had been attempted; and, in actuality, plaintiff's counsel never attempted service. + +21 22 THE COURT: What is the address that you say they should have tried in London? + +23 24 MR. PELUSO: I don't know the address offhand, your Honor, but -- + +25 THE COURT: You must be able to get that. + +a letter memo in opposition by Mr. + +So what do the parties want to do at this point? + +Mr. Peluso? + +4 MR. PELUSO: Yes, your Honor, we can provide that. Plaintiff's counsel already has that, and I believe they have conceded they already have that, from discovery that was not confidential from the other action before Judge Sweet. + +5 6 THE COURT: I thought that they actually disputed that. + +7 8 9 10 11 12 13 14 15 16 17 18 MR. PELUSO: No, your Honor. I think there was some confusion. We may have cited to the wrong document on the docket. They disputed that there was any issue as to her New York home, which in fact had been sold. She could not be served in New York. They conceded in their papers that another issue that was subject to discovery was, I believe the way they put it, a flat in London associated with Ms. Maxwell. Their point was that the events that were relevant to the flat in London happened in 2001/2002. So it was too old for them to attempt service there. I don't really follow the argument, but that was the point. They were not disputing that they are aware of a residence associated with Ms. Maxwell in London. + +19 20 21 THE COURT: But so they are unaware of any address at which she could be served, then. You say that that is no longer a current address. + +22 23 24 25 MR. PELUSO: No, your Honor. They said that it is not a current address. I don't know where Ms. Maxwell lives today. I'm not here to report to the court that I know an address where she can be found. What we are here today on is our + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +application that her law firm, from the prior action, should not be inserted into the middle of this by accepting service. + +THE COURT: I understand that, but some of your arguments appear to be supportive of an effort avoid service. I know you say that they didn't really try very hard before making the application to me. Why don't I simply extend the time to serve for another 60 days or 30 days, a reasonable time? They appear to have been making a record, even if it wasn't made before the fact, of repeatedly asking your client's firm for a way to get ahold of Ms. Maxwell, all of that unsuccessful, even though your client has recently appeared on behalf of Ms. Maxwell before Judge Sweet. Right? + +MR. PELUSO: That is correct, your Honor. The case itself was settled, but there have been some post-judgment issues. + +THE COURT: Right. You relied on the fact that the case in which your client had represented Ms. Maxwell was over; and then, lo and behold, your client shows up representing Ms. Maxwell in this district, so still has the relationship with Ms. Maxwell, enough to be able to appear in this district. + +MR. PELUSO: Your Honor, we have never taken the position that the Haddon firm cannot reach Ms. Maxwell. Our point was they decline to accept service, which law firms are requested to accept service on behalf of their clients all the time. Often they say yes, often they say no. I don't + +4 5 THE COURT: They can't accept service if they are not specifically authorized by the client to accept service. + +6 MR. PELUSO: Correct, your Honor. + +7 8 9 10 11 THE COURT: On the other hand, if the court ordered for alternative service that they can be served and that that will be sufficient notice to the client of service, then they can accept service. In fact, they have to accept service, right? + +12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. PELUSO: Yes. If the court orders the law firm to, then the law firm becomes a vehicle of service. And it is not the passive kind, where the court orders publication or something like leaving it where the party who is attempted to be served is known to frequent. It is actually requiring the law firm to take affirmative acts. And that is the aspect of the order that we raise a strong issue with, especially in a case like this, your Honor, where this is the second plaintiff in a series of allegations that there are dozens of others, no defendant should be put to the choice of appearing in the first case and thereby de facto having an agent for service of process for all future cases. The conscription of the law firm of the party for that purpose carries with it some important implications, and that is why we are bringing this + +think the court would suggest any wrongdoing with either answer. But obviously a law firm can't accept service if their client won't authorize it. + +4 5 6 7 8 9 THE COURT: There would still have to be personal service, personal jurisdiction over the defendant. The only thing that service accomplishes is notifying the defendant of the existence of the lawsuit and providing the defendant with the opportunity to raise all defenses, including the lack of personal jurisdiction. The service should be fairly straightforward if it is reasonably calculated to give notice to the defendant. + +10 11 12 13 14 15 16 17 18 19 Now, I can understand your position that the plaintiff didn't act sufficiently diligently originally to get ahold of Ms. Maxwell and went too quickly to your firm, to your client. I can understand all of that. On the other hand, the plaintiff then puts in all of this correspondence in which they beg you, your client, to accept service, and they get stonewalled. And yet, lo and behold, they appear in this district on behalf of Ms. Maxwell and appear able to contact the client in order to take positions on the client's behalf. So one wonders whether all of this is simply a procedural delay. + +20 21 22 23 I realize from the papers that there have been lots of motions in the other case, and I suspect that there will be lots of motions before me, but this shouldn't be a difficult procedure in order to provide sufficient notice to Ms. Maxwell. + +24 + +25 MR. PELUSO: Your Honor, I think that the -- what I + +application. + +What am I missing? + +4 5 6 7 8 9 10 11 12 would push back against is the idea that the record they have developed shows diligence that warrants alternative service. What they have shown is they asked a law firm to accept service or provide the address information for their client. And they have put in a record now that they asked that many, many times. But that's all they did. They asked the same question many times, which lawyers are free to say no to. And I would submit that it would be an unusual extension of the CPLR provisions for alternative service to grant alternative service merely because a law firm declined to accept service and declined it several times. That is not the basis for the process that brings a party before the powers of the court. + +13 14 15 16 17 18 19 20 21 22 THE COURT: It is not only that, but they appear to have come up against a blank wall for an address for Ms. Maxwell. All of this presumably goes away if your client simply said, Here is an address, here is a physical address, here is an e-mail address, we would prefer that you contact the client directly rather than us. But there is nothing like that. Your client would be free to provide any of that information, but there is no indication here that your client has provided either a physical or an e-mail address for Ms. Maxwell, right? + +23 24 25 MR. PELUSO: I don't believe there is anything to that effect in the record before your Honor. I also don't believe there is any representation by plaintiff that they don't have + +an e-mail address for Ms. Maxwell. I don't know what they would say to your Honor about what information they have. But 4 we know that they have a London address that they didn't attempt service on. + +5 6 THE COURT: You say it is not a good address, I thought. + +7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 MR. PELUSO: No. I don't know. I do not know whether she is there today. My understanding is that they had -- my understanding is that either she doesn't have a permanent physical address in the United States or I can say that my client doesn't know one for her. They don't have a way -- they don't have a mailing address for her or physical address for her. I'm not denying that the Haddon firm can get in touch with her, but I don't know what the situation is in the London address. In the cases where courts allow alternative service, normally if you have an address, you go there, you attempt service, you talk to the neighbors, before skipping all of that and going to service through a law firm that has not been authorized to accept service by their client. And I don't think we would take issue with your Honor's suggestion of extending the time for them to attempt service in another way. Our application is to get the law firm out of it. The law firm should be free to decline accepting service without that being seen as somehow stonewalling. + +25 THE COURT: If I gave them another 30 days to make the + +4 5 6 7 record, why at the end of 30 days would I not authorize service on Haddon as, if no other address comes up, either a physical address or e-mail address, Haddon has shown an ability to contact the plaintiff and, quite recently, to appear on behalf of the plaintiff in the court. That would then appear to be reasonably calculated to give notice to Ms. Maxwell. Why wouldn't that be right? + +8 9 10 11 12 13 14 15 MR. PELUSO: That would certainly be a stronger application, your Honor, or service may be successful in other ways. But the notion of Haddon going along with service on the current record and potentially becoming the agent for service of process for this client for this district in however many cases they are going to bring is not something that makes sense for the law firm to accept without bringing this application for the court to reconsider the ruling. + +16 17 18 THE COURT: Okay. You have certainly diligently opposed the ruling, so let me listen to the plaintiff presumably. + +19 MR. PELUSO: Thank you, your Honor. + +20 21 MR. CASSELL: Yes. Thank you, your Honor. This is Paul Cassell on behalf of + +22 23 24 I know you have had a chance to review our pleadings, so let me just highlight a few things that I think are important here. + +25 First, it is important to understand that this + +4 posture that the motion comes to you on is a motion for reconsideration, and so it is the burden of Haddon to show some reason to change the outcome that is in play right now. + +5 6 7 8 9 10 11 12 We made two procedural points in our opposition, neither of which have been responded to. The first is that the court lacks standing to hear from Haddon as to why there is some defect in the service on defendant Maxwell. They don't have an interest, they haven't alleged any injury, certainly not a particularized injury of the kind that would be sufficient to create Article III standing, and so the motion to reconsider should be denied for that reason alone. + +13 14 15 16 17 18 19 A second concern is timeliness. Ordinarily we wouldn't make a point out of a few days, but I think your Honor has the sense of what's going on here. This appears to be a delay tactic designed to keep this case from getting off the ground, and not because there is some meritorious concern, but simply because there are procedural objections that could be raised for proceduralism's sake. + +20 21 22 23 24 25 We would call to your Honor's attention that you granted our motion for alternative service on September 29. We in fact served Haddon on October 9, and yet the opposition or the motion for reconsideration, I guess I should say, was not timely filed. It came in on October 30, and here we are, you know, four weeks later, or something, litigating. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +It is simply not timely, and the court should deny it for that procedural reason as well. + +But let me turn to the merits, and I think your Honor has already made many of the points that I would want to make. We have -- it wasn't simply a matter of developing a record. We were trying to avoid embroiling the court in any service issues which, as you know from the e-mails, we were told by Haddon Maxwell is not permanently settled. That's a direct quote. "I do not believe she has a permanent residence." Those were the representations that we were given. And so we ran into, as I think your Honor pointed out, a brick wall or blank slate. We didn't know how to proceed. + +Now we have heard from the other side there should have been a bunch of due diligence or prior attempts to serve. In our original motion to the court, we cited this court's decision in Securities and Exchange Commission v. HGI that says: Look, a plaintiff has to show a practicability of service, but there is no requirement of proof of due diligence or actual prior attempts to serve a party. That's a quote from a 1999 decision of this court. + +So I didn't hear anything this afternoon that suggested there was a lack of impracticability, which of course was the basis for the court granting our motion. The only thing we have heard about is that we should have gone hither and yon through London trying to serve Ms. Maxwell there. + +4 5 6 Interestingly, though, you will recall that the Haddon firm filed their letter motion and they cited a newspaper article that said Ms. Maxwell is a British socialite. Well, that same article -- again, this is what the other side was filing -- says that she has been based in the United States since 1999. + +7 8 9 10 11 12 13 14 15 16 17 Now, it is true that we are aware of a client who in 2001 was in a flat in London that appeared to be connected with Ms. Maxwell and was sexually abused, but that was 16 years ago. And I guess what the other side is suggesting is that we should go through the Hague Convention, follow procedures there, chase after this flat, and see if somehow that changes things. We cited in our papers that we provided to your Honor last week a previous decision from this court saying, look, going through the Hague Convention just takes so long and creates such significant expense of impracticable. that that in and of itself can be a showing + +18 19 20 21 22 23 24 25 So there isn't extending things for 30 London and spend what I any reason, I would submit, or 60 days to make us chase think would be thousands of for through dollars, if not tens of thousands of dollars, on foreign process service. Again, we would be willing to spend time and money and the court's time and energy if there was some substantive concern here, but this is all designed, as your Honor pointed out, to make sure that Ms. Maxwell knows about the lawsuit. Well, I + +think she was just a few doors down from where your Honor is 4 5 6 7 8 9 10 sitting right now with attorneys actually litigating an issue relating to confidentiality of documents in this lawsuit. So that provides, I would think, ample basis for the court to conclude that she already knows about the lawsuit. All we are trying to do is to simply effect service here, get the case moving forward, and then she can raise whatever concerns she wants. We submit that there has been no showing sufficient to justify the court reconsidering its earlier ruling on all these things. + +11 12 13 THE COURT: Mr. Cassell, a couple of things. You say that she was just a few doors down. Her lawyers were here. Any reason to believe that she was here? + +14 15 16 17 18 MR. CASSELL: No. I'm sorry if I said she was. She was there through counsel, and we would submit that that is effectively constructively appearing before your Honor, because the litigation in front of Judge Sweet involved confidentiality connected to this particular case. + +19 THE COURT: Yes, but that is stretching it just a bit. + +20 21 22 23 The other item is that it appeared -- and you can correct me if I am wrong -- that all of the e-mail correspondence about service was something that occurred after the Haddon firm was served, or was it before? + +24 25 MR. CASSELL: It is both before and after. It was back as far as February of this year that we were trying to + +4 5 6 7 8 9 10 work through the firm. We followed up again in March. If I have the chronology right, we followed up again in May. And then just as recently as November 7, we realize your Honor's time is valuable, we said, Look, we don't want to burden the court with this issue, if you can just give us something to follow up on. We sent that e-mail on November 7 and, to my knowledge, here we are three weeks later and have not received any response from the Haddon firm. So we have tried to do what we could to make contact through the Haddon firm. + +11 12 13 14 THE COURT: My problem here, Mr. Cassell, is simply not wanting to have the possibility of an error in service at the outset of the case when the error, it would seem to me, could be easily corrected if, in fact, there were error. + +15 16 17 18 19 20 21 22 23 The motion for reconsideration says, in essence, Judge, you didn't have a sufficient record before to you say that service was really impracticable. The plaintiff has attempted to come forward now with all of this subsequent information, none of which really was before you at the time. I plainly have the ability, irrespective of the standing of Haddon or the timeliness of the application, to reconsider my own order and to extend the time for service in a way that assures that there can't be any error. + +24 25 Now, Haddon has gone quite far, and you have gone quite far in showing the impracticability of service on + +4 Ms. Maxwell and indeed the stonewalling of efforts to find an address or an e-mail address for Ms. Maxwell, but none of that was in the record before me at the time that I authorized service on Haddon as an alternative means of service. + +5 6 7 8 9 10 11 Now, if Ms. Maxwell chooses to start the litigation this way before me, not a good way to begin litigation, but so be it. Motions over effective service are seldom made because so easily cured, and at the end of the day, the effect of motions like this is simply to chip away at parties' credibility. If any parties wishes to start this way, so be it. + +12 13 14 15 16 I want to make sure that everything I do in the case is right. I am somewhat persuaded by the argument that the showing of impracticability at the outset left something to be desired in view of everything that has been presented to me since then. + +17 18 19 20 21 22 23 You are welcome to respond to all of that. My inclination is simply to extend the time to serve on Ms. Maxwell until January 5, at which time the plaintiff can indicate that service has been made or apply for alternative service. If there is an application for alternative service, any response should be filed quickly, by January 12, and I will decide it on those papers. + +24 25 Haddon has already protectively sought an extension of time to move or answer for 60 days, so when does + +4 5 6 THE COURT: No reason that I shouldn't -- I assume that these procedural matters will be disposed of soon after January 12, so -- + +7 8 MR. CASSELL: Your Honor, could I be heard just briefly on the time frame that you are contemplating there? + +9 THE COURT: By all means. + +10 11 12 13 14 15 MR. CASSELL: I am not an expert in the Hague Convention but I am informed by others that a 60- to 90-day timeline is the minimum amount of time for service through the Hague Convention. The timeline that you are setting up might work if we were chasing after someone in Manhattan, but we are chasing after someone in a foreign country. + +16 17 18 19 20 21 22 23 24 25 A related point is the issue of cost. This is going to cost tens of thousands -- I'm sorry, thousands of dollars, if not tens of thousands of dollars, to attempt to do this and, as you know, lacks resources here. So I think your Honor was making a point that this is not a good way to start the litigation for Ms. Maxwell. I submit that they will be returning to their offices high-fiving because they have required someone who lacks resources to spend thousands and thousands of dollars simply attempting to effect service in a situation where, as of last week, they had lawyers in the + +that expire? + +MR. CASSELL: That expires, I believe, within -- after 21 days after this particular motion has been resolved. + +4 5 6 7 8 9 And related to that, Haddon obviously has contact information for Ms. Maxwell. They could be directed by your Honor to provide all the contact information that they have to us in an effort to minimize those costs. So those sorts of things, we would submit, should be considered by your Honor in looking at the motion to reconsider. + +10 11 12 13 14 15 16 17 18 19 20 21 22 We realize that we did not make as extensive a record as we could have in initial pleading, but I do think that our initial pleading said that it was implausible, here is why. We didn't burden the court with all of the e-mails and other things at that time. So if the question is whether the record was sufficiently developed, then I would submit it's much more developed today and you could simply deny the motion to reconsider based on the record that you have today; or if your Honor would feel more comfortable in terms of avoiding any error, you could give us the opportunity to re-serve Haddon now in light of the new record that we have developed, and you could grant the alternative service motion based on the record as it exists this afternoon. + +23 THE COURT: Mr. Peluso. + +24 25 MR. PELUSO: Yeah. Your Honor, I don't want to advise plaintiff on how to proceed, but I would suggest that they + +Southern District of New York actually litigating an issue related to the very issues that we are talking about. So we would ask that those factors be considered. + +4 5 6 7 8 examine the Hague Convention, they examine Article 10, they examine those countries that have opted in to Article 10 and determine whether service on a UK address can be accomplished by registered mail before making representations that this process will cost their client thousands of dollars and take 60 to 90 days. And if they look into those things and want to make those representations, they can. I suspect if they look into those things, they will not. + +9 10 11 12 13 14 15 16 17 18 I also just have to take issue with the suggestion that we had stonewalled them by refusing to provide an e-mail address. There was electronic discovery in the earlier case. They certainly have e-mails belonging to Ms. Maxwell. I don't think we heard any representation to the contrary. I don't know what those e-mail addresses are. I suspect plaintiff's counsel knows a lot more about Ms. Maxwell's e-mails than we do. No one is suggesting from my client any relief that will add months to this process or cost thousands of dollars to Ms. Maxwell by any means. + +19 20 21 22 23 24 25 THE COURT: Mr. Cassell, Mr. Peluso suggests, first, that there is an easier way of service under the Hague Convention in Great Britain, but that of course depends upon having an address in Great Britain. He suggests that you actually probably in discovery, which I believe you are able to access with the recent order of Judge Sweet, have access to electronic communications that were copied to Ms. Maxwell. + +4 5 6 7 8 9 10 Finally, what you were suggesting record of what could could be given to me month or before with have been given to me now can all be raised a renewed application of supplementing the at the outset or at the end of the for alternative service if in fact this matter has not been resolved before then. If in fact you are right that all of this information shows that it is impractical to serve Ms. Maxwell, then presumably there are alternative means of notice to Ms. Maxwell. Among those would possibly be Haddon service by an e-mail address. and + +11 12 13 14 15 Finally, I decide every motion in an effort to be right. It is the parties who have to deal with whether I am right or not. All I have to do is to decide every motion in the best way that I can and leave to all of you whatever the consequences of that are. + +16 17 18 19 20 21 22 23 24 25 It would be not the best way to start off the case for a plaintiff to say, well, we may not have made the showing to you that we could have or should have made, but blow through it, Judge, live with it. I don't do that. I try to decide every case in the best way that I can. And it seems to me clear that you won't have to spend thousands of dollars in order to effect service, but you do have to have made the diligent inquiries to attempt service before going to the alternative method of service. What that involves, I don't know at the moment, but that is really up to the parties. + +MR. CASSELL: Your Honor, perhaps could I ask one 4 5 question of opposing counsel? Because I think this might be one way of cutting through all this. Let me just tell you what the one question would be. Isn't it true that Ms. Maxwell already has notice of this lawsuit? + +6 7 THE COURT: Well, Haddon can answer if they want. + +8 9 10 MR. PELUSO: I honestly don't know, your Honor. I suspect someone at Haddon can answer that. I could find out, but I don't think that is service, your Honor. + +11 12 13 14 15 16 17 18 19 20 21 22 23 MR. CASSELL: That's the whole purpose of why we are here, your Honor. And, frankly, I think that is one of the reasons why Haddon is not appearing in front of you today, but has hired sort of a surrogate, if you will, so there is a plausible deniability, or whatever the phrase would be. Perhaps one way to proceed would be to ask Haddon that question through counsel that's here today and if they respond that, yes, Ms. Maxwell does indeed have notice of the lawsuit, at that point I would assume that that amply protects any record or shows that all of these hearings and motions and so forth are much ado about nothing, and we could then move with service through Haddon , since it accomplished the goal that it was designed to accomplish. + +24 25 THE COURT: That is not right, actually. The fact that the defendant has notice, if you will, of the lawsuit + +4 5 doesn't substitute for service of the summons and complaint. True that alternative service is meant to provide notice - and, again, the parties can correct me if I am wrong -- but it doesn't simply dispose of the requirement for service of the summons and complaint. + +6 7 8 9 10 11 12 13 14 15 16 17 18 MR. CASSELL: But our limited point, your Honor appreciate the clarification there, but our limited point was that the alternative service motion is designed to provide notice reasonably calculated under all of the circumstances to apprise interested parties of the pendency of the action. And if that apprisal function has already been accomplished, to even have to spend one additional dollar or one additional month tracking things down through London is energy and time and money being expended for no purpose whatsoever, particularly where -- I agree that the summons and so forth should be provided to Ms. Maxwell, but no one is disputing that that will take more than a few seconds on a keyboard for Haddon to forward it along to their client. + +19 20 21 22 23 24 25 THE COURT: Okay. Well, where I was was I will extend the time for service on Ms. Maxwell until January 5, at which point the plaintiff can either file proof of service or an application for alternative service. And just so that there is no question, the application for alternative service, whatever you believe is most appropriate for alternative service should also be filed, because they have appeared for a limited purpose + +on Haddon + +Any response can be filed by January 12. + +4 5 The time to move or answer is 30 days after service in response to the court's decision on service. That will not lose us much time. + +6 7 Any other deadlines or procedural tasks that I should deal with in this order? + +8 9 MR. Your Honor, Mike for Jeffrey Epstein and Lesley Groff. + +10 11 12 13 14 15 16 17 18 19 20 We are scheduled to file a supplemental motion to dismiss within seven days of the issuance of a confidentiality or protective order in this case. We have a draft of it that we will be circulating to the parties hopefully tomorrow or the day after. I guess the only question from a scheduling perspective is whether it makes sense to stay motion practice on the balance of the case until after the service issue is resolved. We are content to go either way, subject to the court's pleasure on the issue, but I just point that out. That could result in motion practice happening sequentially rather than simultaneously. + +21 22 23 THE COURT: Mr. Cassell, do you want the rest of the defendants to answer or move to dismiss without waiting for Ms. Maxwell? + +24 MR. CASSELL: Yes, your Honor. + +25 THE COURT: I thought that would be the response, + +4 Okay. + +5 6 7 8 9 10 MR. CASSELL: Mr. Pottinger may want to step in on this, but we would like to file a single response to all of the supplemental and various motions to dismiss coming in from the various defendants, so we would ask for an opportunity to respond with one single response 14 days after all of the new information comes in from the various defendants. + +11 THE COURT: I assume for everyone but Ms. Maxwell. + +12 MR. CASSELL: Yes, your Honor. + +13 14 15 THE COURT: It seems reasonable to me. Consolidated response by the plaintiff 14 days after the supplemental papers by the defendants. + +16 And then the reply? + +17 18 19 20 MR. : Your Honor, we respectfully request 14 days after we receive the response for the reply brief. And I say that without knowing how that lands in terms of holidays, towards the end of December. + +21 22 23 24 25 Could I suggest this? Rather than set dates right now for the response and the reply, I can tell you, on behalf of the clients I represent -- and I suspect it is true for the other defendants -- that we won't object to a briefing schedule that consolidates the motions other than Maxwell's, but perhaps + +MR. : That's fine, your Honor. + +THE COURT: -- that motion schedule stands. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +we could meet and confer on that issue and submit a proposed schedule to the court once we have a protective order issued from the court. + +THE COURT: That's fine by me. + +Mr. Cassell? + +MR. CASSELL: That sounds like an excellent approach. + +We agree. + +me. THE COURT: Okay. So submit the proposed schedule to + +Anything else? All right. Good afternoon all. + +MR. CASSELL: Thank you, your Honor. + +THE COURT: Sure. + +MR. 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"debug_data/EFTA02819976" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820001/EFTA02820001.md b/marker2/court-jane-doe-43/EFTA02820001/EFTA02820001.md new file mode 100644 index 0000000000000000000000000000000000000000..0f703f7807a46310b51939e8ab7f3264654d6d90 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820001/EFTA02820001.md @@ -0,0 +1,27 @@ +## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +USA / Plaintiff(s) + +Case No.: 17CV616 + +JEFFREY EPSTEIN ET AL., + +Defendant(s) + +## NOTICE OF FILING OF OFFICIAL TRANSCRIPT + +Notice is hereby given that an official transcript of a ARGUMENT held on 11/28/17 has been filed by the court reporter/transcriber in the above-captioned matter. + +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting the transcript is a judge or a member of the public or media. + +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days. + +This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion. + +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. + +/s KRISTEN CARRANATE + +Court Reporter/Transcriber Date \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820001/EFTA02820001.metadata.json b/marker2/court-jane-doe-43/EFTA02820001/EFTA02820001.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e69cb7e42705a4bb022478f06060db67cc6ae9a3 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820001/EFTA02820001.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820001.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1441, + "elapsed_seconds": 0.82, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE UNITED STATES DISTRICT COURT \nFOR THE SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 154.224, + 67.23 + ], + [ + 418.71282958984375, + 67.23 + ], + [ + 418.71282958984375, + 96.363037109375 + ], + [ + 154.224, + 96.363037109375 + ] + ] + }, + { + "title": "NOTICE OF FILING OF OFFICIAL TRANSCRIPT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 168.3, + 308.17889404296875 + ], + [ + 449.1199951171875, + 308.17889404296875 + ], + [ + 449.1199951171875, + 322.1835632324219 + ], + [ + 168.3, + 322.1835632324219 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 26 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820001" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820002/EFTA02820002.md b/marker2/court-jane-doe-43/EFTA02820002/EFTA02820002.md new file mode 100644 index 0000000000000000000000000000000000000000..f135a112c5c50ea8e1e688c31a8a3bcc6806f261 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820002/EFTA02820002.md @@ -0,0 +1,87 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff, + +No. 17 Civ. 00616 (JGK) + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +## NOTICE OF CASE CAPTION CHANGE + +Come now Plaintiff, , by and through undersigned counsel, to notify the Court that she no longer intends to proceed by way of pseudonym, Jane Doe 43. Accordingly, she respectfully requests that the case caption in this matter be changed to note her identity. Accordingly, respectfully requests that the case caption be changed as follows: + +Plaintiff, No. 17 Civ. 00616 (JGK) + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +Dated: January 5, 2018 + +Respectfully submitted, + +BOLES SCHILLER FLEXNER, LLP + +/s/ Arid McCawlev + +Sigrid S. McCawley (Admitted Pro Hac Vice) + +Meredith (Admitted Pro Hac Vice) + +Boies Schiller Flexner LLP + +401 E. Las Olas Blvd., Suite 1200 + +Ft. Lauderdale, FL 33301 + +Tel: (954) 356-0011 + +J. Esq. + +Stanley Pottinger, Esq. + +425 North Andrews Avenue, Suite 2 + +Fort Lauderdale, Florida 33301 + +Tel: (954) 524-2820 + +Fax: (954) 524-2822 + +Paul G. Cassell (Admitted Pro Hac Vice) + +S.J. Quinney College of Law + +University of Utah + +383 University St. + +Salt Lake City, UT 84112 + +(801)585-5202' + +&#x27; This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on the 5th day of January, 2018, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. + +Kimo S. Peluso Sher Tremonte, LLP 90Broad Street, 23rd Floor New York, NY 10004 k luso@shertremonte.com Counsel for Haddon, P.C. + +Laura A. Menninger, Esq. Jeffrey Pagliuc E . HADDON, & 150 East 10th Avenue Denver, Colorado 80203 Email: Imenninger@hrnflaw.com jpagliuca@hmflaw.com + +John E. Stephenson, Jr. Jonathan D. Parente ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, GA 30309 John.stephenson@alston.com Jonathan.parente@alston.com + +Alexander S. Lorenzo ALSTON & BIRD LLP 90 Park Avenue New York, NY 10016 alexander.lorenzo@alston.com Counsel for Defendant + +Michael Justin Michael A. Keou h , P.C. 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Maxwell, Case No. 15-cv-07433 RWS. In that action, Maxwell is represented by counsel who appeared before that Court on her behalf as recently as November 8, 2017. Despite that fact, Maxwell will apparently not authorize her counsel to accept service of the complaint in this case. Indeed, Maxwell's counsel has gone so far as to hire their own separate legal counsel to argue to this Court that they should not have to accept service in this case. Yet in this very case, Maxwell has already actively participated, including having counsel make a request for additional time to serve her answer and attempting to impose + +I Plaintiff has decided to reveal her identity in connection with this matter and has filed a Notice to Change Case Caption. + +restrictions on the case of discovery materials. See DE 69 and November 23, 2017 Letter to Judge Koeltl, Exhibit D. + +While this Court originally granted Plaintiff Motion for Alternate Service (DE 57), Maxwell's counsel sought reconsideration of that Order on October 30, 2017. This Court held a hearing on November 28, 2017 and issued an Order on November 30, 2017 instructing to again attempt service on Defendant Maxwell on or before January 5, 2018: "By that date, the plaintiff will file either proof of service or a renewed application to the alternate service." DE 90. As directed, effectuate service on Maxwell: has made the following attempts to + +- • +- • +- provided Maxwell's counsel of record in the v. Maxwell case a copy of the summons and complaint; emailecl a copy of the summons and complaint to the following email address which is publicly associated with Maxwell, gmax@ellmax.com. See McCawley Decl. at Exhibit 1, December 4, 2017 E-mail; retained, at significant expense, a private investigation firm to attempt to effectuate service at locations associated with Maxwell in New York and New Jersey, including the following addresses: + - 1. 116 E. 65th Street, New York, NY 10065; + - 2. 457 Madison Avenue, 4th Floor, New York, NY 10022; and + - 3. 55 Monterey Avenue, Teaneck, NJ 07666. + +- conducted a public record search of the London Townhome that was identified in Epstein's Phone Directory as being associated with Defendant Maxwell: 44 Kinnerton Street, London. The UK government recoil/nest demonstrates that title to the property was changed on March 17, 2016 to Square Properties Limited and is no longer owned by Defendant Maxwell rendering attempts at service in London futile. See McCawley Decl. at Exhibit 3, Summary of Title NGL948023; and + +As detailed in the affidavit of Investigator Douglas Mercer (See McCawley Decl. at Exhibit 2), at one location, it was clear that individuals were present in the home but were refusing to answer the door and accept service; + +- Defendant Ghislaine Maxwell is also identified as the founder of the TerraMar Project on its website. The organization has a New York address for its headquarters at 326 E. 65th Street #326, New York, New York 10065. The email address identified with the organization is hello@theterramarproject.org. On January 4, 2018, we served a copy of the summons and complaint to the following potential email addresses: + +- 1. pmaxwell@theterramarproject.org; +- 2. maxwellg@theterramarproject.org; +- 3. ghislaine@theterramarproject.org• +- 4. gmax@theterramarproject.org; +- 5. maxwell@theterramarproject.org• and +- 6. ghislaine.maxwell@theterramarproject.org. + +See McCawley Decl. at Exhibit 4. The only email address which received a delivery failure message was maxwell@theterramarproject.org. + +Accordingly, having made renewed — and unsuccessful efforts — to serve Maxwell through conventional means, such means as the Court now renews her request for alternative service as respectfully suggests that, as the Court allowed in its previous order, that service of the complaints on current legal counsel representing her in a related matter before this Court and other publicly identified email accounts be permitted as a means of alternative service. + +## MEMORANDUM OF LAW + +Service of a Complaint should not be a game of cat and mouse particularly where the defendant is represented by counsel in a matter pending in the same district. See Carillo v. Hagerty, No. 3:05CV1417 (MRK), 2006 WL 2165679, at \*1 (D. Conn. July 31, 2006) (court finding defendant should not benefit from service gamesmanship reasoning that: "service of process is not intended to be a game of hide and seek or cat and mouse."). + +Based on the exhaustion of the other methods of service delineated above, moves, pursuant to Federal Rule of Civil Procedure 4(e)(1), for an order permitting service by an alternative method. Federal Rule of Civil Procedure 4(e)(1) provides that service upon a party may be effected by "following state law for serving a summons in an action brought in courts of general jurisdiction in the state where the district court is located or where service is made." Accordingly, Defendant Maxwell may be served pursuant to CPLR § 308, which provides several methods by which service upon a natural person may be effectuated, including personal service; service by "delivering the summons ... to a person of suitable age and discretion at the actual place of business, dwelling place or usual place of abode of the person to be served" and then mailing the summons to the individual's "last know residence;" or service by "affixing the summons to the door of either the actual place of business, dwelling place or usual place of abode within the state of the person to be served" and then "mailing the summons to such person at his or her last known residence" or to his or her place of business - so called "nail and mail" service. CPLR §§ 308(1), (2) & (4). + +If service under CPLR §§ 308(1), (2) & (4) is impracticable, CPLR § 308(5) permits service "in such manner as the court, upon motion without notice, directs." The determination of whether service is impracticable "depends upon the facts and circumstances of a particular case." Securities & Exch. Comm'n v. HGI, Inc., No. 99 Civ. 3866 (DLC), 1999 WL 1021087, at \*1 (S.D.N.Y. Nov. 8, 1999). Although the plaintiff must show impracticability of service, there is no requirement of "proof of due diligence or of actual prior attempts to serve a party under the other provisions of the statute." Id. "When usual methods of service prove impracticable, service + +that is reasonably calculated, under all the circumstances, to apprise the interested party of the pendency of the action will suffice." D.R.I., Inc. v. Dennis, No. 03 Civ. 10026 (PKL), 2004 WL 1237511, at \*1 (S.D.N.Y. June 3, 2004). + +New York Courts consistently affirm their right to direct or approve alternative methods of service where regular service has been deemed "impracticable." For example, in Dobkin v. Chapman, 21 N.Y.2d 490, 498, 289 N.Y.S.2d 161, 168 (1968), the New York Court of Appeals held that where a plaintiff could not follow the prescribed methods of service as set forth in § 308, Courts are "given the discretion to fashion other means adapted to the particular facts of the case before it" pursuant to § 308(5) (referred to in Dobkin as § 308(4), the predecessor to § 308(5)). Moreover, the Court of Appeals held that a Court's discretion to fashion such methods of service "must be broad" if the statute is to be "meaningful." Id. at 499, 289 N.Y.S.2d at 168. + +There is no doubt that Defendant Maxwell has had actual notice and knowledge of the claims asserted in this Complaint. has tried multiple alternative avenues to serve Maxwell, including (1) sending the documents to her current counsel in another matter, (2) investigating and attempting service at multiple locations known to be associated with Defendant Maxwell, and (3) emailing the documents to Defendant Maxwell's publicly available email address. As a result, this Court should deem the service methods attempted to be sufficient and grant the Motion for Alternate Service. See Rampersad v. Deutsche Bank Secs., Inc., No. 02 Civ. 7311 (LTS), 2003 WL2I073951, at \*1 (S.D.N.Y. May 9, 2003) (authorizing alternative service under § 308(5) when Plaintiff was unable to determine Defendant's residence or place of business after "extensive Internet searches" and inquires with Defendant's former clients); Javier IL v. -Botello, 217 F.R.D. 308, 309 (W.D.N.Y. 2003) (service by publication authorized when individual Defendant was a fugitive from the criminal justice system; was likely aware of + +the pending civil action through his relatives, who were co-Defendants; and when the Court determined that Defendant would likely read a newspaper that was circulated in the region of his last known residence); see also Inc., 1999 WL 1021087, at \*1 (service by publication in USA Today authorized when Defendant's whereabouts were unknown, efforts to locate his home or business address by searching computer databases failed, and there existed no record that he designated an agent for service); aR.1., Inc., 2004 WL 1237511, at \*2 (after Plaintiff unsuccessfully attempted to serve Defendant through a process server and searched databases for his address, Court authorized service by sending process by certified mail to Defendant's last known address; by publishing the action in a local newspaper; and by emailing it to Plaintiffs last known email address). + +WHEREFORE, Plaintiff prays for this Court to enter an Order granting Plaintiff's Motion to Approve Alternative Service Pursuant to Federal Rule of Civil Procedure 4(e)(1) and New York Civil Practice Law and Rules Section 308(5) upon Defendant Ghislaine Maxwell and finding that the service efforts made by Plaintiff's counsel herein are sufficient. Dated: January 5, 2018 + +Respectfully submitted, + +BOLES SCHILLER FLEXNER LLP + +/s/ Sigrid McCawley + +Sigrid S. McCawley (Admitted Pro Hac Vice) + +Meredith (Admitted Pro Hac Vice) + +Boies Schiller Flexner LLP + +401 E. Las Olas Blvd., Suite 1200 + +Ft. Lauderdale, FL 33301 + +Tel: (954) 356-0011 + +J. M, Esq. + +Stanley Pottinger, Esq. + +425 North Andrews Avenue, Suite 2 + +Fort Lauderdale, Florida 33301 + +Tel: (954) 524-2820 Fax: (954) 524-2822 + +Paul G. Cassell (Admitted Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-52022 + +2 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on the 5th day of January, 2018, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. + +Kimo S. Peluso Sher Tremonte, LLP 90Broad Street, 23rd Floor New York, NY 10004 k luso@shertremonte.com Counsel for Haddon, & P.C. + +Laura A. Menninger, Esq. Jeffrey Pagliuca E. . HADDON, & 150 East 10th Avenue Denver, Colorado 80203 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com + +John E. Stephenson, Jr. Jonathan D. Parente ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, GA 30309 John.stephenson@alston.com Jonathan.parente@alston.com + +Alexander S. Lorenzo ALSTON & BIRD LLP 90 Park Avenue New York, NY 10016 alexander.lorenzo@alston.com Counsel for Defendant + +Michael Justin Michael A. Keou h , P.C. STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoe.com jchu@steptoe.com Counsel for Defendants, Jeffrey Epstein and Lesley Groff + +/s Sigrid McCawlev Sigrid McCawley \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820005/EFTA02820005.metadata.json b/marker2/court-jane-doe-43/EFTA02820005/EFTA02820005.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e8cd8306bfdf96f4f7e640fdde9d8507e47f652c --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820005/EFTA02820005.metadata.json @@ -0,0 +1,425 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820005.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 8, + "chars": 12284, + "elapsed_seconds": 1.35, + 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/dev/null +++ b/marker2/court-jane-doe-43/EFTA02820013/EFTA02820013.md @@ -0,0 +1,15 @@ +## EXHIBIT 1 + +From: Sigrid McCawley Sent Monday, December 04, 2017 6:13 PM To: gmaxl@ellmax.com Cc: brad@epllc.com; 'StanPottinger@aol.com' er@aol.com); Paul Cassell (cassellp@law.utah.edu); Meredith =; Brittany (brittany@epllc.com) Subject: Complaint & Summons Attachments: 2017-01-26 [DE 1] Complaint.pdf; 2017-10-04 [DE 64] Electronic Summons Issued-Maxwell.pdf; 2017-06-05 [DE 45] First Amended Complaint.pdf + +Hello Ms. Maxwell, + +Please see the attached which is a complaint and an amended complaint filed against you and the related summons. + +Thank you, Sigrid + +Sigrid McCawley Partner + +BOIES SCHILLER FLEXNER LLP + +401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 (t) +1 954 377 4223 (m)+1 954 770 5377 smccawlevabsfllo.corn www.bsfllp.com \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820013/EFTA02820013.metadata.json b/marker2/court-jane-doe-43/EFTA02820013/EFTA02820013.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..37cac3e63e928f5337835eaddd29a8db1bc8893f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820013/EFTA02820013.metadata.json @@ -0,0 +1,116 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820013.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 755, + "elapsed_seconds": 0.53, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "EXHIBIT 1", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 216.036, + 305.37 + ], + [ + 399.2649230957031, + 305.37 + ], + [ + 399.2649230957031, + 344.2991638183594 + ], + [ + 216.036, + 344.2991638183594 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 5 + ], + [ + "Line", + 3 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "Line", + 23 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820013" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820015/EFTA02820015.md b/marker2/court-jane-doe-43/EFTA02820015/EFTA02820015.md new file mode 100644 index 0000000000000000000000000000000000000000..76ebb9c04107f345bb9aa4cc84ecdd1a3a7fcec3 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820015/EFTA02820015.md @@ -0,0 +1,43 @@ +## EXHIBIT 2 + +UNITED STATES DISTRICT COURT +for the +Southern District of New York + +Jane Doe 43, Plaintiff + +v. + +Civil Action No.17-cv-616 + +Jeffrey Epstein, Ghislaine Maxwell +Sara [REDACTED], Lesley Groff, Defendant (s) + +AFFIDAVIT + +Douglas G. Mercer, being duly sworn deposes and states: + +1. 1. I am employed as the Chief Investigator by Alpha Group Investigations, an investigative services company. I supervised the service of a Summons in a Civil Action, Complaint and First Amended Complaint to be served on Ghislaine Maxwell. +2. 2. On Wednesday, December 6th, 2017 Alpha Group Research Analyst [REDACTED] Dorilio Identified three addresses in the New York City area that are currently associated with Ghislaine Maxwell, or have been associated with Ghislaine Maxwell: 116 E. 65th Street, New York, New York 10065; 457 Madison Avenue, fourth floor, New York, New York 10022 and 55 Monterey Avenue, Teaneck, New Jersey 07666. Mr. Dorilio was unsuccessful in locating any other current known or associated addresses for Ghislaine Maxwell in the New York City area. +3. 3. On Thursday, December 14th, 2017 at 11:55 am Alpha Group Investigator Kevin [REDACTED] arrived at 55 Monterey Avenue, Teaneck, New Jersey, which appeared to be a two-story single-family home. The investigator knocked on the front door and rang the doorbell several times, but no one answered the door, although the investigator could hear voices within the residence. Investigator [REDACTED] served the Summons in a Civil Action, Complaint and First Amended Complaint for Ghislaine Maxwell by placing them in the mailbox adjacent to the front door. +4. 4. On Thursday, December 14th, 2017 at 1:00 pm Alpha Group Investigator Kevin [REDACTED] arrived at 116 E. 65th Street, New York, New York, which appeared to be a five-story residence. Investigator [REDACTED] observed numerous old newspapers in plastic bags on the steps in front of the front door. Investigator [REDACTED] did not observe any footprints in the freshly fallen snow by the front door. Investigator [REDACTED] rang the door bell several times and knocked on the front door several times, but no one answered. Investigator [REDACTED] served the Summons in a Civil Action, Complaint and First Amended Complaint for Ghislaine Maxwell by placing them by the front door. +5. 5. On Thursday, December 14th, 2017 at 1:45 pm Alpha Group Investigator Kevin [REDACTED] arrived at 457 Madison Avenue, which was also known as the Trunk Club. Investigator [REDACTED] entered the building and spoke to a Caucasian male, 21-35 years old, [REDACTED] hair who was seated behind a desk in the lobby. Investigator [REDACTED] was advised by the male behind the desk that Ghislaine Maxwell had not resided at the location for some time. Investigator [REDACTED] served the Summons in a Civil Action, + +Complaint and First Amended Complaint for Ghislaine Maxwell to the male at the front desk in the lobby. + +- 6. On Thursday, December 14th, 2017 your deponent mailed copies of the Summons in a Civil Action, Complaint and First Amended Complaint for Ghislaine Maxwell by placing them in plain genvelopes, each addressed to Ghislaine Maxwell, which were marked "persona confidential. Your deponent then mailed the envelopes to 116 E. 65th Street, New York, New York 10065; 457 Madison Avenue, fourth floor, New York, New York 10022 and 55 Monterey Avenue, Teaneck, New Jersey 07666 by placing the envelopes in in an official depository under the exclusive care and custody of the U.S. Postal Service. +- 7. Sirsday, December 21th, 2017 at 12:55 pm Alpha Group Investigator Kevin arrived at 55 Monterey Avenue, Teaneck, New Jersey, which appeared to be a two-story single-family home. The investigator knocked on the front door and rang the doorbell several times, but no one answered the door. Investigator stayed outside the residence in case someone did open the door, but he did n anyone at the residence. The investi ator did hear a dog barking from within the house. At 1:05 pm Investigator served the Summons in a Civil Action, Complaint and First Amended Comp aint for Ghislaine Maxwell by placing them in the mailbox adjacent to the front door. +- 8. On Thursday, December 21tt, 2017 your deponent mailed a copy of the Summons in a Civil Action, Complaint and First Amended Complaint for Ghislaine Maxwell by placing the documents in plain envelope addressed to Ghislaine Maxwell, which was marked "personal & confiden is . Your deponent then mailed the envelope to 55 Monterey Avenue. Teaneck, New Jersey 07666 by placing the envelopes in in an official depository under the exclusive care and custody of the U.S. Postal Service. +- 9. Your deponent is familiar with the process for serving court papers and it is unlikely that other reasonable efforts would have produced successful service on Ghislaine Maxwell. + +Sworn to before me this 21th\_sla y of December, 2017. + +Enza CiC nWJD Notary u lc + +ENZA M NOTARY PUBLIC-STATE OF NEW YORK No. 01MI6137216 Qualified in Suffolk County + +My Commission Expltes November 21.)0T7 + +02.4 + +ENZA M -1IC STATE OF NEW YORK 011416137216 in Suffolk County oi Expiates November 21. 2017 DOUGLAS a /MERCER \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820015/EFTA02820015.metadata.json b/marker2/court-jane-doe-43/EFTA02820015/EFTA02820015.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..61ec108acb25cb6e9f8704903b4bd198716d18e2 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820015/EFTA02820015.metadata.json @@ -0,0 +1,181 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820015.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 5224, + "elapsed_seconds": 9.08, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "EXHIBIT 2", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 215.42399999999998, + 305.37 + ], + [ + 400.9447326660156, + 305.37 + ], + [ + 400.9447326660156, + 344.2991638183594 + ], + [ + 215.42399999999998, + 344.2991638183594 + ] + ] + }, + { + "title": "UNITED STATES DISTRICT COURT for the Southern District of New York", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 190.332, + 68.29200000000002 + ], + [ + 377.604, + 68.29200000000002 + ], + [ + 377.604, + 107.31600000000002 + ], + [ + 190.332, + 107.31600000000002 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 5 + ], + [ + "Line", + 3 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 12 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 100 + ], + [ + "Line", + 47 + ], + [ + "Text", + 8 + ], + [ + "ListItem", + 4 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820015" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820018/EFTA02820018.md b/marker2/court-jane-doe-43/EFTA02820018/EFTA02820018.md new file mode 100644 index 0000000000000000000000000000000000000000..0a37b1b5e130b9481d00ae4a99766dffe24a49a1 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820018/EFTA02820018.md @@ -0,0 +1,41 @@ +## EXHIBIT 3 + +![](_page_1_Picture_1.jpeg) + +c' • GOV.UK + +Find property information + +## Summary of title NGL948023 + +Purchased on 19 December 2017 at 20:31:44. + +This information can change if we receive an application. This service is unable to tell you whether or not there is an application pending with HM Land Registry. + +Address: 44 Kinnerton Street London SW1X 8ES + +Leaseholder: Square Properties Limited + +70 Grosvenor Street London W1K 3JP + +Tenure: Leasehold + +This title was last changed on 17 March 2016 at 14:45:52. + +## VAT Receipt + +Date: 19 December 2017 at 20:31:44 HM Land Registry + +Transaction ID: 9527599532 Trafalgar House + +Description: Summary of title: NGL948023 1 Bedford Park + +Net amount: £2.50 Croydon + +VAT @ 20%: E0.50 CRO 2AQ + +Total inc VAT: £3.00 VAT registration number: + +GB 8888181 53 + +If you have any problems with your purchase, you can contact HM Land Registry on 0300 006 0411. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820018/EFTA02820018.metadata.json b/marker2/court-jane-doe-43/EFTA02820018/EFTA02820018.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a10fcd92057783506d07c5b2a944c3a53810eb38 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820018/EFTA02820018.metadata.json @@ -0,0 +1,172 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820018.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 902, + "elapsed_seconds": 1.0, + "image_assets": [ + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "EXHIBIT 3", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 216.036, + 362.88 + ], + [ + 399.6298828125, + 362.88 + ], + [ + 399.6298828125, + 402.0491638183594 + ], + [ + 216.036, + 402.0491638183594 + ] + ] + }, + { + "title": "Summary of title NGL948023", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 32.725, + 93.95800000000001 + ], + [ + 311.2916564941406, + 93.95800000000001 + ], + [ + 311.2916564941406, + 118.81298828125 + ], + [ + 32.725, + 118.81298828125 + ] + ] + }, + { + "title": "VAT Receipt", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 32.725, + 518.062 + ], + [ + 117.82726287841797, + 518.062 + ], + [ + 117.82726287841797, + 536.3994445800781 + ], + [ + 32.725, + 536.3994445800781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 5 + ], + [ + "Line", + 3 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 26 + ], + [ + "Text", + 17 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820018" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820018/_page_1_Picture_1.jpeg b/marker2/court-jane-doe-43/EFTA02820018/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..261bbb25d93b686f80f373858fdec3d7b73d567e --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820018/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e5af963b0e0627dd733f610e940a0f737c5ff9beae963713136055f2df907a50 +size 2196 diff --git a/marker2/court-jane-doe-43/EFTA02820020/EFTA02820020.md b/marker2/court-jane-doe-43/EFTA02820020/EFTA02820020.md new file mode 100644 index 0000000000000000000000000000000000000000..301be07064e0c5c05d6435e889dc19f6c752b68c --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820020/EFTA02820020.md @@ -0,0 +1,25 @@ +## EXHIBIT 4 + +From: Aneisha Christie Sent Thursday, January 04, 2018 3:41 PM To: 'gmaxwell@theterramarproject.org; 'maxwellg@theterramarprojectorg'; 'ghislaine@theterramarproject.org'; 'gmax@theterramarprojectorg'; 'maxwellOtheterramarprjectorg'; 'ghislaine.maxwell@theterramarprojeci, Cc: 'Brad istanpottinger; 'Paul Cassell'; Meredith ; Brittany • Sigrid McCawley Subject: Jane Doe 43 v. 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Las Olas Blvd., Suite 1200 + +Fort Lauderdale, FL 33301 + +(t) +1 954 377 4236 + +(m)+1 954 356 0011 + +achristie(ThbsfIlp.com + +www.bsfllp.com \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820020/EFTA02820020.metadata.json b/marker2/court-jane-doe-43/EFTA02820020/EFTA02820020.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1f734774ad577ffd0435ecf5ee8a05c4cf563db3 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820020/EFTA02820020.metadata.json @@ -0,0 +1,143 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820020.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1001, + "elapsed_seconds": 0.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "EXHIBIT 4", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 215.42399999999998, + 362.88 + ], + [ + 401.1722106933594, + 362.88 + ], + [ + 401.1722106933594, + 402.0491638183594 + ], + [ + 215.42399999999998, + 402.0491638183594 + ] + ] + }, + { + "title": "Aneisha Christie", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 33.660000000000004, + 49.41 + ], + [ + 130.10189819335938, + 49.41 + ], + [ + 130.10189819335938, + 64.214111328125 + ], + [ + 33.660000000000004, + 64.214111328125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 5 + ], + [ + "Line", + 3 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 52 + ], + [ + "Line", + 27 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820020" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820022/EFTA02820022.md b/marker2/court-jane-doe-43/EFTA02820022/EFTA02820022.md new file mode 100644 index 0000000000000000000000000000000000000000..d3141951ec0b7e0dbf4afaab376c6bd99cdcbfb0 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820022/EFTA02820022.md @@ -0,0 +1,89 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff, No. 17 Civ. 00616 (JGK) + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +## DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF'S RENEWED MOTION TO APPROVE ALTERNATE SERVICE PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 4(eX1) + +I, Sigrid McCawley, declare that the below is true and correct to the best of my knowledge as follows: + +- I. I am a Partner with the law firm of Boies, Schiller & Flexner LLP and duly licensed to practice in Florida and before this Court pursuant to this Court's Order granting my Application to Appear Pro Hac Vice. +- 2. I respectfully submit this Declaration in Support of Plaintiff's Renewed Motion to Approve Alternate Service Pursuant to Federal Rule of Civil Procedure 4(e)(1). +- 3. Attached hereto as Exhibit 1 is a true and correct copy of the December 4, 2017 E-mail serving Summons and Complaint to E-mail address gmax@ellmax.com. +- 4. Attached hereto as Exhibit 2 is a true and correct copy of the December 21, 2017, Affidavit of Chief Investigator, Douglas Mercer of Alpha Group Investigations detailing his company's efforts to serve Defendant Ghislaine Maxwell. + - 5. Attached hereto as Exhibit 3 is a true and correct copy of Gov.UK's Summary of + +Title NGL948023. + +6. Attached hereto as Exhibit 4 is a true and correct copy of the January 4, 2018, Email serving the Summons and Complaint to E-mail gmaxwell@theterramarproject.org and other potentially associated email addresses. + +I declare under penalty of perjury that the foregoing is true and correct. + +Dated: January 5. 2018. + +Respectfully Submitted, + +BOLES, SCHILLER & FLEXNER LLP + +By: /s/ Sigrid McCawley + +Sigrid McCaS (Pro Hac Vice) + +Meredith (Pro Hac Vice) + +Boies Schiller & Flexner LLP + +401 E. Las Olas Blvd., Suite 1200 + +Ft. Lauderdale, FL 33301 + +(954) 356-0011 + +at (Pro Hac Vice) + +. JAFFE, WEISSING, + +FISTOS & LEHRMAN, P.L. + +425 North Andrews Avenue, Suite 2 + +Fort Lauderdale, Florida 33301 + +(954) 524-2820 + +Paul G. Cassell (Pro Hac Vice) + +S.J. Quinney College of Law + +University of Utah + +383 University St. + +Salt Lake City, UT 84112 + +(801) 585-5202' + +This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on the 5th clay of January, 2018, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. + +Kimo S. Peluso Sher Tremonte, LLP 90Broad Street, 23rd Floor New York, NY 10004 k luso@shertremonte.com Counsel for Haddon, & P.C. + +Laura A. Menninger, Esq. Jeffrey Pagliuca Es . HADDON, & 150 East 10th Avenue Denver, Colorado 80203 Email: linenninger@hinflaw.com ipagliuca@hmflaw.com , P.C. + +John E. Stephenson, Jr. Jonathan D. Parente ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, GA 30309 John.stephenson@alston.com Jonathan.parente@alston.com + +Alexander S. Lorenzo ALSTON & BIRD LLP 90 Park Avenue New York, NY 10016 alexander.lorenzo@alston.com Counsel for Defendant + +Michael Justin Y.K Michael A. Keou h STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoe.com jchu@steptoe.com Counsel for Defendants, Jeffrey Epstein and Lesley Groff + +/s/ Sigrid McCawley Sigrid McCawley \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820022/EFTA02820022.metadata.json b/marker2/court-jane-doe-43/EFTA02820022/EFTA02820022.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..30010d9b52780f93d20c069ded5514b4268ad7c4 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820022/EFTA02820022.metadata.json @@ -0,0 +1,216 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820022.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3537, + "elapsed_seconds": 1.3, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 72.9 + ], + [ + 293.59381103515625, + 72.9 + ], + [ + 293.59381103515625, + 103.863037109375 + ], + [ + 69.156, + 103.863037109375 + ] + ] + }, + { + "title": "DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF \nPLAINTIFF'S RENEWED MOTION TO APPROVE ALTERNATE SERVICE \nPURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 4(eX1)", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 98.53200000000001, + 302.94 + ], + [ + 514.1724243164062, + 302.94 + ], + [ + 514.1724243164062, + 346.4830322265625 + ], + [ + 98.53200000000001, + 346.4830322265625 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 223.38, + 72.08999999999999 + ], + [ + 388.520263671875, + 72.08999999999999 + ], + [ + 388.520263671875, + 86.2330322265625 + ], + [ + 223.38, + 86.2330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 27 + ], + [ + "Text", + 7 + ], + [ + "ListItem", + 5 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 32 + ], + [ + "Text", + 25 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Footnote", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 96 + ], + [ + "Line", + 48 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820022" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820025/EFTA02820025.md b/marker2/court-jane-doe-43/EFTA02820025/EFTA02820025.md new file mode 100644 index 0000000000000000000000000000000000000000..05ef8926e671586789e517d66a55f5caa2a19610 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820025/EFTA02820025.md @@ -0,0 +1,47 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +Plaintiff, + +vs. + +JEFFREY EPSTEIN GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +Defendants. + +CASE NO. 17 Civ 616 (JCL() + +## CONFIDENTIALITY STIPULATION AND (PROPOSED) ORDER + +WHEREAS, the Court issued an order on November 22, 2017 granting defendants the opportunity to submit a supplemental motion to dismiss the complaint in this action ("Supplemental Motion") (ECF it 85) (the "November 22 Order"); + +NOW THEREFORE, in accordance with the November 22 Order and Federal Rule of Civil Procedure 26(c), and upon the stipulation and consent of the parties through their counsel indicated below ("Parties"), it is SO ORDERED that: + +- 1. As consented to by Ghislaine Maxwell, the deposition of Jane Doe 43 taken in the matter captioned v. Maxwell, Case No. I 5-cv-07433(RWS) a Action"), and exhibits marked at that deposition (collectively "Jane Doc Transcript"), may be used in connection with the Supplemental Motion. Such use shall be restricted as follows: + - a. The Jane Doe Transcript may only be used for purposes of the Supplemental Motion; + - b. The dissemination of the Jane Doe Transcript is restricted to the parties in this action, the parties' lawyers who are working on this matter, and the Court; and + +- c. Any Jane Doe Transcript used in connection with the Supplemental Motion shall be filed under seal and not accessible to the public, and the parties will redact any of the Jane Doe Transcript from their public filings and submit under seal any portions of the Jane Doe Transcript. +- 2. Notwithstanding the foregoing, nothing herein shall restrict the rights of the Parties to: (a) seek discovery of materials, including the Jane Doe Transcript, from any of the Parties or non-parties in the ordinary course of discovery in this action, in the event that this action survives the motions to dismiss; and (b) use without restriction any materials, including the Jane Doe Transcript, that are obtained in such discovery. Nothing herein is intended to restrict Jane Doe 43 from using her own materials in any manner she deems appropriate, provided that should Jane Doe 43 use any materials outside of the Jane Doe Transcript, Defendants may use all of the materials produced by Jane Doe 43 in the Action in connection with the Supplemental Motion. +- 3. This Stipulation and Order may be modified by the Court at any time for good cause shown following notice to all panics and an opportunity for them to be heard. + +Dated: + +Dated: t b + +lc/ AND POTfINGER By;,\_ e - Brad Attorney for Plaintiff Jane Doe 43 < - 17\_ + +> STEPTQfi & J011405,47-", ,7". By: / • / Michael Attorneys for Defendants Jeffrey Epstein and Lesley Groff + +Date& eihom + +SO ORDERED, + +UNITED STATES DISTRICT JUDGE + +ALSTON & BIRD, LLP + +By:AAL--"pcir" .° + +Alexander S Lorenzo John E. 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MI 212 506 3955 mmiller©steptoe.com + +1114 Avenue of the Americas New York, NY 10036 212 506 3900 main www.sleptoe.com + +January 17, 2018 + +## VIA ECF + +Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 + +Dear Judge KocIt]: + +![](_page_0_Picture_2.jpeg) + +We represent Defendants Jeffrey Epstein and Lesley Groff in the above-referenced matter. We write jointly on behalf of Plaintiff Jane Doe 43 and Defendants Epstein, Groff and (collectively, the "Parties") and submit the enclosed Confidentiality Stipulation and [Proposed] Order ("Proposed Order") pursuant to the Court's directive set forth at the conference of November 28, 2017. + +The Parties have reached agreement on the Proposed Order after engaging in several rounds of negotiation and exchanging several rounds of drafts. The Parties hereby respectfully request the Court to enter the Proposed Order. + +In accordance with the Court's prior orders, Defendants will e their supplemental motion to dismiss seven (7) days after the Proposed Order is en d y the Cou + +edit b + +Michael C. 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As consented to by Ghislaine Maxwell, the deposition of Jane Doe 43 taken in the matter captioned [REDACTED] v. *Maxwell*, Case No. 15-cv-07433(RWS) ("[REDACTED] Action"), and exhibits marked at that deposition (collectively "Jane Doe Transcript"), may be used in connection with the Supplemental Motion. Such use shall be restricted as follows. + 1. a. The Jane Doe Transcript may only be used for purposes of the Supplemental Motion; + 2. b. The dissemination of the Jane Doe Transcript is restricted to the parties in this action, the parties' lawyers who are working on this matter, and the Court and *[Signature]* and Court personnel, + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC# +DATE FILED: 1-19-18 + +c Any Jane Doe Transcript used in connection with the Supplemental Motion shall be filed under seal and rot accessible to the public, and the panics will redact any of the Jane Doe Transcript from the:I public filings and submit under seal any portions of the Jane Doe Transcript. + +2. Notwithstanding the foregoing, nothing herein shall restna the rights of the Parties to (a) seek discovery of materials, including the Jane Doe Tiansaipt, from any of the Parties or non-parties in the ordinary course of discovery in this action. in the event that this action survive% the motions to dismiss, and (b) use without restriction any matenals. including the Jane Doc Transei mt. :hat are obtained in such discovery. Nothing herein is intended to restrict Jane Doe 43 from using her own materials in any manner she deems appropriate, provided that should Jane Doe 43 use any materials outside of the Jane Doe Transcript, Defendants may use all of the materials produced by Jane Doe 43 in the Action in connection with the Supplemental Motion + +3. This Stipulation and Order may be modified by the Court at any time for good cause , + +Dated' 5aA 2 c ib) + +Dated k // /I 8 + +AND POTrNGER + +Brad Attorney for Plpintiff Jane Doe 43 ' / + +STEPT9fl & JoH,p;soN. + +By: t.,/ `Cy Michael IN Attorneys for Defendants Jeffrey Epstein and Lesley Groff + +F PRIPERED: + +.Jr + +Dated: January 17, 2018 + +ALSTON & BIRD, LLP + +![]()Alexander S Lorenzo + +John E. Stephenson, Jr. + +Attorneys for Defendant [REDACTED] + +SO ORDERED, + +UNITED STATES DISTRICT JUDGE \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820029/EFTA02820029.metadata.json b/marker2/court-jane-doe-43/EFTA02820029/EFTA02820029.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5c332177c014d3b70d743b59f02ad8dd044530f6 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820029/EFTA02820029.metadata.json @@ -0,0 +1,165 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820029.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3119, + "elapsed_seconds": 6.5, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 89.64399999999999, + 108.53999999999999 + ], + [ + 280.598, + 108.53999999999999 + ], + [ + 280.598, + 131.22 + ], + [ + 89.64399999999999, + 131.22 + ] + ] + }, + { + "title": "CONFIDENTIALITY STIPULATION AND [PROPOSED] ORDER", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 139.99200000000002, + 289.17 + ], + [ + 442.694, + 289.17 + ], + [ + 442.694, + 300.51 + ], + [ + 139.99200000000002, + 300.51 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 14 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 29 + ], + [ + "Text", + 13 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 13 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 3 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820029" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820032/EFTA02820032.md b/marker2/court-jane-doe-43/EFTA02820032/EFTA02820032.md new file mode 100644 index 0000000000000000000000000000000000000000..3ebc5e3c2c1bd3f6124ccba68840481e00a8658b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820032/EFTA02820032.md @@ -0,0 +1,31 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +Plaintiff, + +-against- + +JEFFREY EPSTEIN, GHISLANE MAXWELL, EM, LESLEY GROFF and NATALYA + +Defendants. + +Case No. 17-cv-00616 (JGK) + +NON-PARTY HADDON & P.C.'S RESPONSE TO PLAINTIFF'S RENEWED MOTION FOR ALTERNATIVE SERVICE + +Non-Party Haddon, & EM, P.C. ("Haddon M"), through its undersigned counsel, submits this statement in response to Plaintiff's Renewed Motion to Approve Alternative Service filed on January 5, 2018 (Dkt. No. 97) (the "Renewed Motion"). + +Haddon opposes the Renewed Motion to the extent Plaintiff seeks an order compelling Haddon to accept service of process on Maxwell's behalf, or service of other pleadings and documents, in this action or in any other matter. Haddon has not been authorized to accept any such service and objects to becoming the general agent of process for + +takes no position with respect to Plaintiff's request for an order by this Court deeming the Complaint served on Defendant Maxwell, to the extent based on email transmissions as described in Plaintiff's Renewed Motion and accompanying papers. + +Dated: New York, New York January 21, 2018 + +SHER TREMONTE LLP + +By: /s/Kinzo S. Peluso Kimo S. Peluso Justine A. Harris + +90 Broad Street, 23rd Floor New York, New York 10004 (212) 202-2600 (212) 202-4156 (fax) kpeluso@shertremonte.com + +Attorneys for Haddon, P.C. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820032/EFTA02820032.metadata.json b/marker2/court-jane-doe-43/EFTA02820032/EFTA02820032.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bf5c4c6a9168a833f87972d0df06aa6ee953dd47 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820032/EFTA02820032.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820032.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1378, + "elapsed_seconds": 0.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 67.932, + 70.47 + ], + [ + 293.59381103515625, + 70.47 + ], + [ + 293.59381103515625, + 100.10302734375 + ], + [ + 67.932, + 100.10302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 28 + ], + [ + "Line", + 15 + ], + [ + "Text", + 7 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 26 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820032" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820034/EFTA02820034.md b/marker2/court-jane-doe-43/EFTA02820034/EFTA02820034.md new file mode 100644 index 0000000000000000000000000000000000000000..abbf58dc7ab6cd7e120517a138f0e4fb8f15be17 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820034/EFTA02820034.md @@ -0,0 +1,27 @@ +Michael C. 212 506 3955 mmiller©Meptoe.com + +1114 Avenue of the Americas New York, NY 10036 212 506 3900 main vAvw.steptoe.com + +![](_page_0_Picture_2.jpeg) + +January 23, 2018 + +## VIA ECF + +Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 + +Dear Judge Koeltl: + +We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") in the abovereferenced matter and write to request permission to file a 30-page brief in support of Defendants' supplemental motion to dismiss. + +The brief that Defendants plan to submit will provide rounds for dismissal that are applicable not olio Defendants, but also to defendant ("n). We understand that plans to adopt certain of the arguments to be set forth in Defendants' brief, instead of repeating them in her brief. We further understand that will separately file a brief, but primarily to set forth additional grounds for dismissal that are applicable to her. We expect that the total pages of the two briefs will be under 50. + +The Court entered the Confidentiality Stipulation and Order ("Confidentiality Order") on January 19, 2018 (ECF # 100). In accordance with the Court's order dated November 22, 2017 (ECF # 85) providing for seven (7) days from the entry of the Confidentiality Order to file the supplemental motions to dismiss, Defendants will file their motion on January 26, 2018. + +Defendants therefore respectfully request permission to fi 0-page brief. + +.Respe fully sub d, 6 + +Michael C. 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NY 10036 212 506 3900 main www steptoe.com + +## VIA ECF + +Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +## APPLICATION GRANTED SO ORDERED + +aoho G. Koeltl, U.S.D.J. + +January 23, 2018 + +Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 + +Dear Judge Koeltl: + +We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") in the abovereferenced matter and write to request permission to file a 30-page brief in support of Defendants' supplemental motion to dismiss. + +The brief that Defendants plan to submit will provide rout ds dismissal that are applicable not orlio Defendants, but also to defendant n• We understand that plans to adopt certain of the arguments to be set forth in Defendants' brief, instead of repeating them in her brief. We further understand that will separately file a brief, but primarily to set forth additional grounds for dismissal that are applicable to her. We expect that the total pages of the two briefs will be under 50. + +The Court entered the Confidentiality Stipulation and Order ("Confidentiality Order") on January 19, 2018 (ECF # 100). In accordance with the Court's order dated November 22, 2017 (EC!: # 85) providing for seven (7) days from the entry of' the Confidentiality Order to file the supplemental motions to dismiss, Defendants will file their motion on January 26, 2018. + +Defendants therefore respectfully request permission to fl 0-page brief. + +Cc ully sub ted, + +Michael C. Counsel for Defendants Jeffrey Epstein and Lesley Groff + +USDC SDNY DOCUMENT ELECTRONiCAl PLED DOCti DATE FILED: \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820035/EFTA02820035.metadata.json b/marker2/court-jane-doe-43/EFTA02820035/EFTA02820035.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..519e0b09282c55bb6475b4a482f236a73486ee1f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820035/EFTA02820035.metadata.json @@ -0,0 +1,119 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820035.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1718, + "elapsed_seconds": 1.05, + "image_assets": [ + "_page_0_Picture_4.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 80.434, + 178.66168212890625 + ], + [ + 129.46707153320312, + 178.66168212890625 + ], + [ + 129.46707153320312, + 192.2005615234375 + ], + [ + 80.434, + 192.2005615234375 + ] + ] + }, + { + "title": "APPLICATION GRANTED \nSO ORDERED", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 268.93199999999996, + 73.834716796875 + ], + [ + 418.8006286621094, + 73.834716796875 + ], + [ + 418.8006286621094, + 105.4029541015625 + ], + [ + 268.93199999999996, + 105.4029541015625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 101 + ], + [ + "Line", + 46 + ], + [ + "Text", + 16 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "Caption", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820035" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820035/_page_0_Picture_4.jpeg b/marker2/court-jane-doe-43/EFTA02820035/_page_0_Picture_4.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..92ae0ab997e47e5bd832e934c02f71fabfc16129 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820035/_page_0_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:fd140773041241e3506d7f6fe7185d3fe2a675ffb28ac5b66a6dee9baa4abc01 +size 8997 diff --git a/marker2/court-jane-doe-43/EFTA02820036/EFTA02820036.md b/marker2/court-jane-doe-43/EFTA02820036/EFTA02820036.md new file mode 100644 index 0000000000000000000000000000000000000000..07f3ac94bf9a4160ad8fcd9f0c0a4d6e2efaca7f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820036/EFTA02820036.md @@ -0,0 +1,27 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +Plaintiff, vs. + +JEFFREY EPSTEIN GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +Defendants. + +CASE NO. 17 Civ 616 (JGK) + +## NOTICE OF MOTION + +PLEASE TAKE NOTICE THAT, upon the accompanying memorandum of law and declaration of Michael C. (with exhibits), Defendants Jeffrey Epstein and Lesley Groff ("Defendants") will move the Court, pursuant to Fed. R. Civ. P. 9(b), 12(b)(2) and (6), 12(f), and before the Honorable John G. Koeltl, at the United States Courthouse, 500 Pearl Street, New York, New York 10007, as soon as counsel may be heard, for an Order (1) granting the Defendants' supplemental motion to dismiss the First Amended Complaint; (2) striking a portion of the First Amended Complaint if the motion to dismiss is not granted; and (3) any other relief the Court deems just and proper. + +Dated: New York, New York Yours, etc., January 26, 2018 + +tYtecfieCt\_ + +Michael C. Justin Y.K. 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Stephenson in support of Supplemental Motion to Dismiss, and the exhibits attached thereto, and in accordance with the schedule entered by this Court, Defendant by and through her counsel, Alston & Bird LLP, will move this Court at the United States Courthouse, 500 Pearl Street, New York, New York, at the earliest available time, for an Order pursuant to Rule 12 of the Federal Rules of Civil Procedure dismissing the claims asserted against her in the Amended Complaint with prejudice. + +Dated: Atlanta, Georgia January 26, 2018 + +By: /s/John E. Stephenson. Jr. + +John E. Stephenson, Jr. + +(admitted pro hac vice) + +Jonathan D. Parente + +(pro hac vice forthcoming) + +ALSTON & BIRD LLP + +1201 West Peachtree Street + +Atlanta, Georgia 30309 + +(404) 881-7000 + +john.stephenson@alston.com + +jonathan.parente®alston.com + +Alexander S. Lorenzo + +ALSTON & BIRD LLP + +90 Park Avenue + +New York, New York 10016 + +(212) 210-9400 + +alexander.lorenzo®alston.com + +Counsel or + +To: Counsel of Record for All Parties \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820038/EFTA02820038.metadata.json b/marker2/court-jane-doe-43/EFTA02820038/EFTA02820038.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2c898d1d7c751aa7563bcbdddf2b3a3266421e43 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820038/EFTA02820038.metadata.json @@ -0,0 +1,143 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820038.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1335, + "elapsed_seconds": 1.1, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 88.12799999999999, + 71.28 + ], + [ + 296.29022216796875, + 71.28 + ], + [ + 296.29022216796875, + 100.10302734375 + ], + [ + 88.12799999999999, + 100.10302734375 + ] + ] + }, + { + "title": "DEFENDANT NOTICE OF \nSUPPLEMENTAL MOTION TO DISMISS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 176.868, + 321.57000000000005 + ], + [ + 436.2590026855469, + 321.57000000000005 + ], + [ + 436.2590026855469, + 350.9830322265625 + ], + [ + 176.868, + 350.9830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 24 + ], + [ + "Text", + 9 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 23 + ], + [ + "Text", + 21 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820038" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820040/EFTA02820040.md b/marker2/court-jane-doe-43/EFTA02820040/EFTA02820040.md new file mode 100644 index 0000000000000000000000000000000000000000..a58a7b227591b6f6c90ea1a59294122174e3d753 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820040/EFTA02820040.md @@ -0,0 +1,95 @@ +## Exhibit A + +## ALSTON&BIRDRI, + +One Atlantic Center 1201 West Peachtree Street Atlanta. GA 30309-3424 + +404.881.7000 + +Fax: 4O4.881.7777 + +www.alston.com + +John F. Stephenson. Jr. + +## VIA EMAIL AND U.S. MAIL + +Brad , Esq. + +Jaffe, Weissing, + +Fistos & Lehrman, P.L. + +425 North Andrews Ave., Suite 2 + +Fort Lauderdale, FL 33301 + +Direct Dial: 404.881.7697 + +May 15, 2017 + +Email: john.stephensonVahlon.com + +Re: Doe 43 v. Epstein, et at, No. 1:17-CV-00616 (S.D.N.Y.) + +Dear Brad: + +As contemplated by the Court's directives at the initial conference, and in accordance with the parties' May 12, 2017 stipulation, I write on behalf of defendant to identify what we believe are deficiencies in the Complaint. The claims against should be dismissed for the reasons outlined below. + +At the outset, the entire Complaint—including all claims all Defendants—is subject to dismissal based on the defects described in Michael letter dated today. That correspondence was sent on behalf of defendants Jeffrey Epstein and Lesley Groff, but the many grounds for dismissal set out in the letter also apply to any claim against + +- The Complaint's allegations improperly lump together all "Defendants" and also improperly lump together various statutory provisions ( Letter at 6, 10-11); +- The purported "fraud"-based claims under 18 U.S.C. § 1591 are legally insufficient: These allegations fall short under the heightened standards applicable under Rule 9(b), and Plaintiff has failed to adequately allege the requisite "fraudulent intent" or "reasonable reliance" (id. at 3-6); +- Section 1591 was never intended to address or regulate the type of consentingadult relationship at issue in the allegations (id. at 7); +- Plaintiff also has not pleaded a legally viable theory under Section 1591's "coercion" prong (id. at 8-9); +- The Complaint fails to plausibly allege the requisite "commercial" sex act—much less one "caused" by "force, fraud, or coercion" (id. at 9-10); + +May 15, 2017 Page 2 + +- The Complaint merely parrots back various statutory elements and does not state a plausible claim that Plaintiff—an adult of sound mind who voluntarily entered into a consensual relationship—was the victim of a criminal sex-trafficking offense (id. at I I); +- **Plaintiffs claims are all barred by the applicable statute of limitations under Section 1595** (id. at 12-13); and +- **The allegations highlight independent jurisdictional and venue defects that are alone fatal** (id. at 13-14). + +Mr. letter effectively details and gives notice of these and other deficiencies, so for the sake of efficiency, we join in his entire letter and incorporate by reference the arguments, authorities, and citations that he sets out more fully.' Beyond that, however, I write separately to emphasize a few select issues that apply with particular force in the case of given the specific allegations that have (and have not) been made against her. + +## The Complaint fails to state a claim against EM + +The lack of factual content in the allegations and improper lumping of Defendants underscores that Plaintiff has not and cannot, state a claim against my client. There are hardly any allegations about MEM She is identified by name only a handful of times in the 20 pa e Com laint. And most of the allegations that could even arguably be construed as directed at simply recite Section 1591's legal conclusions and statutory buzzwords—e.g., "recruited," "procured," "fraud," or "coercion." (See, e.g., Comp. 1 21; see also Kelsey v. Goldstar Estate Buyers Corp., No. 3:13-CV-00354-HU, 2014 WL 1155253, at \*5-6 (D. Or. Mar. 21, 2014) ("They do not allege facts. They are simply a regurgitation of [Section 1591's] wording woven together with conclusory statements . . . .").) One allegation vaguely references some "verbal abuse and threats" that seem to be attributed to several individuals, including but the Complaint does nothing to describe who said what or what the alleged comments might have related to. (Id. 1 46.) That is not enough to state a plausible claim that violated the criminal sex trafficking provisions at issue. See Ashcroft v. !ghat, 556 U.S. 662, 678 (2009) ("A pleading that offers 'labels and conclusions' or a 'formulaic recitation of the elements of a cause of action will not do."). + +The dearth of facts and allegations directed toward makes the Complaint's repeated and improper lumping of all "Defendants" together particularly egregious. Plaintiff alleges, for example, that "Defendants recruited Plaintiff' (Compl. 1 33) and later that "Defendants provided" Plaintiff with an apartment, a car service, a cell phone, and other consideration (id. 1 49). This type of group pleading runs afoul of Rule 8, which requires "specification" as to "the particular activities by any particular defendant" See Am. Sales Co. v. AstraZeneca AB, No. l0Civ.6062, 2011 WL 1465786, at \*5 (S.D.N.Y. Apr. 14, 2011). Courts routinely dismiss claims that "fail[] to differentiate among the defendants, alleging + +I also fully agree with Mr. position that paragraphs 12 through 32 contain a host of allegations that are unproven, irrelevant, and prejudicial in this action. They should be removed or stricken under Rule 12(f). + +May 15, 2017 Page 3 + +instead violations by `the defendants' (Atuahene v. City of Hartford, 10 F. App'x. 33, 34 (2d Cir. 2001)), and that "attribute" alleged acts "generally to `Defendants." Bias v. City of New York, No. 10—CV-5495, 2010 WL 5475809 (E.D.N.Y. Dec. 30, 2010). + +The lumping of all Defendants is not only impermissible but also implausible: Taken literally, the allegations would claim that all five Defendants recruited Plaintiff and that each of the five then provided her with an apartment, a phone, and a car. Plus, certain allegations that refer to acts of 'The Defendants" collectively are later narrowed by Plaintiff in a way that specifically excludes (Compare Compl. 1 34 with 1 35.) As currently drafted, the Complaint fails to put on sufficient notice of the allegations against her. + +The Complaint also fails to state a claim against under Section 1595 because Plaintiff has not alleged—much less plausibly alleged—that had the requisite knowledge under the underlying criminal provisions. lqbal, 556 U.S. at 678 ("a complaint must contain sufficient factual matter, accepted as true, to 'state a claim to relief that is lausible on its face."). Section 1591 requires that Plaintiff allege, among other things, that (i) "recruit ed , entice[d], harbor[ed], transport[ed], provide[d], or obtain[ed]" Plaintiff and (ii) that did so "knowing that force, fraud, or coercion ... w[ould] be used to cause [Plaintiff] to engage in a commercial sex act." 18 U.S.C. § 1591(a) (effective July 26, 2006). Even assumin that Plaintiff has alleged the other elements—again, she has not the claims against would still fail because the Complaint does not allege that knew that force, fraud, or coercion would be used to cause Plaintiff to engage in a commercial sex act.2 + +Plaintiffs allegations about involvement in the purported fraud are impermissibly vague and in all events insufficient. The Complaint alleges only that "confirmed" the promise of others that Mr. Epstein could use his influence to get her into a fashion institute. (Compl. 1 37.) The allegation is woefully deficient under Rule 9(b), and more generally, it is not at all clear what it means for la to have allegedly "confirmed this promise." Either way, there are no allegations that knew that the alleged promises might have been false—i.e., that some other individual(s) did not subjectively intend to perform and make good on their alleged educational promise. The absence of this critical knowledge allegation is especially problematic because, by Plaintiffs own allegations, Mr. Epstein had consistently followed through on various other alleged promises to Plaintiff. (Compl. 1 49.) The allegations as pleaded are not enough to "nudge[] the[] claims across the line from conceivable to plausible." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). + +As far as the alleged coercive conduct, the Complaint does not even mention IMI name or otherwise attempt to connect to the alleged intimidation or threats made by other individuals that sup sedl "coerced [Plaintiff] into sexual compliance." (Compl. 1 45.) It is not alleged that re ated or confirmed such coercive threats. There is no reason alleged (or otherwise) why would have had the requisite + +2 For the avoidance of doubt, as discussed above and as described in Mr. letter, among other things. Plaintiff has not sufficiently alleged (i) fraud, (ii) coercion, (iii) a "commercial" sex act, or (iv) the requisite causal link that fraudulent or coercive conduct produced the alleged sex acts. + +May 15, 2017 Page 4 + +knowledge of the alleged coercive statements. See lqbal, 556 U.S. at 679 (explaining that the "mere possibility of misconduct" is not enough). + +Without knowledge, there is no claim against + +Plaintiffs claims are time-barred. + +Any theoretical claim that Plaintiff might have against would be barred by the applicable statute of limitations. The alleged events, as relating to any of the Defendants, took place in 2006 and 2007. Because Plaintiff did not file suit until January 26, 2017—more than four years after the alleged events-this entire action is time barred. See Abarca v. little, 54 F. Supp. 3d 1065 1068 (Minn. 2014) (holding that four-year statute of limitations applies because the alleged unlawful conduct occurred prior to the 2008 amendment of Section 1595). + +Even if Plaintiff could claim the benefit of the ten-year limitations period Plaintiffs claim against would still be barred. First, each of the allegations about took place in the 2006 calendar year before Plaintiff first left for South Africa. Even accepting the allegations as true, the Complaint shows that did not do anything in 2007—i.e., within the ten-year period leading up to the filing of this lawsuit. + +As important, Plaintiff cannot plausibly allege that any alleged fraud or coercion attributable to any of the Defendants caused her to engage in sex acts after she left the United States in January 2007. By that time, she was at home with her parents in South Africa thousands of miles away, and by her own allegations, she was already alert as to the alleged fraud and coercion and had refused to perform the acts demanded of her. (Compl. 1 51.) + +If you would like to discuss any of these issues, please do not hesitate to reach out. + +Sincerely, + +John E. 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Most of the men are looking for fit, sexy women, and most of the women want nice guys who can make them smile and laugh. But if eHarmony or Match.com is a chatty social mixer, Seeking Arrangement is a down-and-dirty marketplace where older moneyed men and cute young women engage in brutally transactions. They're not searching for longtime soul mates; they want nostrings-attached "arrangements" that trade in society's most valued currencies: wealth, youth and beauty. In the cheesy lexicon of the site, they are "sugar daddies" and "sugar babies." + +There's the i8-year-old from France asking for \$5,000 to \$io,000 a month from "a mentor who can provide me with the finer things in life and keep me happy!" And the 49-year-old investor from upstate New York willing to pay \$5,000 a month for a "daytime playmate" for "intense connection without commitment." Critics say the site is at best a convenience store for adulterers and at worst a virtual brothel, but Brandon Wade, Seeking Arrangement's 38-year-old founder and chief executive, is unperturbed by the criticism. "We stress relationships that are mutually beneficial," he says. "We ask people to really think about what they want in a relationship and what they have to offer. That kind of upfront honesty is a good basis for any relationship." + +The site now claims more than 300,000 registered members, far fewer than mainstream dating sites like Match.com, which has 1.5 million paying subscribers, but still a remarkable number. Sugar babies outnumber daddies to to 1. Wade says. nmyieline what one Sugar daddy railed "the hest fishine hole T + +9 Get 30% off for one year of The Time! Subscriber login + +This abundance of possibility is part of what the site is selling, along with fantasy. Some of these men — especially those shopping for women half their age — are digging deep into their pockets to pay for an illusion: that despite their receding hairlines and wattled skin, they're still enchanting enough to charm pretty young women. One image on the site features a dazed, graying man doted on by two barely clad attendants — a caricature of an already caricatured relationship. But this marketing spin doesn't capture the nuances of the relationships that often develop between the "daddies" and the "babies" who meet on the site — relationships that can turn out to be more complicated than even the members themselves expect. Men may use money as a way to buy themselves out of the normal obligations of romance, like accommodating a woman's emotional needs as much as their own. But despite the power and security that the money buys, it can also undercut the very ego it's intended to boost. + +Consider B. K., a fit finance executive in his early 4os, who, last October, began "dating" a 20-year-old engineering major at a college go minutes from his house. Like nearly half the sugar daddies on Seeking Arrangement, B. K. is married. (Neither B. K. nor any other user of the site would allow full names to be published — certain the revelation would infuriate wives or boyfriends, shock colleagues and repel friends or family — and agreed to use only their first names, nicknames or initials.) B. K. and his wife opted against separation, for the sake of the kids, and for now, they have a policy — at least in his mind — of don't ask, don't tell. Between pangs of guilt about cheating, B. K. views his secret dallying as a safety valve, letting him feel desired so he can return home and appreciate the many things he loves about his wife, even if they don't include giving him the attention he wants. + +And so, nearly each week, B. K. gets together with Lola, the young woman he met on the site, for a meal or a gym workout and a few hours at a hotel outside the Western city where he lives. Their visits are generally no longer than four or five hours because Lola, a senior, has a full course load and also works 4o hours a week at two low-wage jobs. With no money from her parents, she was in her Seeking Arrangement profile, saying she needed "immediate financial assistance." In B. K., she gets that in the form of \$100 or \$150 stuffed in her bag each time they meet. He feels good about helping her with her tuition, encouraging her studies and romancing her, albeit in hotel rooms. Most of all, he's grateful that she doesn't want a commitment. At least he was at first. + +"It's very clear with this site that she's getting something out of this, hopefully emotional support and mentoring advice and fun in bed, but also something financial, so don't come back to me and say that you were used or that I left you high and thy," he said. "I like that aspect of it, but on the other hand, it would be nice not to have the money involved, because you always wonder: would she still want to be with me even without the money? Does the money make me more attractive than I really am?" + +ABOUT 30 PERCENT OF ARRANGEMENTS on the site involve the daddy paying an "allowance," usually a thousand or two a month, though the site claims some reach \$10,000. The rest provide the baby with incidental cash, shopping sprees, gifts, travel or the fleeting illusion that theirs is a high-end, easy life. I get flown to whatever city I want," wrote a North Carolina college student, who goes by the name gurinextdoor on the site's blog, a mix between an online support group and a kaffeeklatsch. "He pays for it, takes me shopping, we talk, laugh, go out to eat and do whatever we want to do for our days together.... I don't bring up mundane problems about my home life, and he does the same. ... If I wanted someone to talk to about my life problems, I'd get a boyfriend or a therapist." + +Like B. IC's companion, Lola, many women on the site are in their zos, though plenty of others are in their 3os, 4os and 5os. Some are looking for attention, some have financial problems and some are seeking refuge from romantic pain. On the blog and in conversations with me, still others said benefactors provide a way to get the extras they want — the Fendi bags, the todie-for shoe collection or the breast enhancement. A surprising number of babies say on the blog that they don't need the money at all, either because they have decent-paying jobs or bottomless credit cards from their parents. What appeals to them about the arrangements are the expensive gifts — "I just LOVE being spoiled," gushed one 19-year-old woman on the blog — because those gifts make them feel valued, as if the money spent measures just how desirable they are. + +Other women on the site would happily forfeit conspicuous prizes and go for the cash instead, especially for tuition. One woman's profile says, "That you can help me get through school and achieve financial stability through support and mentoring is more important than wowing me with diamonds and Prada." In fact, Seeking Arrangement pays to have its ads pop up on search engines whenever + +someone types in "student loan," "tuition help," "college support" or "help with rent." Lola was one of many to stumble on the site that way, when — behind on her rent and tuition and down to one meal a day — she Googled "student loan." What popped up was hardly what she expected, but she was willing to try almost anything to stay in school. + +Her first sugar daddy, a man in his early 5os, turned out to be a terrible kisser and too dominating in bed. "I had to grit my teeth every time we met," she told me. In four visits, she earned \$550, enough to cover the rent, and then dropped him. A month later, she connected with another sugar daddy, a man in his late 5os who lived in Louisiana. The only thing he wanted, he told her, was that she do well in school. He insisted she send her transcript, and once satisfied, he sent her nearly \$500 a month. Though they never met, never even talked on the phone, he wrote her long letters by hand encouraging her studies and advising her on finances and sent her novels, newspaper clippings and a J. K. Rowling commencement address for inspiration. He never once mentioned sex. + +Six months later, the man in Louisiana had to cut back on expenses, so Lola began looking for a new source of income to supplement the \$8 an hour she earned working in a lab and the cash she picked up cleaning houses and selling her plasma. Last October, Lola and B. K. had their first date. + +Though petite, Lola seems older than she is, maybe because she is so matterof-fact in her manner. On the day I met her, on her way to meet B. K., she was wearing jeans, a striped T-shirt and no makeup. Her hair was pulled back, nononsense style, making her look more as if she were about to go camping than rendezvous with her sugar daddy. She brought along a textbook and her GRE vocabulary flashcards, in case B. K. was late. + +"At first, it was a job, then it became a pleasant job and then it was getting together with a friend," she said, describing her relationship with B. K. "With him, I don't feel like a prostitute, though maybe I am. It's not just the sex with us. We care about each other, we talk, there's a connection, not just business." + +Whether sugar relationships amount to prostitution is hotly debated among the site's members. "Let's get real here," wrote GoldenGate on the blog. "I'm with a guy who's old enough to be my dad, short and balding. Not to mention his other shortcomings, ahem. But he gives me a great big fat allowance every month. If that wasn't there, we wouldn't be together." + +Others on the blog were shocked, saying they could never be with a man, even a rich one, if they weren't somehow attracted to him. Indeed, most go to considerable effort to distinguish between "sugar" and prostitution. (Legally, at least, they are right; since the 1970s, courts have ruled that as long as the woman is paid for some service besides sex — housecleaning, companionship — the arrangement is not the equivalent of prostitution.) They say being a sugar baby is no more an occupation than dating is, especially when the goal of dating is to find a rich boyfriend or a wealthy husband. They routinely turn down creeps interested in nothing but sex. + +Some sugar babies also insist that wives who stay in miserable marriages for an American Express black card, mansion or country-club membership are more like prostitutes than they are. And yet the blatant financial transactions leave many uneasy. Even Seeking Arrangement's chief executive uses a fake name his legal one is Brandon Wey — partly because he's afraid his association with the site might dampen his chances of raising capital for a more mainstream enterprise in the future and partly because he thought the name Brandon Wade sounded more Hugh Hefneresque. + +In interviews and on the blog, the site's members parse the nuances of the sex and money transactions. "I read on a post about asking iok if you're model material... so because I ask for so little, am I 'on sale'?" wrote one woman. "I don't think I can accept more than ik a month plus gifts, because then I will start feeling compelled to do ANYTHING for him." + +E. C., a 23-year-old sales-and-marketing coordinator in Toronto, says she already earns \$40,000 a year as well as commission and the use of a company car. But having grown up in a wealthy family, her current salary doesn't allow her to live in the manner to which she's accustomed. So E. C. dined with a banker from the site who was charming and attractive. His breath, however, was so bad she decided he wasn't sugar-daddy material. + +Then she met a charming 43-year-old businessman from the site with nice breath. She tried to steer their conversations to the question of an allowance, unsuccessfully. On their third date, they slept together. Afterward, she was glad no money had changed hands. "If he'd given me money after that, I would have felt he was paying me for the sex," she said. "And if he'd paid me beforehand, I would have felt I owed him something, and the whole thing would have gone from charming to being bought." Instead of paying her, he takes her to swank restaurants and penthouse suites in Niagara Falls. "He shows me off to the whole place, and it makes me feel good." + +Her parents, she added, would be appalled if they knew she was on such a site — except if they thought it increased her chance of meeting an eligible and rich young doctor. + +MOST PEOPLE WOULD LIKELY BE appalled to learn that a daughter — or father — was using SeekingArrangement.com. Beth , a Temple University historian of courtship, said that her first reaction to the site was "revulsion." But when she reconsidered it within the historical context of dating, she had a somewhat different response. + +Heterosexual relationships, including marriage, have long involved economic transactions, but points out that when men provided financial security, they traditionally did so in exchange for a woman's sexual virtue (and potential to bear and rear children), not for sexual thrills. For that, they often turned to prostitutes and mistresses, involving a more money-for-sex exchange. It's only in the last century that money has been traded — albeit indirectly — for sexual attention from "respectable" unmarried women. In the early i9oos, courtship shifted from girls' porches or parlors to a commercial venture: a date. Etiquette manuals of the time were explicit — boys were to pay for meals, entertainment and transportation, and in return, girls were to provide wellgroomed company, rapt attention and at least a certain amount of physical affection. His money bought not only companionship but also her indebtedness. + +"It made a lot of people uneasy, because if men's money was central to the dating relationship, what distinguished it from prostitution?" says. Seen in this context, argues, Seeking Arrangement "is a piece of contemporary society. It's simply more explicit and transparent about the bargains struck in the traditional model of dating." + +Though one-quarter of the site's sugar daddies (including married ones) are looking for male "babies" and i percent of the site's members are "sugar + +mommies," they still tend to fall into traditional roles, where the one who is paid supplies sex, admiration, comfort and the kind of status conferred by any other expensive consumer good. The "baby" is the one who regulates her appearance, schedule, behavior and emotions to make the payer feel special. + +Still, a 22-year-old named Mercedes told me, "I don't see how people can view this as exploitation." Mercedes is a junior who pays her own tuition at a Georgia university. She has had six sugar daddies in the past year to supplement her wages busing tables and washing dishes at a bar. "I could go out and work three jobs and still go to school and probably make decent grades, but is that really what I want to do? I make more money this way, and I have a lot more fun because I get to go out to concerts, go shopping, see movies and make money off of it. If instead of this I was just dating a rich guy, it'd be almost the same thing, and society wouldn't look down on that. You know with a sugar daddy that they're spending a lot of money on you and they clearly want something in return, but is that really any different than how it is with a boyfriend?" + +BRANDON WEY GOT THE IDEA for the site from his own dissatisfying love life as an M.I.T. student and then as a well-off but awkward tech executive. Traditional dating Web sites were no help. "It was difficult to advertise the assets I had compared to hundreds of thousands of guys who had better looks or better pickup lines," says Wey, now married to a woman 13 years younger than he is, whom he met before the site went live. "I needed to find a way to put myself at the front of the line." + +Wey unveiled SeekingArrangement.com in 2006 and aimed to keep the site well stocked for his wealthy customers. Babies can join free, while daddies pay \$44.95 a month — and an optional \$5 to ensure the site's name doesn't show up on credit-card statements. For another \$1,200 a year, a sugar daddy can become a Diamond Club member, with his income and net worth verified and his profile featured at the top of the home page. + +B. K. joined the site about a year ago, swapping flirtatious e-mail messages with potential sugar babies, taking a few out to dinner and romancing one for a few months before he found Lola. He was drawn, he said, to her independence and intellect, her humility, her academic determination and, of course, her looks. He loved their time together — dancing, snuggling, the whole bit — and, at times, feared he was falling in love. + +From the start, Lola was clear that her heart lay elsewhere. Her boyfriend of four years lives tam miles away, and though they see each other only a few times a year, Lola maintains that she is deeply in love with him. When B. K. asked Lola what gift she wanted for Christmas, she demurred, but when pressed, she asked if he would pay for plane fare to visit her boyfriend. B. K. said yes — and felt great about it. "Isn't that what love is?" he told me later. "It's not about trying to own someone." + +While Lola was gone, B. K. sent her e-mail and text messages virtually every day but heard nothing back. Pining, he began trolling the site, window shopping, and noticed Lola had logged on. He feared that she was looking to replace him. "I was like, What the hell is this?" He e-mailed her, asking why she was on the site, but got no answer. "Maybe I'm the needy one," he mused. He wondered if Lola was trying to end their relationship or if her boyfriend had found out. "The nostrings-attached assumption is hard on my heart sometimes, but I don't think she will just disappear." + +RELATIONSHIPS BETWEEN RICH men and kept women have been around for a very long time, of course, but the Internet makes hunting for such arrangements easier. Quickly and privately, a well-off man can find a young woman wherever in the world he wants. And he can find someone who fits his needs, however unconventional they may be. + +One sugar daddy whose screen name is has tried long-term girlfriends, mistresses, prostitutes and a brief marriage. Now single, the 39-year-old entrepreneur has found the arrangement that suits him best: a monogamous business-associate-with-benefits deal in which he pursues an entrepreneurial project with a young, beautiful, intelligent woman. He provides financial backing, mentoring and networking; she provides sex, fun and, inevitably, a bit of worshiping, all of which make him feel virile and influential. In between vacations using his private jet, both work hard on the project. They don't tend to see each other much, as he travels frequently for his work. + +profile on Seeking Arrangement is audacious. He advertises for a woman who is "drop-dead beautiful, sexy, fun and elegantly mannered in a fancy setting. She must turn heads ... and make me the envy of the crowd." He wants no tattoos, no cosmetic implants, no vegetarians and no Gen Yers who begin their e-mail-message sentences with lowercase letters. + +When I asked to chat in person, ■ **suggested meeting at CORE, a private Manhattan club where membership is by invitation only and costs \$65,000 the first year and where assent was required before I could be admitted. Sitting alone at a long conference table in a room set aside for him, he looked utterly unremarkable, a man of average height with a buzz cut and an aloof air. But once** ■ **got talking, he became affable and witty, especially as he described his unorthodox history with women. He started college when most kids his age were still in middle school. "When you go to college at that age, you're pretty undatable," he said. "I was somewhere between a curiosity, a mascot and a friend. I tutored freshman physics and calculus so I could at least be near women. Of course, all they'd do is talk about their boyfriends."** + +**He has an almost mathematical approach to assessing relationships, and once even computed the costs for a girlfriend, mistress, prostitute and wife mistresses turn out to be most expensive by the hour; wives, by the year; girlfriends are cheapest all around. But he's not as calculating as he seems. In fact, he concluded there's little correlation between cost and quality. Still, he is relentlessly searching for an algorithm that will predict relationships' success.** + +■ **is also more determined than most to try separating a sugar baby's affection and the money she's paid to provide it. In his arrangements, he says, he establishes a trust in the woman's name that pays a monthly stipend of at least \$5,000 for the length of their contract. If the woman decides to quit sleeping with him at any point, he may quit serving as adviser and pamperer, but the stipend continues regardless. "If I didn't do that, then it's like a leash I'm putting on somebody, and that seems really unfair," he said. "Besides, then I'd never know what the relationship was really about."** + +■ **runs these relationships with an explicit business plan, a set budget, measurable goals and quarterly reviews. From the outset, the contract has an end date. It's a brilliant, if contrived, way to protect his pride. The contract specifies that the romance and sex are to end by the preset date, so there's no break up, no rejection, no bruised ego. She's not dumping him; the gig's just over.** + +**He was involved in three relationships this way, helping the women establish a school overseas, start a tech company and help run a nonprofit, he told me. He declined to put me in touch with the women but said each had been successful. He is like Pygmalion, smitten with his own creations.** + +He found those three women through word of mouth, long before he discovered Seeking Arrangement and its rush of possibilities. Between November and shortly after I met him in mid-January, he had winnowed down 140 candidates to four finalists. "It feels so good to have so many people paying attention to me," he said. He met all four, interviewed them extensively, coached them on their business plans and took two of them on multiday outings. In each case, he told them he preferred to put off sex until he'd settled on a candidate, though he did end up sleeping with one of them — but only, he says, because she so aggressively pursued him. + +NOR ARE MEN THE ONLY ONES seeking relationships within particular parameters. A. B. was 18 when she first went on the site, in 2006, looking for extra money. She had started college at 15 but quit when her money ran out. She was soon contacted by a well-to-do, married filmmaker whom she liked immediately. He encouraged her ambition to become a professor of art or philosophy. For a few months, they saw each other frequently, visiting museums, discussing Camus and Nietzsche, taking in films, sharing their poetry and artwork and sometimes romping in bed. He gave her \$500 each time they met, whether or not they had sex. In between visits, he sent her money for art supplies. He said if she got a part-time job, he'd pay the tuition and living expenses she couldn't cover. + +Ecstatic, A. B. re-enrolled at her Southern college. Her sugar daddy flew her up to Pennsylvania to meet him a few times. But he became increasingly peeved that she also had a boyfriend at school. And though her boyfriend understood why she was in a relationship with a sugar daddy, A. B. felt compromised, as if she were leading two lives. She ended that Seeking Arrangement relationship. + +About two years later, A. B. met another sugar daddy from the site, a single father who seemed pleasant enough but unlikely to entangle her emotions. Still, after a few visits, he wanted nothing but sex, so she stopped seeing him. + +"When these sugar-daddy relationships go the way I think they should go, the lines are pretty blurry between that and a typical boyfriend-girlfriend relationship," she said. "And when they go the way I don't think they should go, the lines are blurry between that and sex work." + +In February, A. B. met a third benefactor. This one was a pleasant and clever psychologist in his 4os. He flew her to San Francisco. They went to jazz clubs and a tony restaurant, talked about philosophy and shared a bed but stayed on their own sides all night. But the next night, after they'd both been drinking, he pressured her into forgoing a condom during sex. "I yielded because I thought that if he came away from the weekend having enjoyed himself, he would be more likely to want to see me again and want to support me," she said. The experience soured her on flagrantly transactional relationships, because she realized the power dynamic would always be lopsided. She is done being a sugar baby, A. B. said, even if it means delaying her education even longer. + +AT TIMES, B. K. DEBATED WHETHER to turn off his Seeking Arrangement profile to honor his relationship with Lola. But whenever communication from her would go dark for a few days, he was glad that his profile was still active. The e-mail messages he got from women were an ego balm. After all, it's not often a man in his 4os is wooed by a former surfer in her 20S or a 26-year-old model looking for the "finer things in life." + +During the two weeks over Christmas that Lola was incommunicado and B. K. worried that he'd just been dumped, he received a suggestive note from a woman close to his age from another state. She sent him long enticing messages, which boosted his morale. Unlike Lola, she was mercurial and dramatic, and he was drawn by her damsel-in-distress air. He loved feeling like her savior. Neither Lola nor his wife seemed to need saving, just help with tuition (in Lola's case) or with kids and chores (in his wife's case). + +Everything about the woman seemed enticingly dangerous, and B. K. became obsessed with her and told me their interactions were like the "thrill" of running through a burning building and making it out alive. And then it imploded: a combination of hotheadedness, different politics and her resentment that he wouldn't pony up a regular allowance. + +By then, Lola was back at school. She said she'd been out of touch during her visit with her boyfriend because her cellphone battery died. She told B. K. she hadn't bought a charger because she was out of money, even using Target gift cards she received at Christmas to pay for groceries. She reassured him that she wanted to keep seeing him but also reminded him that she had several looming deadlines at school and at the lab where she worked. Delighted that she was still + +in his life, B. K. turned off his Seeking Arrangement profile. But with Lola's packed schedule, their visits dwindled to every other week. It took days for her to respond to his e-mail messages. Even a text message he sent asking "Are you O.K.?" went unanswered for days. + +Eventually, she e-mailed him in her typically even-tempered way: "I am all right. When I don't respond it means I don't have time at the moment and then I forget because I'm running from one place to the next." + +Restless, B. K. switched his profile on. He got a Seeking Arrangement message from a graduate student in her mid-2os who lived just to miles from his office. They met for a quick coffee, long enough for the woman to grab B. K.'s hand and put it on her ripped abs, just to show him what she was made of. He was thrilled by her aggressiveness. Afterward, when he suggested by e-mail that he could pay her \$1,500 a month, she objected that she was worth much more. He decided to play it cool and wait for her to come begging. + +And then in the midst of all that, he got a message from Lola that she could meet him the following Sunday afternoon, after a study session. Upon getting her note, his message to me was effusive: "YAY!!! I'm almost giddy like a schoolboy!!" + +When they finally met in late February, B. K. asked Lola more about her boyfriend than he ever had before. Lola told him she loved her boyfriend and that she hoped he would propose after she graduates later this year. Once engaged, she added, she would stop being a sugar baby. B. K. felt devastated. + +Lola seemed particularly tender in that meeting, he told me. Moved by his deep affection for her, B. K. offered her an extra \$200 to see her boyfriend over spring break. Afterward, he was scared he would soon lose her and also scared at how much his feelings for her had intensified. If she asked him to leave his wife, he told me, he would seriously consider it. + +In the days after their meeting, B. K.'s moods shifted rapidly; he was dreamy one minute, testy or melancholy the next. Then, after weeks of silence, the graduate student with the taut abs e-mailed him, and they agreed to meet at a local bar. "I may be a fool for love, but I'm also practical," he said before going to meet her, adding that, then again, "maybe I am just a big wallet, and I'm getting played on all sides." + +On a weekday evening, B. K. sat in a back booth, waiting for his new potential sugar baby. She showed up in a tight, low-cut blouse and scooted up next to him, he told me, purring that it had all been a misunderstanding and that \$1,500 a month would be just fine. To his delight, she said none of the other men on Seeking Arrangement had impressed her the way he had. B. K. explained that his current sugar baby might soon get engaged and disappear from the scene. At that point, he assured her, he would want to pursue things. She snuggled in closer and told him that she would wait. And then she started kissing and nibbling on his ear. + +Ruth Padawer is an adjunct professor at Columbia University's Graduate School of Journalism. 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GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +Defendant. + +-x + +## DECLARATION OF JOHN E. STEPHENSON. JR. + +I, John E. Stephenson, Jr., declare as follows pursuant to 28 U.S.C. § 1746: + +1. I am an attorney-at-law duly admitted to practice pro hac vice before the Southern District of New York in this matter. I am a partner with the law finn of Alston & Bird LLP, which has an office at 90 Park Avenue, New York, NY 10016. I represent in the above-captioned case. + +2. I submit this Declaration based upon my personal knowledge, information, and belief, in support of Complaint. Supplemental Motion to Dismiss the Amended + +3. Attached hereto as Exhibit A is a true and correct copy of the May 15, 2017 pre-motion letter that I sent to Plaintiff's counsel. That letter served to identify and discuss the deficiencies in the January 26, 2017 Complaint. + +4. Attached hereto as Exhibit B is a true and correct copy of the April 10, 2009 New York Times article titled "Keeping Up With Being Kept" The article can be accessed online at http://www.nytimes.com/2009/04/12/magazine/12sugardaddies-t.html. The last time that I accessed the article online was earlier today. + +I declare under penalty of perjury that the above facts are true and correct. + +Executed this 26th day of January, 2018. + +/s/ John E. Stephenson, Jr. John E. 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KOELTL, District Judge: + +The plaintiff, has moved the Court to approve alternative service on the defendant Ghislaine Maxwell and to find that service has been effected. The plaintiff asserts that, despite diligent measures, she has been unable to serve Maxwell personally. The plaintiff argues, however, that she has taken reasonable measures to provide Maxwell with notice of the pending lawsuit and requests that this service should be deemed sufficient. Non-party Haddon , P.C. ("Haddon Maxwell's counsel in another litigation pending in this Court, has refused to accept service on behalf of Maxwell and has objected to becoming a general agent of process for Maxwell, but has taken no position on the plaintiff's application to deem service effected through the email efforts that the plaintiff has already made. Neither + +&#x27;The Clerk of Court is directed to amend the case caption to name as the plaintiff. See Docket No. 96. + +Maxwell nor any representative of Maxwell has otherwise opposed the current motion. + +Federal Rule of Civil Procedure 4(e)(1) permits a plaintiff to serve a defendant by following the procedures set forth by state law in the state where the district court is located. New York Civil Practice Law and Rules Section 308 sets forth available methods of service. Where service under §S 308(1), (2), or (4) -- which generally provide variants of personal service -- is impracticable, § 308(5) provides that the Court may approve alternative service methods. See, e.g., Rampersad v. Deutsche Bank Sec., Inc., No. 02-cv-7311(LTS)(AJP), 2003 WL 21073951, at \*1 (S.D.N.Y. May 9, 2003). Service under § 308(5) requires a showing of impracticability of the other methods of service, but does not require a showing of due diligence. Id. + +The plaintiff has taken various steps in an effort to serve Maxwell personally -- all to no avail. The plaintiff retained a private investigation firm to attempt to determine where Maxwell resides, and that firm attempted service at three physical addresses potentially associated with Maxwell. The plaintiff also emailed the summons and complaint to several email addresses that are publicly associated with Maxwell, only one of which has been returned as undelivered. The plaintiff has also provided a copy of the summons and complaint to Haddon + +who currently represents Maxwell in another litigation pending in this district. + +Under these circumstances, the plaintiff has demonstrated impracticability, because she has made numerous efforts to obtain information about the defendant's current residence and general contact information to effectuate personal service but has been unable to locate Maxwell. See, e.g., S.E.C. v. Nnebe, No. 01-cv-5247 (KMW), 2003 WL 402377, at \*3 (S.D.N.Y. Feb. 21, 2003) (collecting cases). Accordingly, the Court finds that the plaintiff has demonstrated that service on Maxwell is impracticable and thus grants the motion for alternative service. + +Further, the steps already taken by the plaintiff to serve Maxwell are "reasonably calculated, under the circumstances, to apprise [her] of the pendency of the action and afford [her) an opportunity to present (he]r objections," and the Court therefore deems service of the summons and complaint to be complete as to defendant Maxwell. See, e.g., Bozza v. Love, No. 15-cv-3271 (LGS), 2015 WL 4039849, at \*2 (S.D.N.Y. July 1, 2015) (holding that service upon the defendant's counsel in an unrelated matter was sufficient); Rampersad, 2003 WL 21073951, at \*1. + +Finally, Haddon objection to becoming a general agent of process for Maxwell is unfounded. The Court's ruling that service by email and personal delivery to Haddon has been reasonably calculated to provide Maxwell with notice of this lawsuit and an opportunity to respond does not turn Haddon into a general agent for Maxwell. Indeed, this order does not even require Haddon to accept service on behalf of Maxwell, but rather finds that service on Haddon is likely to provide notice of the lawsuit to Maxwell, given that Haddon is presumably in contact with Maxwell with regards to their representation of her in the other pending matter. See Bozza, 2015 WL 4039849, at \*2. + +Accordingly, the motion for alternative service is granted. The Clerk of Court is directed to close the motion pending at Docket Number 97. Defendant Maxwell's time to move or answer is twenty-one days from the date of this order. If Maxwell chooses not to appear, the plaintiff may pursue whatever remedies are available, including the entry of a default judgment. + +SO ORDERED. + +Dated: New York, New York January 30, 2018 + +g. %Cate- n G. 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McCawley, Esq. Telephone: (954) 356-0011 Email: smccawlcy@bstllp.com + +January 31, 2018 + +## VIA ECF + +Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et at, Case No.: 17-cv-00616 (JGKI + +Dear Judge Koeltl: + +We represent Plaintiff, in the above-referenced matter and write to respectfully request a thirty-one (31) day extension of time until February 26, 2018 to file a consolidated opposition to (1) Defendants Motion to Dismiss (DE 79 & 80) and (2) Defendants Supplemental Motion to Dismiss (DE 104 & 105). In addition, Plaintiff also requests permission to file a fifty (50) page consolidated opposition brief, which mirrors the page extension the Defendants received. + +Counsel for Plaintiff has conferred with counsel for Defendants and Defendants have agreed to the thirty-one (31) day extension as well as the fifty (50) page limitation. + +Accordingly, Plaintiff respectfully request that she be permitted to submit her opposition by February 26, 2018 and to be permitted to submit fifty (50) pages in opposition to Defendants' multiple motions to dismiss. + +Respectfully submitted, + +Is/Sigrid S. 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McCawley, Esq. +Telephone: (954) 356-0011 +Email: [smccawley@bsfllp.com](mailto:smccawley@bsfllp.com) + +January 31, 2018 + +**VIA ECF** + +Hon. John G. Koeltl +United States District Court +United States Courthouse +500 Pearl Street +New York, NY 10007 + +**Re: Jane Doe 43 v. Jeffrey Epstein, et al., +Case No.: 17-cv-00616 (JGK)** + +*Application granted +So ordered. +2/1/18 at S.D.S.* + +Dear Judge Koeltl: + +We represent Plaintiff, [REDACTED] in the above-referenced matter and write to respectfully request a thirty-one (31) day extension of time until February 26, 2018 to file a consolidated opposition to (1) Defendants Motion to Dismiss (DE 79 & 80) and (2) Defendants Supplemental Motion to Dismiss (DE 104 & 105). In addition, Plaintiff also requests permission to file a fifty (50) page consolidated opposition brief, which mirrors the page extension the Defendants received. + +Counsel for Plaintiff has conferred with counsel for Defendants and Defendants have agreed to the thirty-one (31) day extension as well as the fifty (50) page limitation. + +Accordingly, Plaintiff respectfully request that she be permitted to submit her opposition by February 26, 2018 and to be permitted to submit fifty (50) pages in opposition to Defendants' multiple motions to dismiss. + +Respectfully submitted, + +*Is/ Sigrid S. McCawley* +Sigrid McCawley, Esq. + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC# \_\_\_\_\_ +DATE FILED: 2-2-18 + +cc: All Counsel of Record + +BOIES SCHILLER FLEXNER LLP \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820066/EFTA02820066.metadata.json b/marker2/court-jane-doe-43/EFTA02820066/EFTA02820066.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d6ce7d6f843bb4d93a03f5dc9373d1193c128be3 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820066/EFTA02820066.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820066.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1529, + "elapsed_seconds": 6.58, + "image_assets": [ + "_page_0_Picture_20.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 82.62, + 153.09 + ], + [ + 130.968, + 153.09 + ], + [ + 130.968, + 166.04999999999998 + ], + [ + 82.62, + 166.04999999999998 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 28 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 3 + ], + [ + "Picture", + 2 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820066" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820066/_page_0_Picture_20.jpeg b/marker2/court-jane-doe-43/EFTA02820066/_page_0_Picture_20.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..45f1d3f70af84c01ecd4f2ff77d4735c2f95fbcd --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820066/_page_0_Picture_20.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:14b75b6736c3b0d91637da2899c1a0d9ac0d940e6651a754fa0a679ef319b0cb +size 6503 diff --git a/marker2/court-jane-doe-43/EFTA02820067/EFTA02820067.md b/marker2/court-jane-doe-43/EFTA02820067/EFTA02820067.md new file mode 100644 index 0000000000000000000000000000000000000000..5b265a9991b9ef584cd53bea486e811ed8406bec --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820067/EFTA02820067.md @@ -0,0 +1,292 @@ +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT NEW YORK + +x + +JANE DOE 43, + +I 7-cv-00616-JGK + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +Defendant. + +x + +#### DEFENDANT MEMORANDUM OF LAW IN SUPPORT OF SUPPLEMENTAL MOTION TO DISMISS + +John E. Stephenson, Jr. (admitted pro hac vice) Jonathan D. Parente (pro hac vice forthcoming) ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, Georgia 30309 (404) 881-7000 john.stephenson@alston.com jonathan.parente@alston.com + +Alexander S. Lorenzo ALSTON & BIRD LLP 90 Park Avenue New York, New York 10016 (212) 210-9400 alexanderlorenzo@alston.com + +# TABLE OF CONTENTS + +| INTRODUCTION | 1 | +|----------------------------------------------------------------|------------------------------------------------------------------| +| BACKGROUND | 1 | +| APPLICABLE LAW | 4 | +| ARGUMENT | 5 | +| 1. Plaintiff has failed to state a claim that | violated Section 1591. 5 | +| A. | The Act does not cover the type of consenting-adult relationship | +| alleged | 6 | +| B. | The Amended Complaint fails to meet the Twomblyllqbal pleading | +| standards. | 7 | +| C. Plaintiff cannot plausibly allege that | had the requisite | +| knowledge under Section 1591 | 10 | +| II. The Amended Complaint does not state a Section 1592 claim. | 15 | +| III. The claim against is time-barred | 16 | +| IV. This Court is not a proper forum for Plaintiff's action. | 18 | +| CONCLUSION | 18 | + +## TABLE OF AUTHORITIES + +| CASES Abarca v. little, | | | Page(s) | +|------------------------------------------------------------------|-----------------------------------------------------|----------------------------------|-------------| +| 54 F.Supp.3d 1064 (D. | Minn. Allison v. Round Table Inv. Mgmt. Co., LP, | 2014) | 16, 17 | +| 447 F. App'x | 274 (2d Cir. 2012) Am. Sales Co. v. AstraZeneca AB, | | 1 | +| No. 10 Civ. 6062, 2011 Ashcroft v. lgbal, | WL | 1465786 (S.D.N.Y. Apr. 14, 2011) | 8 | +| 556 U.S. 662 (2009) Atuahene v. City of Hartford, | | | passim | +| 10 F. App'x Bell Atl. Corp. v. Twombly, | 33 (2d Cir. 2001) | | 9 | +| 550 U.S. 544 (2007) Daimler AG v. Bauman, | | | 4, 13 | +| 134 S. Ct. 746 (2014) D'Attore v. City of New York, | | | 18 | +| No. 10 CIV. 6646, 2013 Elias v. City of New York, | WL | 1180395 (S.D.N.Y. Mar. 15, 2013) | 10 | +| No. 10-CV-5495, 2010 Greenberg v. Christ, | WL | 5475809 (E.D.N.Y. Dec. 30, 2010) | 9 | +| 198 F.Supp.2d 578 (S.D.N.Y. 2002) Gucci Am., Inc. v. Weixing Li, | | | 13 | +| 768 F.2d 122 (2d Harris v. Mills, | Cir. 2014) | | 18 | +| 572 F.3d 66 (2d | Cir. 2009) Kelsey v. Goldstar Estate Buyers Corp., | | 15 | +| No. 3:13-CV-00354-HU, 2014 WL 1155253 (D. | | Or. Mar. | 21, 2014) 8 | +| No. 10-CV-4124, 2013 WL 6816174 (W.D. | | Ark. Dec. 24, 2013) | 15 | + +- Lentell v. Merrill & Co., 396 F.3d 161 (2d Cir. 2005) 4 Lunkes v. Yannai, 882 F. Supp. 2d 545 (S.D.N.Y. 2012) 7 +- v. City of New York, No. 07 Civ. 7834, 2008 WL 1826483 (S.D.N.Y. Apr. 23, 2008) 9 0 & G Carriers, Inc. v. M, 799 F. Supp. 1528 (S.D.N.Y. 1992) 8 Oluch v. Orina, 101 F.Supp.3d 325 (S.D.N.Y. 2015) 16, 17 Rosner v. Bank of China, No. 06 CV 13562, 2008 WL 5416380 (S.D.N.Y. Dec. 18, 2008) 11 San Leandro Emergency Med. Grp. v. Philip Morris Co., 75 F.3d 801 (2d Cir. 1996) 11 St. Louis v. Perlitz, No. 3:13-CV-1132, 2016 WL 1408076 (D. Conn. Apr. 8, 2016) 5 Townes v. City of New York, 176 F.3d 138 (2d Cir. 1999) 10 United States v. Corley, No. 14-1709, 2017 WL 549021 (2d Cir. Feb. 9, 2017) 7 United States 621 F.3d 101 (2d Cir. 2010) 7 United States v. Todd, 627 F.3d 329 (9th Cir. 2010) 14 Velez v. M, 693 F.3d 308 (2d Cir. 2012) 16 Walden v. Fiore, 134 S. Q. 1115 (2014) 18 Weinstein Co. v. Smokewood Entm't Grp., 664 F. Supp. 2d 332 (S.D.N.Y. 2009) 8 ex rel. U.S. v. Applied Research Assocs., Inc., 328 F. App'x 744 (2d Cir. 2009) 12 + +# Rums + +| Fed. R. Civ. P. 8 | 8 | +|--------------------------|----| +| Fed. R. Civ. P. 9(b) | 12 | +| Fed. R. Civ. P. 12(b)(6) | 4 | +| Fed. R. Civ. P. 12(f) | 3 | + +## STATUTES + +| Victims of Trafficking and Violence Protection Act of 2000, 18 U.S.C. § 1591, et seq. ..... | passim | +|----------------------------------------------------------------------------------------------------|--------| +| 18 U.S.C. § 1591 ..... | passim | +| 18 U.S.C. § 1592..... | 15 | +| 18 U.S.C. § 1593A ..... | 16 | +| 18 U.S.C. § 1594..... | 14 | +| 18 U.S.C. § 1595..... | 5, 16 | + +## OTHER AUTHORITIES + +## INTRODUCTION + +The Amended Complaint represents Plaintiff's second (unsuccessful) attempt to state a claim that Jeffrey Epstein's personal assistant—violated federal sex-trafficking laws. As contemplated by the Court's directives, sent a pre-motion letter that identified and discussed the initial Complaint's fatal flaws. Plaintiff responded with her Amended Complaint, presumably in an effort to cure its shortcomings. But the Amended Complaint remains legally deficient—failing for all the same reasons as the initial Complaint. + +Among other problems, the Amended Complaint's allegations (i) stem from a consensual, adult relationship that is beyond the scope of the Victims of Trafficking and Violence Protection Act, 18 U.S.C. § 1591, et seq., (ii) are insufficient to state a claim against personally because, among other defects, they fail to plausibly allege that had the requisite actual knowledge for a statutory violation, (iii) highlight that any theoretical claim that Plaintiff might have otherwise had is barred by the applicable statute of limitations, and (iv) reveal that this Court is not the proper forum. Plaintiff has no legally viable claim, and especially no claim against Having failed twice to state a claim, the case against must be dismissed. + +#### BACKGROUND' + +In October 2006, Plaintiff met Defendant Jeffrey Epstein. (Am. Compl. 1 34.) Plaintiff was then an adult woman over the age of 18. There are no allegations that she was uneducated, inexperienced in the world, or had anything less than full mental capacity. Epstein was older than her—already in his mid-fifties. (Id. 1 11.) He was unmarried. And he was wealthy (a successful hedge-fund manager worth more than a billion dollars). (Id. TI! I I. 60.) + +I For purposes of this motion only, the factual allegations in the Amended Complaint are accepted as true. See Allison v. Round Table Inv. Mgmt. Co., LP, 447 F. App'x 274, 275 (2d Cir. 2012). + +Soon after they met, the two entered into a consensual relationship. (Am. Compl. 1 43.) Epstein agreed to provide—and did provide—Plaintiff with a cell phone, a car service, and an apartment in the Upper East Side of Manhattan. (Id. 1 52.) They engaged in sexual acts "dozens of times" at his "townhouse in New York and on his private island in the U.S. Virgin Islands." (Id. 145.) + +According to the Amended Complaint, Epstein "confirmed" to Plaintiff 'That he would use his wealth and influence to have [her) admitted into the Fashion Institute of Technology (known as 'F.I.T.') in New York City or into a similar institute of higher learning offering a curriculum of fashion industry training." (Am. Comp1.1 38.) Other defendants, including some of Epstein's employees, allegedly "confirmed and reiterated this promise." (Id.) Plaintiff further claims that Epstein and Defendant Ghislaine Maxwell told her that 'They also had the ability to make sure that she would obtain no formal education or modeling agency contract if she failed to provide the sexual favors desired." (Id. 1 41. + +In January 2007, Plaintiff left New York and flew to South Africa. (Am. Compl. 1 38.) That is where she is originally from (id. 1 3) and where her parents lived (id. 1 58). According to the allegations, Plaintiff was there on a "recruitment assignment" to find a South African model that Epstein could hire as an assistant, but she chose not to complete that assignment. (Id. 11 55- 56.) By her own account, "based upon Plaintiffs experience," she "did not believe the requested model would be placed in a legitimate position of employment of Defendant Epstein." (!d.156.) + +In February 2007, Plaintiff nevertheless decided to return to New York. (Am. Comp1.1 61.) Epstein and Maxwell allegedly confirmed again their commitment to "help + +Plaintiff be admitted to F.I.T. or a comparable college." (Id.1 61.) But according to the Amended Complaint, they "failed and refused to perform" that promise. (Id. 1 62.) 2 + +By May 2007, Plaintiff had once again left the United States-this time for good. (Am. Compl. 1 64.) + +Nearly a decade later, on January 26, 2017, Plaintiff brought this lawsuit under the Victims of Trafficking and Violence Protection Act. (Dkt. No. 1.) Claiming that false promises "induce[d] and coerce[d]" her to have sex with Epstein, the Amended Complaint asserts human-trafficking claims against Epstein, Maxwell, and four other individuals. (Am. Compl. 1 68.) Among the named defendants is Epstein's former personal assistant maintained Epstein's schedule and also handled various travel arrangements, which allegedly included flights for Plaintiff on commercial airlines and Epstein's private jet. (Id. ¶1 15, 51.) 3 + +2To be sure, Plaintiff does not allege that she applied to F.I.T. (or a similar institute), that she was qualified for admission, or—if she did apply—that her application was denied. + +3joins Defendants Epstein and Groff's request that paragraphs 11-33 of the Amended Complaint should be stricken under Rule 12(f). (See Epstein and Groff's January 26, 2018 Memorandum of Law, at pp. 5-6.) Those paragraphs assert scandalous, harassing, and immaterial allegations about unrelated proceedings, including Epstein's earlier guilty plea in Florida. The claims there involved events leading up to a 2005 criminal investigation in that State. By contrast, the allegations here took place in 2006 (not before 2005), relate to an adult relationship (no allegations about a minor), and occurred in New York and the Virgin Islands (not Florida). For these same reasons, Plaintiffs initial Complaint acknowledged that she did not claim to be a victim in connection with the Florida criminal proceedings. (See, e.g., Dkt. No. I, 1 29.) + +On May 15, 2017, sent a pm-motion letter identifying the many deficiencies in the initial Complaint. (Declaration of John E. Stephenson, Exhibit A.) In response, on June 5, 2017, Plaintiff elected to file her Amended Complaint, which is the subject of this motion to dismiss. + +## APPLICABLE LAW + +## A. Standard of Review + +To survive a motion to dismiss under Rule 12(b)(6), "a complaint must contain sufficient factual matter, accepted as true, to 'state a claim to relief that is plausible on its face.'" Ashcroft v. lqbal, 556 U.S. 662, 678 (2009) (quoting Bell All. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). "A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." lqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 556). There must be more than the "mere possibility of misconduct" (Iqbal, 556 U.S. at 679): The allegations must "nudge[] then claims across the line from conceivable to plausible." Twombly, 550 U.S. at 570. + +Courts will draw reasonable inferences in the plaintiff's favor but need not accept as true "conclusions of law or unwarranted deductions of fact." Lentell v. Merrill & Co., 396 F.3d 161, 174-75 (2d Cir. 2005). "A pleading that offers 'labels and conclusions' or a 'formulaic recitation of the elements of a cause of action will not do.'" lqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 555). "Nor does a complaint suffice if it tenders 'naked assertion[s]' devoid of 'further factual enhancement.'" M. + +A motion to dismiss for lack of personal jurisdiction "is inherently a matter requiring the resolution of factual issues outside of the pleadings and all pertinent documentation submitted by the parties may be considered in deciding this motion." John Hancock Prop. & Cas. Ins. Co. v. Universale Reinsurance Co., No. 91 CIV 3644, 1992 WL 26765, at \*6 (S.D.N.Y. Feb. 5, 1992). + +Allegations may be deemed refuted when the defendant meets them "with direct, highly specific, testimonial evidence regarding a fact essential to jurisdiction." Tannerite Sports, LLC v. NBCUniversal Media LLC, 135 F. Supp. 3d 219, 228 (S.D.N.Y. 2015). + +## B. The Victims of Trafficldng and Violence Protection Act + +The Victims of Trafficking and Violence Protection Act of 2000, 18 U.S.C. § 1591, a seq., criminalizes certain activities related to an enterprise that engages in commercial sex trafficking of children or deceived adults. In particular, broken down into elements, the applicable version of Section 1591(a)(1) declares that: + +[1] Whoever [2] knowingly -- [3] in or affecting interstate or foreign commerce . . [4] recruits, entices, harbors, transports, provides, or obtains by any means [5] a person; [6] knowing that [7][a] force, fraud, or coercion . . . will be used to cause the person to engage in a commercial sex act, or [b] that the person has not attained the age of 18 years and will be caused to engage in a commercial sex act, [8] shall be punished as provided in subsection (b). + +18 U.S.C. § 1591(a)(1) (2006).4 + +Section 1595 gives a sex-trafficking victim the right to bring a civil action against the perpetrator who violated the Act's criminal provisions. 18 U.S.C. § 1595(a). + +## ARGUMENT + +# I. Plaintiff has failed to state a claim that violated Section 1591. + +The sex-trafficking case against fails to state a claim, for at least three reasons: First, the consensual, adult relationship at issue is outside the scope of conduct meant to be + +4 Plaintiff's claim stems from alleged conduct in 2006 and 2007, so the statute in effect at that time governs the analysis here. Applying later amendments to this statute impermissibly risks expanding defendants' liability for past conduct. See Sr. Louis v. Perlitz, No. 3:13-CV-1132, 2016 WL 1408076, at \*3 (D. Conn. Apr. 8, 2016). + +regulated by the Victims of Trafficking and Violence Protection Act. Second, the allegations fall short measured against the TwombIyliqbal pleading standards. Third, Plaintiff cannot plausibly allege that possessed the actual knowledge that would be required for a sex-trafficking claim under Section 1591. + +### A. The Act does not cover the type of consenting-adult relationship alleged. + +Plaintiff and Epstein, as consenting adults, voluntarily engaged in sexual activity. Their private relationship and the ultimate differences they encountered are beyond the aims of the Victims of Trafficking and Violence Protection Act—falling outside the scope of conduct that Congress intended to regulate and prohibit. + +incorporates by reference—and expressly adopts—the arguments on this point from Defendants Epstein and Groff's January 26, 2018 Memorandum of Law at pp. 7-9. In short, Congress passed Section 1591 of the Act to "combat trafficking in persons, a contemporary manifestation of slavery whose victims are predominantly women and children." H.R. Conf. Rep. 106-939 (2000). It is about ending trafficking and forced commercial sex acts by women who were lured into the United States by means of fraud. Id. + +That is not this case. Plaintiff already lived in New York City before she met Epstein, apparently having moved there for reasons completely unrelated to these Defendants. Plaintiff was not a victim "lured" into this Country by human traffickers. She voluntarily entered into a relationship with Epstein among other reasons because—in her estimation—it might bring the advantage of helping her get into college. There were other benefits, too: "living quarters ... a car service for Plaintiff to use as needed; [and] a cell phone." Plaintiff was not "caused" to engage in commercial sex acts by way of "fraud." Her relationship with Epstein had the hallmarks of the not uncommon arrangement in which an older male offers support to a younger female companion. (Declaration of John E. Stephenson, Exhibit B.) That Epstein allegedly did not deliver on one + +promise as quickly as Plaintiff might have preferred cannot turn this into a violation of federal sextrafficking laws.5 + +### B. The Amended Complaint fails to meet the 7'womblyllgbal pleading standards. + +Plaintiff's purported claim does not meet the Twombly/Igbal pleading requirements. The allegations lack necessary factual support and improperly lump all five Defendants together. + +Focusing on the allegations that can be construed as directed at =, many simply recite Section 1591's legal conclusions and statutory buzzwords. For instance, in Paragraph 51, the Amended Complaint appears to allege that Defendants Groff, Maxwell, and "worked in concert with one another to recruit, procure, entice, and otherwise cause many other females to engage in commercial sex acts, through their use of threats, fraud, and coercion." (Am. Compl. 1 51.) By way of further illustration, Paragraph 20—which should not have been included in the first place, and relates only to the criminal proceedings in Florida that, as Plaintiff admits, have no connection to her—asserts that "Defendants Epstein and Maxwell, with help from assistants, + +5 A survey of decisions involving the Victims of Trafficking and Violence Protection Act confirms that the allegations here bear little resemblance to the facts in those cases. See, e.g., United States v. 621 F.3d 101, 103 (2d Cir. 2010) (defendant "induced a fourteen-year old ninth-grader to work for him as a prostitute"; when "using two eighteen-year old girls as prostitutes," he "raped both of them" and "held them against their will and exploited their addiction to heroin"); braes v. Yannai, 882 F. Supp. 2d 545 (S.D.N.Y. 2012) (defendant allegedly lured victims "using websites designed to match women seeking work as au pair with families in need of such workers" and "deceived them into illegally entering the United States, where he proceeded to effectively imprison them in his house, sexually abuse them, and demand unpaid domestic services"); United States v. Corley, No. 14-1709, 2017 WL 549021 (2d Cir. Feb. 9, 2017) (defendant recruited minors to work for him as prostitutes, advertising the victims online). + +associates and underlings, recruited and procured hundreds of girls" and that "such recruitment and procurement included fraud, coercion, threats, intimidation, fear, the threat of coercion, and a combination of these and similar tactics." US 1 20.) These assertions "do not allege facts": "They are simply a regurgitation of [Section 1591's] wording woven together with conclusory statements." Kelsey v. Goldstar Estate Buyers Corp., No. 3:13-CV-00354-HU, 2014 WL 1155253, at \*5-6 (D. Or. Mar. 21, 2014). Plaintiff's formulaic recitation of the elements— "[njaked assertions devoid of further factual enhancement" (Iqbal, 556 U.S. at 678)—will not do. See also Weinstein Co. v. Smoknvood Entm't Grp., 664 F. Supp. 2d 332, 338 (S.D.N.Y. 2009) ("The tenet that a court must accept as true all of the allegations in a complaint is inapplicable to legal conclusions.") (quoting Iqbal). + +At the same time, the Amended Complaint repeatedly and improperly lumps all Defendants together. Plaintiff alleges, for example, that "Defendants recruited Plaintiff into their sexual enterprise." (Am. Compl. 1 34.) Later, she alleges that "Defendants all participated in arranging for Plaintiff to be transported" (id. 1 45); "Defendants further used possession and control of Plaintiff's passport" (id. 1 49); and "Defendants provided living quarters for Plaintiff . . . a car service . . . a cell phone" (id. 1 52). Such group-pleading runs afoul of Rule 8, which requires "'specification' as to the particular activities by any particular defendant . . .." Am. Sales Co. v. AstraZeneca AB, No. l0Civ.6062, 2011 WL 1465786, at \*5 (S.D.N.Y. Apr. 14, 2011); 0 & G Carriers, Inc. v. 799 F. Supp. 1528, 1538 (S.D.N.Y.1992) (dismissing claims because of "repeated undifferentiated grouping of defendants so that it is impossible to tell what each individual defendant is accused of doing"). + +To survive a motion to dismiss, Plaintiff must "indicate clearly the defendants against whom relief is sought and the basis upon which the relief is sought against the particular defendants." v. City of New York, No. 07 Civ. 7834, 2008 WL 1826483, at \*I (S.D.N.Y. Apr. 23, 2008). But that did not happen. Instead, Plaintiff asserts allegations generally against all Defendants—betraying the pleading standard's purpose to put on notice as to the specific allegations she need defend against. See Atuahetie v. City of Hartford, 10 F. App'x 33, 34 (2d Cir. 2001) (holding that allegations "failed to differentiate among the defendants, alleging instead violations by 'the defendants"); Elias v. City of New York, No. 10—CV-5495, 2010 WL 5475809 (E.D.N.Y. Dec. 30, 2010) (plaintiff failed to give defendants fair notice of claims where complaint "attribute[dj discrimination, retaliation, and disparate treatment generally to `Defendants"). + +Plaintiff's lumping of Defendants is not only impermissible but also implausible. Taken literally, her allegations would claim that all five Defendants recruited Plaintiff to have sex with Epstein, and that each of the five then provided her an apartment, a driver, and a mobile phone. It does not make sense. Plus, some of the allegations that refer broadly to "Defendants" are later clarified and narrowed so as to specifically exclude=. For instance, the Amended Complaint first states that "Defendants recruited Plaintiff" (Am. Compl. 1 34), but the next paragraph details how it was Defendant Natalya that allegedly "approached and recruited Plaintiff." (Id. ¶ 35.) While Plaintiff's allegations suggest that the "Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts" (id. 1 57), the surrounding lines elaborate that this portion of the Amended Complaint relates to only some of the Defendants—having nothing to do with alleged conduct by + +Plaintiff's allegations lack factual detail, state little more than legal conclusions, and impermissibly lump 'Defendants" together. Because the Amended Complaint falls short under Twolubly/kbal,Plaintiff has failed to state a claim. + +And Plaintiff's claim also fails for another reason. As discussed in Defendants Epstein and Groff's January 26, 2018 Memorandum of Law at p. 24, [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] That alone gives reason to dismiss this action. + +**C. Plaintiff cannot plausibly allege that [REDACTED] had the requisite knowledge under Section 1591.** + +The Amended Complaint does not plausibly allege that [REDACTED] had the requisite knowledge. For this reason alone, any potential claim against [REDACTED] is subject to dismissal. + +To state a claim for violation of 18 U.S.C. § 1591, Plaintiff must allege that [REDACTED] performed one of the enumerated trafficking acts while "knowing" that "force, fraud, or coercion" would be used to cause Plaintiff to engage in a commercial sex act. The upshot? Even if Plaintiff could allege that [REDACTED] "transported" her, and even if we assume that it was for purposes of a + +"commercial sex act," Plaintiff would still need to allege that knew that "force, fraud, or coercion" would cause her to have sex with Epstein. This she has not done.\* + +### 1. The purported "fraud" claim. + +Plausible actual-knowledge allegations demand factual content. See Rosner v. Batik of China, No. 06 CV 13562, 2008 WL 5416380, at \*5 (S.D.N.Y. Dec. 18, 2008), eV, 349 F. App'x 637 (2d Cir. 2009) ("[W]hile the element of actual knowledge may be alleged generally, the plaintiff still must accompany that general allegation with allegations of specific facts that give rise to a strong inference of actual knowledge regarding the underlying fraud"); see also San Leandro Emergency Med. Grp. Profit Sharing Plan v. Philip Morris Co., 75 F.3d 801, 812 (2d Cir. 1996) ("[P]laintiffs allege no facts supporting their assertion that defendants had knowledge ... [n]or do plaintiffs offer anything but conclusory allegations to support their contention that defendants knew."). And yet Plaintiff's assertions here are conspicuously void of specific facts. For context, in the initial Complaint, there were no allegations (express or implied, plausible or not) that knew that the other Defendants might use force, fraud, or coercion to cause Plaintiff to engage in commercial sex with Epstein. After pointed out the deficiency in her May 15, 2017 pm-motion letter, Plaintiff elected to file the Amended Complaint. In the revised pleading, Plaintiff now alleges that "knew that Plaintiff was actually being recruited for sexual purposes" and "knowingly made false representations to ensure that Plaintiff would cooperate in fulfilling Epstein's sexual desires." (Am. Comp!. 1 40.) But Plaintiff cannot solve + +6 In the alternative, Section 1591 allows for liability where a defendant instead acts "knowing" that the person who "will be caused to engage in a commercial sex act" has "not attained the age of 18 years." But that portion of the statute's text cannot apply here: Plaintiff is, and at all relevant times was, over the age of 18. + +the problem by adding the conclusion that "knew" that fraud would be used to make Plaintiff perform sex acts, or weaving in the blanket statement that "knowingly." all the while acted + +At most, the allegations might support an inference that Plaintiff was "being recruited for a sexual purpose" and that would have known that "confirmed and reiterated" promises about Epstein's ability to help with Plaintiff's education. (Am. Compl. 11 38, 40.) But that still would not make for a plausible inference that knew that any fashion-school-related representations might have been false. Said another way, there is no basis (alleged, or otherwise) to infer that acted knowing of others' fraudulent intent—that Epstein or others never meant to make good on promises to help Plaintiff gain admission into FIT or a similar school.? + +And the allegations that have been made are such that the only plausible inference is that expected Epstein to follow through on his commitments. The few specific allegations in the Amended Complaint confirm that understanding would have been that Epstein intended to keep any promises of assistance. Plaintiff's allegations confirm that Epstein provided Plaintiff with a cell phone, car service, and even an Upper East Side apartment. (Am. Compl. 1 52.) He supposedly "continued to provide Plaintiff with things of value" as their relationship + +&#x27; To the extent the Amended Complaint can be construed as asserting that herself "repeated" false representations, Plaintiff has failed to plead fraud with the requisite particularity required by Rule 9(b). See Fed. R. Civ. P. 9(b). She does not allege when, where, or how allegedly "confirmed and reiterated" or "repeated" others' alleged fraudulent promises to Plaintiff. Nor are there allegations to detail the statements attributed to =. ex rel. U.S. v. Applied Research Assocs., Inc., 328 F. App'x 744, 747 (2d Cir. 2009) ("(1)n alleging fraud or mistake, a party must state with particularity the circumstances constituting fraud or mistake."). + +progressed. (Id.1 62.) This establishes that Epstein made good and delivered on earlier promises. How could know whether Epstein intended to deliver on these first three promises, but not his fourth? The Complaint does not say.8 + +That Epstein did not ultimately follow through on this last commitment is not sufficient to show that the alleged representations about F.I.T. were false when made, and certainly insufficient to show that knew of any falsity or fraudulent intent. See Greenberg v. Christ, 198 F.Supp.2d 578, 583 (S.D.N.Y. 2002) ("[Fjailure to fulfill a promise to perform future acts is not grounds for a fraud action" and "fraudulent intent cannot be inferred merely from the nonperformance of a party's representations"). Slapping a "knowing" label here and there throughout the Amended Complaint does not cure its deficiencies. There is no mention of a conversation, agreement, or any significant interaction between Epstein and on the subject of the alleged fraud. Plaintiff herself concedes that certain so-called "underlings" participated in the alleged "scheme" "wittingly and unwittingly." (Am. Compl. 1 19) (emphasis added). The "mere possibility of misconduct" is decidedly not enough. lqbal, 556 U.S. at 679. + +There are no allegations to "nudge" Plaintiff's knowledge-based claim against "across the line from conceivable to plausible." Twombly, 550 U.S. at 570. In the end, had no reason to know whether Epstein or others subjectively intended to fulfill the educational promise to Plaintiff. + +8 Plaintiff also alleges that told Plaintiff that Epstein had used his wealth and influence to advance own career. (Am. Compl. 1 53.) But Epstein did help This makes it even less plausible that had reason to think that anyone was using "fraud" to force Plaintiff to engage in a commercial sex act. + +### 2. The purported "coercion" claim. + +Nor are there plausible allegations that knew that some "coercion" would be used to cause Plaintiff to have sex with Epstein. The purported coercive statements are attributed primarily to "Epstein and Maxwell." name is not uttered in connection with any of those claims. For example, Paragraph 41 states that "Maxwell and Epstein also threatened Plaintiff that, while they had the ability to advance her education and career, they also had the ability to make sure that she would obtain no formal education or modeling agency contract if she failed to provide the sexual favors desired." (Am. Compl. 1 41.) is not alleged to have participated in or been aware of such "threats." Again in Paragraph 48, "Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance ... and [to] continue performing the demanded commercial sex activity." (Id. 1 48.) Only "these Defendants" (id. ¶ 48)—not \_—are mentioned as having alleged involvement in the so-called coercion. + +Plaintiff does not allege that repeated or confirmed the alleged threats, or that she knew that any threats might be used to cause Plaintiff to engage in a commercial sex act. Thus, where the fraud-based allegations against are deficient for lack of knowledge, the allegations about coercion are even worse. + +Plaintiff cannot invoke the civil remedy under Section 1595 since she does not and cannot plausibly allege that knew that "force, fraud, or coercion" would be used to cause Plaintiff to engage in a commercial sex act. Without the requisite knowledge, Plaintiff might be able to allege that engaged in conduct that other people might not look favorably upon, or possibly even conduct that is prohibited by some other statute. But she cannot state a claim for relief under this statute. See United States v. Todd, 627 F.3d 329, 335 (9th Cir. 2010) ("Where a defendant + +engages in sex trafficking without the use of force, fraud, or coercion, or where children are not involved, his conduct is criminalized by a different set of statutes."); see also Kolbek v. Twenty First Century Holiness Tabernacle Church, Inc., No. 10-CV-4124, 2013 WL 6816174, at \*16 (W.D. Ark. Dec. 24, 2013) (dismissing Section 1595 civil claim where defendants may have violated other sex-related statutes but not Section 1591). Without knowledge, there is no Section 1591 claim against =. 9 + +# II. The Amended Complaint does not state a Section 1592 claim. + +Section 1592 makes it unlawful to "knowingly destroy, conceal, remove, confiscate, or possess any actual or purported ... government identification document, of another person" during the commission of trafficking activities. 18 U.S.C. 1592(a). Plaintiff parrots back the language from this statute. Indeed, for the first time in the Amended Complaint, Plaintiff makes conclusory statements that Defendants "took possession of Plaintiff's passport" and "used possession and control of Plaintiff's passport" to coerce her into performing sexual acts. (Am. Compl. II 45, 49, 54, 69.) + +Here again, Plaintiff fails to provide any specific facts to make a plausible claim. When did the Defendants take her passport? Did they take it from her without her knowledge? With force? Or did she willingly hand it over? What was the purported reason for which they had her passport? How long did they hold her passport? And how did the Defendants "use possession and control" of the passport to cause her to perform sexual acts? The allegations give no answers. Instead, they merely state conclusions pulled directly from the language of the statute. See Harris + +9 For similar reasons, Plaintiff's effort to add a claim that Defendants violated Section 1594(a) (Am. Compl. I 71 )—separately prohibiting "attempted" violations of Section 1591—must also fail. + +v. Mills, 572 F.3d 66, 72 (24 Cir. 2009) ("Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.") (quoting lqbal). + +To the extent Plaintiff means to plead a Section 1592 violation, any such claim is inadequate as a matter of law.10 + +## III. The claim against is lime-barred. + +Plaintiff has no claim against for the reasons outlined above. In all events, any theoretical cause of action against would be barred by the applicable statute of limitations. + +In 2008, the Act was amended to give victims ten years, rather than four years, to bring a private action against perpetrators under the civil-remedy provision. See 18 U.S.C. § 1595(c)(1) (as amended in 2008) ("No action may be maintained under this section unless it is commenced not later than . .. 10 years after the cause of action arose"). Here, the alleged events had all ended by 2007—before the 2008 amendment—so the four-year period still applies. See Abarca v. Little, 54 F.Supp.3d 1064, 1068 (D. Minn. 2014) (holding that four-year limitations period applies where Section 1595 claim stems from pre-2008 conduct); but see Olitch v. Orina, 101 F.Supp.3d 325, 330 (S.D.N.Y. 2015) (applying amendment retroactively). Since Plaintiff filed suit well outside of the four-year window, this action is time-barred. + +10 Nor can there be any claim based on Section 1593A. (Am. Compl. 1 70.) That provision has no application here since it was first enacted in December 2008, after all of the alleged acts had been completed. Velez v. M, 693 F.3d 308, 325 (24 Cir. 2012) (describing "well-established presumption against" retroactive amendments). Regardless, there are no plausible allegations that violated Section 1593A, which today criminalizes those who knowingly participate in or benefit from a venture in contravention of Section 1592 and 1595(a). + +But even if the ten-year statute of limitations applied, the claim against would still be barred. There is no allegation that committed any of the statute's enumerated acts (e.g., recruiting, transporting) that constitute "trafficking" since January 26, 2007—the start of the tenyear period leading up to this lawsuit. That should end the inquiry. + +In reality, the limitations period on Plaintiff's Section 1595 claim commenced no later than January 2007 and expired before the Complaint was filed on January 26, 2017. hereby incorporates by reference and adopts the arguments in Defendant Epstein and Groff's January 26, 2018 Memorandum of Law addressing this issue, at p. 24-29. + +In short, January 2007 marks when Plaintiff first left the United States.il The allegations confirm that, by then, Plaintiff's eyes were open: She was aware of and had already realized the Defendants' so-called fraudulent "scheme." That is why Plaintiff "deliberately refused to perform the recruitment assignment" in South Africa—i.e., "she knew that the requested female model would not be placed in a legitimate position of employment with Defendant Epstein." (Am. Compl. 1 56.) Plaintiff thus cannot claim to have been relying on any fraudulent representation about FIT that came after January 2007. Plus, by this point, she was at home with her parents in South Africa. She was on another continent, thousands of miles away, and beyond the reach of the Defendants, so any alleged coercion over her also necessarily ended in January 2007. See, e.g., Abarca, 54 F. Supp.3d 1064, 1070 (holding that Section 1595 claim arose when plaintiff traveled home to Mexico during "extended absences from defendants" with "physical freedom to seek legal advice and assistance"); Oluch v. Orina, 101 F. Supp. 3d 325, 330 (S.D.N.Y. 2015) (Section 1595 + +&quot; Notably, there is no allegation to suggest that this occurred on or after January 26, 2007. + +claim accrued when plaintiff first exited the defendant's home). By any measure, this action is time-barred because Plaintiff filed suit more than ten years after her cause of action arose. + +## IV. This Court is not a proper forum for Plaintiff's action. + +Even if Plaintiff could somehow articulate a viable claim—again, she cannot—this case should not proceed in the Southern District of New York. The allegations are insufficient to establish that this Court has personal jurisdiction over the Defendants. incorporates by reference—and expressly adopts—the discussion spanning pages 24 to 30 of Defendants Epstein and Groff's January 26, 2018 Memorandum of Law, + +As explained above, the statute of limitations here should be four years, but in all events no more than ten years. Because the alleged acts giving rise to liability occurred outside of the limitations period, Plaintiff cannot plead or prove the necessary "suit-related conduct" in New York. Walden v. Fiore, 134 S. Ct. 1115, 1121-22 (2014). That means Plaintiff's claim does not "arise out of or relate to" or the other Defendant's contacts with the forum state as specific jurisdiction would require. Gucci Ant., Inc. v. Weixing Li, 768 F.3d 122, 141 (2d Cir. 2014).12 + +For similar reasons, this District is an improper venue. For brevity, and to avoid duplication, incorporates by reference Defendants Epstein and Groff's arguments on this issue too. + +## CONCLUSION + +For these reasons, the case against should be dismissed in its entirety. + +12 For the avoidance of doubt, this Court likewise does not have general (or all-purpose) jurisdiction over because Plaintiff has not alleged—and cannot allege—that s domiciled in New York. Dainder AG v. Bauman, 134 S. Ct. 746, 760 (2014). + +Dated: Atlanta, Georgia January 26, 2018 + +By: /s/John E. Stephenson. Jr. + +John E. Stephenson, Jr. (admitted pro hac vice) Jonathan D. Parente (pro hac vice forthcoming) ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, Georgia 30309 (404) 881-7000 john.stephenson@alston.com jonathan.parente@alston.com + +Alexander S. Lorenzo ALSTON & BIRD LLP 90 Park Avenue New York, New York 10016 (212) 210-9400 alexander.lorenzo@alston.com + +Counsel or Defendant + +![](_page_23_Picture_6.jpeg) \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820067/EFTA02820067.metadata.json b/marker2/court-jane-doe-43/EFTA02820067/EFTA02820067.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..157b63afecfede15455e68a8155a403c32b46005 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820067/EFTA02820067.metadata.json @@ -0,0 +1,1484 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820067.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 24, + "chars": 42374, + "elapsed_seconds": 7.19, + "image_assets": [ + "_page_23_Picture_6.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 85.085, + 104.302 + ], + [ + 288.2865295410156, + 104.302 + ], + [ + 288.2865295410156, + 133.8170166015625 + ], + [ + 85.085, + 133.8170166015625 + ] + ] + }, + { + "title": "DEFENDANT \nMEMORANDUM OF LAW IN SUPPORT OF \nSUPPLEMENTAL MOTION TO DISMISS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 94.605, + 349.11000000000007 + ], + [ + 501.2032470703125, + 349.11000000000007 + ], + [ + 501.2032470703125, + 377.9470520019531 + ], + [ + 94.605, + 377.9470520019531 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 232.05000000000004, + 104.302 + ], + [ + 364.0332336425781, + 104.302 + ], + [ + 364.0332336425781, + 120.603515625 + ], + [ + 232.05000000000004, + 120.603515625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 223.125, + 105.164 + ], + [ + 373.09564208984375, + 105.164 + ], + [ + 373.09564208984375, + 120.603515625 + ], + [ + 223.125, + 120.603515625 + ] + ] + }, + { + "title": "Rums", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 84.49, + 104.302 + ], + [ + 123.85330200195312, + 104.302 + ], + [ + 123.85330200195312, + 120.43353271484375 + ], + [ + 84.49, + 120.43353271484375 + ] + ] + }, + { + "title": "STATUTES", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 84.49, + 231.01600000000002 + ], + [ + 140.65553283691406, + 231.01600000000002 + ], + [ + 140.65553283691406, + 246.363037109375 + ], + [ + 84.49, + 246.363037109375 + ] + ] + }, + { + "title": "OTHER AUTHORITIES", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 84.49, + 428.41400000000004 + ], + [ + 195.41094970703125, + 428.41400000000004 + ], + [ + 195.41094970703125, + 443.9830322265625 + ], + [ + 84.49, + 443.9830322265625 + ] + ] + }, + { + "title": "INTRODUCTION", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 248.115, + 105.164 + ], + [ + 348.01348876953125, + 105.164 + ], + [ + 348.01348876953125, + 120.3170166015625 + ], + [ + 248.115, + 120.3170166015625 + ] + ] + }, + { + "title": "BACKGROUND'", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 249.89999999999998, + 508.58 + ], + [ + 343.315, + 508.58 + ], + [ + 343.315, + 523.0670471191406 + ], + [ + 249.89999999999998, + 523.0670471191406 + ] + ] + }, + { + "title": "APPLICABLE LAW", + "heading_level": null, + "page_id": 8, + "polygon": [ + [ + 241.57000000000005, + 185.33 + ], + [ + 353.5484619140625, + 185.33 + ], + [ + 353.5484619140625, + 200.853515625 + ], + [ + 241.57000000000005, + 200.853515625 + ] + ] + }, + { + "title": "A. 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Menninger + +150 East 10th Avenue Denver. Colorado 80203 PH 303.831.7364 DC 303.832.2628 www.hmflaw.com Imenningerehmflaw.com + +February 14, 2018 + +## Via ECF + +Hon. John G. Koeltl United States District Judge United States District Court Daniel Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 + +Re: v. Jeffrey Epstein, et at, 17-cv-00616 (JGK) + +Dear Judge Koeltl: + +On January 30, 2018, this Court granted Plaintiff's motion for alternative service. ECF No. 107. Under this Court's order, Defendant Ghislaine Maxwell has until February 20, 2018 to respond to or answer the amended complaint. + +On behalf of Ms. Maxwell, I respectfully request a twenty-one day extension of time to respond to or answer the amended complaint in this case. I am presently in the process of securing local counsel for Ms. Maxwell. + +I have conferred with J. who has agreed to this request. Accordingly, I respectfully request that this Court grant a twenty-one day extension of time, up to and including March 13, 2018, within which to respond to or answer the amended complaint. + +Hon. John G. Koeltl February 14, 2018 Page 2 + +Respectfully submitted, + +HADDON, AND~, P.C. + +Is/ Laura A. Menninger Laura A. Menninger + +## CERTIFICATE OF SERVICE + +I certify that on February 14, 2018, I served the accompanying Letter Motion on the following counsel of record: + +Sigrid S. McCawley Meredith BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com + +J. JAFFE, WEISSING, FISTOS & LEHRMAN, P.I-425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com + +John E. Stephenson, Jr. Alexander S. Lorenzo ALSTON & BIRD, LLP 90 Park Avenue New York, NY 10016 john.stephenson@alston.com alexander.lorenzo@alston.com + +Paul G. Cassell 383 S. 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John G. Koeltl United States District Judge United States District Court Daniel Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 + +Haddon. and S r.c Laura A. MonnInger + +150 Easl 10lh AVOIX1O Denver. Colorado 80203 PH 303.831.7364 IX 303332.2628 www.hmflaw.com !manning orehmficree.com + +APPLICATION GRANTED SO ORDERED (9L' P er - John G. Koeltl, U.S.D.J. + +Re: v. Jeffrey Epstein, et al., 17-cv-00616 (JGK) + +Dear Judge Koeltl: + +On January 30, 2018, this Court granted Plaintiff's motion for alternative service. ECF No. 107. Under this Court's order, Defendant Ghislaine Maxwell has until February 20, 2018 to respond to or answer the amended complaint. + +On behalf of Ms. Maxwell, I respectfully request a twenty-one day extension of time to respond to or answer the amended complaint in this case. I am presently in the process of securing local counsel for Ms. Maxwell. + +I have conferred with J. who has agreed to this request. Accordingly, 1 respectfully request that this Court grant a twenty-one day extension of time, up to and including March 13, 2018, within which to respond to or answer the amended complaint. + +Hon. John G. Koeltl February 14, 2018 Page 2 + +Respectfully submitted, + +HADDON, AND P.C. + +/s/ Laura A. Menninger + +Laura A. Menninger + +## CERTIFICATE OF SERVICE + +I certify that on February 14, 2018, I served the accompanying Letter Motion on the following counsel of record: + +Sigrid S. McCawley Meredith HOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfIlp.com mschultz@bsfIlp.com + +JAFFE, WEISS1NG, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com + +John E. Stephenson, Jr. Alexander S. 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Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 + +&#x27; Plaintiff originally filed this action under the pseudonym "Jane Doe 43," but is now proceeding under her real name. + +## TABLE OF CONTENTS + +| | Pa | +|-----------------------------------------------------|---------------------------------------------------------------------| +| TABLE OF AUTHORITIES | ii | +| INTRODUCTION | 1 | +| BACKGROUND | 4 | +| ARGUMENT | 6 | +| I. | THE FACTS AND BACKGROUND REGARDING THE PRIOR PROCEEDINGS | +| ARE PROPER AND SHOULD NOT BE STRICKEN | 6 | +| SEX TRAFFICKING STATUTE | 9 | +| A. | Has Successfully Pled Fraud and/or Coercion 9 | +| Has Properly Pled a Causal Link | 13 | +| C. MEll Groff and | Has Successfully Alleged Knowledge Against Defendants | +| | Has Specifically Alleged Reasonable Reliance 15 | +| E. | Has Successfully Alleged Predicate Acts and Violation of | +| Sections 1592, 1593A, and 1594(a)-(c) | 16 | +| F. | The Amended Complaint Meets the Twomblyllqbal Pleading Standards 18 | +| III. | CLAIM IS WELL WITHIN THE STATUTE OF LIMITATIONS. 22 | +| IV. THIS COURT HAS JURISDICTION OVER THE DEFENDANTS | 27 | +| V. | VENUE IS PROPERLY LAID IN THE SOUTHERN DISTRICT OF NEW YORK 29 | +| VI. | THE COURT SHOULD IGNORE MATERIAL OUTSIDE THE COMPLAINT IN | +| RULING ON THE MOTION TO DISMISS | 29 | +| VII. IF NECESSARY, | ALSO RENEWS HER REQUEST FOR | +| JURISDICTIONAL DISCOVERY | 30 | +| CONCLUSION | 32 | +| CERTIFICATE OF SERVICE | 31 | + +## TABLE OF AUTHORITIES + +| Cases Abarca v. Little, | Page | +|---------------------------------------------------------------------------------------|------| +| 54 F. Supp. 3d 1064 (D. Minn. 2014) | 22 | +| vffi Polk & Wardwell UP, | | +| 850 F. Supp. 2d 392 (S.D.N.Y. 2012) Ashcroft v. lqbal, | 8 | +| 556 U.S. 662, 129 S. Ct. 1937, 173 L. Ed. 2d 868 (2009) | 18 | +| Ashland Inc. v. Stanley &Co., | | +| 652 F.3d 333 (2d Cir. 2011) Atuahene v. City of Hartford, | 16 | +| 10 F. App'x 33 (2d Cir. 2001) Bell AIL Corp. v. Twombly, | 20 | +| 550 U.S. 544, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007) | 18 | +| No. 12 CIV. 847 RWS, 2012 WL 3240428 (S.D.N.Y. Aug. 7, 2012) | 29 | +| Crigger v. Fahnstock & Co., Inc., | | +| 443 F.3d 230 (2d Cir. 2006) D'Attore v. City of New York | 15 | +| No., 10 CIV 6646, 2013 WL 1180395 (S.D.N.Y. Mar. 15, 2013) Elias v. City of New York, | 21 | +| No. 10-CV-5495, 2010 WL 5475809 (E.D.N.Y. Dec. 30, 2010) | 20 | +| 848 F.2d 24 (2d Cir. 1988) Geldzahler v. New York Med. Coll., | 29 | +| 663 F. Supp. 2d 379 (S.D.N.Y. 2009) Greenberg v. Chrust, | 23 | +| 198 F. Supp. 2d 578 (S.D.N.Y. 2002) Heskiaoff v. Sling Media, Inc., | 11 | +| No. 17-1094-CV, 2017 WL 5632078 (2d Cir. Nov. 22, 2017) | 18 | + +- Hudak v. Berkley Grp., Inc., No. 3:13-CV-00089-WWE, 2014 WL 354676 (D. Conn. Jan. 23, 2014) 19 I.B. Trading, Inc. v. Tripoint Glob. Equities, LLC, No. 17-CV-1962 (JGK), 2017 WL 5485318 (S.D.N.Y. Nov. 15, 2017) 6, 9 In re Enterprise Mortgage Acceptance Co., LLC Sec. Litig., 391 F.3d 401 (24 Cir. 2004) 22 In re Giant Interactive Grp., Inc. Sec. Litig., 643 F. Supp. 2d 562 (S.D.N.Y. 2009) 29 Kopec v. Coughlin, 922 F.2d 152 (2d Cir.1991) 23 Lama v. Malik, 192 F. Supp. 3d 313 (E.D.N.Y. 2016) 22 +- v. City of New York, No. 07 CIV. 7384 (DC), 2008 WL 1826483 (S.D.N.Y. Apr. 23, 2008) 20 Nagelberg v. Meli, No. 17 CIV. 2524 (LLS), 2017 WL 5201446 (S.D.N.Y. Oct. 27, 2017) 9 Precision Assocs., Inc. v. Panalpina World Transp., (Holding) Ltd., No. CV-08-42 JG VVP, 2013 WL 6481195 (E.D.N.Y. Sept. 20, 2013) 20 Schlaifer & Co. v. Estate of Andy Warhol, 119 F.3d 91 (2d Cir. 1997) 16 Schramm v. Krischell, 84 F.R.D. 294 (D. Conn. 1979) 7 Tardibuono-Quigley v. HSBC Mortg. Corp. (USA), No. 15-CV-6940 (KMK), 2017 WL 1216925 (S.D.N.Y. Mar. 30, 2017) 20 Townes v. City of New York, 176 F.3d 138 (2d Cir. 1999) 21 United States v. Marcus, 487 F. Supp. 24 289 (E.D.N.Y. 2007) 9, 12 United States v. Paris, No. CR 03:06-CR-64(CFD), 2007 WL 3124724 (D. Conn. Oct. 24, 2007) 12 Vassilatos v. Ceram Tech Int'l, Ltd., 92 Civ. 4574, 1993 WL 177780 (S.D.N.Y. May 19, 1993) 23 + +#### Statutes + +| 18 U.S.C. § 1591 | passim | +|------------------------|--------| +| 18 U.S.C. 1591(a)(2) | 12 | +| 18 U.S.C. § 1591(e)(3) | 13 | +| 18 U.S.C. § 1595 | 21 | + +## Rules + +| Fed. R. Civ. P. 9(b) | 9 | +|--------------------------|---| +| Fed. R. Civ. P. 12(b) | 9 | +| Fed. R. Civ. P. 12(6)(6) | 6 | +| Fed. R. Civ. P. I2(f) | 6 | + +Plaintiff '), by and through her undersigned counsel, opposes Defendants' Motions to Dismiss2, and states as follows. + +## INTRODUCTION + +brings a one-count cause of action against Defendants Jeffrey Epstein, Ghislaine Maxwell, ==, Lesley Groff, and Natalya (collectively, the "Epstein Defendants" or "Defendants") for engaging in commercial sex trafficking in violation of 18 U.S.C. §159I. The Epstein Defendants insultingly belittle the significant abuse by labelling the trafficking endured as a "consensual relationship" between a "young woman" and an "older man." There was nothing "consensual" about the coercion and abuse that suffered at the hands of convicted sex offender Jeffrey Epstein and his enablers. The fact that suffered in silence for many years and finally mustered the courage to speak out against her abusers should be applauded, not condemned. Going many steps too far, Defendants also claim that trafficking by Epstein was not a "commercial sex act" because Epstein Mot. to Dismiss at 19. Epstein and his enablers' acts were not •— they were malicious and calculated, and knowingly intended to cause to engage in commercial sex acts. Remember, was not Mr. Epstein's first victim. As alleged in the Amended Complaint: + +"[i]n 2005, Defendant Epstein and numerous co-conspirators within the venture and enterprise were subjects of a Palm Beach, Florida Police Department criminal investigation which revealed that Defendant Epstein has engaged in sexual activities with dozens of young teenage school children. Each child identified in that particular investigation was lured into Defendant Epstein's Palm Beach + +2 Plaintiff responds to Defendants' Motion to Dismiss [DE 80 and 83] and Supplemental Motion to Dismiss [DE 104, 105 and 111] together in this consolidated response. + +mansion with a promise that she would receive money from providing him with a body massage, although once there, each young female was made to engage in sexual acts in order to receive the promised compensation...The United States Attorney's investigation continued from 2006 through September 2007 at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office deferring federal prosecution of Defendant Epstein and his numerous co-conspirators, including Defendants and Groff, each named by the Federal Government as co-conspirators for identified federal sex crimes against more than 30 minors." + +See McCawley Decl. at Exhibit 1, Am. Compl. at 11 24-26. As explained in the Amended Complaint, Epstein had perfected a scheme of recruiting young females for illegal sexual purposes for himself and his business associates. One of the most remarkable facts of this case is the timing of the Defendants' abuse of. Epstein and his co-conspirators, including and Groff, knew they were being investigated by State and Federal authorities in Florida for the commission of serious sex offenses against dozens of minor children at the same time they brazenly continued their trafficking scheme to victimize . Epstein's attorneys were in mid-negotiations with Federal Prosecutors while Epstein was committing new sex offenses against , and the United States Attorney's Office for the Southern District of Florida had already uncovered how the scheme of recruiting victims operated. + +Defendants' system worked by having the recruiters "inform target victims that Epstein possessed extraordinary wealth, power, resources and influence; that he was a philanthropist who would help female victims advance their careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact, however, these representations were fraudulent. The young females were actually required to perform intimate sexual acts at the Defendants' direction and the Defendants did not help nor intend to help advance the victims' careers." See McCawley Decl. at Exhibit I at 1 16. And, as further alleged in the Amended Complaint: "[t]he Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein's compulsive need for sex with young females by preying on their personal, psychological, financial and related vulnerabilities. The Defendants' tactics included promising the victims money, shelter, transportation, gifts, employment, admission into educational institutions, educational tuition, protection and other things of value in exchange for sex. Defendants also took possession of the victims' passports to coerce compliance with their demands. Defendants also trafficked young females to Epstein's friends and acquaintances in order to secure financial and other benefits as well as social, educational and business connections." Id. at 1 18. + +was recruited in the same way as so many of the victims that came before her. As explained in the Amended Complaint, lbjeginning in approximately October 2006 and continuing through April 2007, Defendants recruited Plaintiff into their sexual enterprise by fraudulently promising to use their connections and resources to secure her admission to an institution of higher education at the expense of Defendant Epstein." Id. at 1 34. The promises were followed by threats. As alleged in the Amended Complaint: "Maxwell and Epstein also threated Plaintiff that, while they had the ability to advance her education and career, they also had the ability to make sure that Plaintiff would not obtain formal education or modeling agency contracts if she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions give her by Defendants Epstein, Groff, and Maxwell." Id. at 141. Epstein repeatedly required to engage in sexual acts during the massages "and made it known to Plaintiff that further sex would be required in order for her to obtain assistance he promised her and to avoid Defendants' threatened retaliation against her if Plaintiff did not perform as demanded." Id. at 1 43. + +In ruling on a motion to dismiss, the Court must take all allegations in the Amended Complaint as true and all inferences are drawn in favor of the plaintiff in determining whether she has stated a cause of action. has properly pled all elements of her claim under 18 U.S.C. § 1595, and the associated underling statutes. Defendants have not met the standard for a motion to dismiss. Accordingly, Defendants' motions to dismiss should be denied in its entirety. + +# BACKGROUND + +As alleged in detail in the Amended Complaint, Epstein, alongside Maxwell, =, Groff, and recruited and trafficked hundreds of young women in an elaborate sex trafficking venture and enterprise. Through Epstein's considerable means, wealth, and power, he sexually abused these women for his own sexual desires and further trafficked some of them to his powerful friends and other individuals. was one of these victims, having been recruited into Epstein's sexual enterprise in October 2006. , one of Epstein's many recruiters, met and introduced her to Epstein. "described [Epstein] as a wealthy philanthropist who regularly used his wealth, influence and connections to help financially poor females like Plaintiff achieve their personal and professional goals and aspirations." See McCawley Decl. at Exhibit I, Am. Compl. at 1 36. Epstein, as well as Maxwell, =, and Groff, told that Epstein would use his wealth and influence to have Institute of Technology (F.I.T.) — in exchange for admitted into the Fashion providing massages. ■ **relied on Defendants' representations. As the Amended Complaint states, "[b]etween October 2006 and May 2007, Defendants Maxwell, =, and Groff each also confirmed and reiterated this promise to Plaintiff many times, each telling Plaintiff that Epstein would use his wealth and connections to advance Plaintiff's education." Id. at '1 38. Further, "Epstein and the other Defendants represented to Plaintiff in manners that were persuasive, credible, and reasonable** to Plaintiff, as they would have been to any other person similarly situated, that they had the political, business, financial, social, educational, and other influence and connections sufficient to arrange for and insure her admission into F.I.T. or a similar school of higher learning." Id. atl 40. + +However, with the Defendants' promise came a terrible price. From October 2006 to in and around April/May 2007, the Epstein Defendants sexually abused and trafficked She was instructed to provide "body massages" for Epstein in New York and in the Virgin Islands, which were convened into a sexual act each time. As pled in the Amended complaint, "Defendant Maxwell frequently controlled the assignment, or `rotation,' of Plaintiff and the other young females concerning the time, place and manner of the sex acts they were told to provide to Defendant Epstein. Defendant Maxwell also gave instructions on how to perform certain sexual techniques on Epstein. Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with other females." Id. at 1 47. While Defendants coerced her into continued sexually compliance with false promises of a formal education, they also threatened her that they had the ability to hurt her and ensure that she would not receive an education if she did not comply. Ultimately, Defendants made good on their threats. They verbally abused her, physically restrained her when she tried to escape from Epstein's island, confiscated her passport, pressured her to lose weight to the point of malnutrition ("she underwent a diet and lowered her body weight from 57 kilograms (approximately 125 pounds) to 52 kilograms (approximately 114 pounds)" (See McCawley Decl. at Exhibit 1 at 1 57)), and refused to help her get admitted into F.I.T. or any other school. Indeed, "Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts with Epstein and others." Id. + +In fled from the United States in order to get away from Epstein and the other Defendants. As alleged in the Amended Complaint, "[i]n and after May 2007, Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's cover-up included efforts to intimidate witnesses who might provide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done." Id. at 1 65. + +#### ARGUMENT + +"In deciding a motion to dismiss pursuant to Rule 12(6)(6), the allegations in the Amended Complaint are accepted as true, and all reasonable inferences must be drawn in the plaintiffs' favor. The Court's function on a motion to dismiss is 'not to weigh the evidence that might be presented at a trial but merely to determine whether the complaint itself is legally sufficient.' The Court should not dismiss the Amended Complaint if the plaintiffs have stated 'enough facts to state a claim to relief that is plausible on its face.' A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." I.B. Trading, Inc. v. Tripoint Glob. Equities, LLC, No. 17- CV-1962 (JGK), 2017 WL 5485318, at \*1 (S.D.N.Y. Nov. 15, 2017) (internal citations omitted). + +## I. THE FACTS AND BACKGROUND REGARDING THE PRIOR PROCEEDINGS ARE PROPER AND SHOULD NOT BE STRICKEN. + +Id. On the contrary, the Defendants have not met the standard to strike, and has properly included these contextually necessary facts in her Amended Complaint. + +A court will only strike pleadings if the material is "redundant, immaterial, impertinent, or scandalous." Fed. R. Civ. P. 12(t). "Such motions are not favored and will not be granted unless it is clear that the allegations in question can have no possible bearing on the subject matter of the litigation. If there is any doubt as to the possibility of relevance, a judge should err on the side of denying a Rule 12(t) motion, especially if the presence of the material at issue does not prejudice the moving party." Schramm v. Krischell, 84 F.R.D. 294, 299 (D. Conn. 1979) (denying motion to strike). + +Here, has properly included allegations that are directly relevant to her claim of sex trafficking. Paragraphs 11 through 33 of her Amended Complaint are crucial to pleading the circumstances surrounding her trafficking, and the coercion and force whereby the Defendants trafficked her. These allegations explain how Epstein uses his wealth and power to sexually abuse young girls, and how his co-Defendants helped recruit them. These allegations are relevant to the extent that they show the Defendants' modus operandi for trafficking and sexually abusing girls in their criminal enterprise, of which was a direct victim. These facts demonstrate knowledge and motive of the Defendants as well as demonstrate that the Defendants were indeed an operating group of co-conspirators who had operated in concert as such for years. As stated in the Complaint, they show that "[b]y the time Plaintiff was recruited into victimization, each Defendant had years of experience perfecting methods of coercion, understanding Epstein's requirements, and becoming more loyal to the continuance and survival of the venture and enterprise." See McCawley Decl. at Exhibit 1, Am. Comp!. at 32. There is no prejudice to the Defendants and the allegations have probative significances, as they are part and parcel of sex trafficking claim. + +As one illustration of the importance of these allegations to the case, the Amended Complaint alleges that Defendant Epstein, acting in concert with the other co-conspirators, took steps to conceal evidence from law enforcement authorities (Id. at 1 31)— evidence that presumably remains concealed from as well even today. intends to argue at the trial in this case that, to the extent some evidence related to her trafficking may be missing, it is due to the criminal concealment of the Defendants. The jury is entitled to know the circumstances that would have prompted the Defendant to take such extraordinary and criminal action specifically, their fear of potential federal indictment. + +As an additional illustration of the importance of these allegations, the Amended Complaint also alleges a continuing cover-up — extending beyond May 2007 — in which the Defendants attempted to "intimidate witnesses who might provide corroborating testimony to Plaintiff as well as destruction of documents and other evidence of what they had done." See McCawley Decl. at Exhibit I at 1 65. Here again, it is contextually necessary to explain why the Defendants would be intimidating witnesses and destroying documents, which is what the allegations about related criminal proceedings provide. + +Here, the references to the former Epstein proceedings are certainly not taunts, but are crucial allegations to the circumstances of this case. Accordingly, the Court should deny Defendants' motion to strike. + +#### HAS PROPERLY PLED A CLAIM FOR VIOLATIONS OF THE SEX TRAFFICKING STATUTE + +has properly pled a claim for violations under 18 U.S.C. § 1591 — which clearly covers the Epstein Defendants' conduct — and has pled in detail fraud, coercion, a causal link, knowledge, and predicate acts. Defendants have not met the standard for dismissal under Rule 12(b), and their motions to dismiss must be denied. + +# A. Has Successfully Pled Fraud and/or Coercion + +has successfully pled fraud under the heightened standard under Fed. R. Civ. P. 9(b). A complaint alleging fraud must "(I) specify the statements that the plaintiff contends were fraudulent, (2) identify the speaker, (3) state where and when the statements were made, and (4) explain why the statements were fraudulent." I.B. Trading, 2017 WL 5485318, at \*2 (denying motion to dismiss fraud claim) (internal citations omitted); Nagelberg v. Meli, No. 17 CIV. 2524 (LLS), 2017 WL 5201446, at \*3 (S.D.N.Y. Oct. 27, 2017) (same). + +the sex trafficking statute covers any relationship that meets the elements of the statute, and labelling it as an does not change the fact that was sexually trafficked. + +In United States v. Marcus, 487 F. Supp. 2d 289, 304 (E.D.N.Y. 2007), rev'd on other grounds, 538 F.3d 97 (2d Cir. 2008), the defendant was convicted under 18 U.S.C. § 1591 for acts of sex trafficking in what began as an adult, consenting relationship. He appealed his sentence and tried to argue that the sex trafficking statute was "never meant to regulate conduct that occurs within a domestic, intimate relationship." Id. at 304. The court was unconvinced, finding this argument "nonsensical." Id. It held that a commercial sex act is "quite broadly defined" under the statute, and so long as the elements of the statute are present, the "mere existence of a past or present domestic, intimate relationship" does not preclude meeting the definition under the statute. + +Id. + +Here, relationship with Epstein is clearly covered under the sex trafficking statute, as she has pled that the nature of the relationship was based on fraud and coercion. The Amended Complaint satisfies all of these elements in numerous paragraphs, including: + +- introduced Plaintiff to Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology (known as "F.I.T.") in New York City or into a similar institute of higher learning offering a curriculum of fashion industry training." See McCawley Decl. at Exhibit I, Am. Compl. at 138 ((1) specifying fraudulent statement; (2) identifying speaker). +- "Between October 2006 and May 2007, Defendants Maxwell, =, and Groff each also confirmed and reiterated this promise to Plaintiff many times, each telling Plaintiff that Epstein would use his wealth and connections to advance Plaintiff's education." Id. at] 38 (( I ) specifying fraudulent statement; (2) identifying speaker; (3) stating when statements were made). +- "More specifically, each of the Defendants last verified this information that Epstein was using his connections to ensure Plaintiff was admitted into F.I.T. in exchange for Plaintiff's continued sexual cooperation with Lpstein in March or April of 2007." Id. +- "These false and fraudulent representations included Defendants' telling Plaintiff that Epstein would use his connections to have her admitted into F.I.T. or a similar institute, college, university or school of higher learning and provide her with employment opportunities." Id. at 1 40 ((I) specifying fraudulent statement; (2) identifying speaker). +- "In furtherance of their venture and enterprise, Defendants provided living quarters for Plaintiff at 301 East 66th Street, New York, in the Southern District of New York; a car service for Plaintiff to use as needed; a cell phone; and other valuable consideration in order to maintain Plaintiffs sexual compliance. Each of the Defendants told Plaintiff she would obtain the benefits of a place to live and phone + +and transportation as long as she remained compliant with their demands that she service Epstein sexually.” *Id.* at ¶ 52 ((3) stating where statements were made). + +- • “The relationship between Plaintiff and Defendants Epstein and Maxwell was defined and characterized by **Defendant Epstein’s** and **Defendant Maxwell’s** frequent and persistent fraudulent representations that **they would provide Plaintiff with a formal education and career advancement if she provided sex to Defendant Epstein and others in the times, places and manners demanded by Defendants. Defendants Groff and [REDACTED]** each also told Plaintiff that **Defendant Epstein would advance Plaintiff’s education and career in order to coerce Plaintiff into sex. Defendant [REDACTED]** told Plaintiff that Epstein had done the same for her career.” *Id.* at ¶ 53 ((1) specifying fraudulent statement; (2) identifying speaker). +- • “In fact, however, these representations were knowingly false, were not acted upon by Defendants, and were made by Defendants Epstein, Groff, [REDACTED], and Maxwell **solely for the purpose of maintaining Plaintiff’s financial dependence on, emotional vulnerability to, and sexual compliance with Defendant Epstein’s demands.** The other Defendants intentionally repeated these representations and intentionally made statements **designed to convince Plaintiff that the representations were true and could be relied upon.** These representations and statements were made to Plaintiff **in furtherance of the sex trafficking venture and enterprise for which they were each employed.”** *Id.* at ¶ 53 ((4) explaining why statements were fraudulent). +- • “All such representations, promises, and threats were made **solely for the purpose of coercing and otherwise inducing Plaintiff into prolonged sexual compliance.** Defendants knowingly benefitted financially and received things of value as a result of coercing and inducing Plaintiff into sexual compliance and otherwise participating in their illegal venture and enterprise.” *Id.* ¶ 66 ((4) explaining why statements were fraudulent). + +Accordingly, [REDACTED] has satisfied the heightened pleading standard for fraud. + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +internal citation omitted). Here, + +has pled Defendants' intent to deceive her and has given the specific reason for why: + +[The representations] ... were not acted upon by Defendants, and were made by Defendants Epstein, Groff, =, and Maxwell solely for the purpose of maintaining Plaintiff's financial dependence on, emotional vulnerability to, and sexual compliance with Defendant Epstein's demands. The other Defendants intentionally repeated these representations and intentionally made statements designed to convince Plaintiff that the representations were true and could be relied upon. These representations and statements were made to Plaintiff in furtherance of the sex trafficking venture and enterprise for which they were each employed. + +See McCawley Decl. at Exhibit I, Am. Compl. at 1 53. This is far more than a naked assertion that Defendants never intended to perform future acts, but it instead shows the specific reason why Defendants had to lie to Accordingly, element of fraud. to maintain her dependence on them for sexual compliance. has successfully pled the existence of the intent not to perform as an + +Under the sex trafficking statute, need only show that Defendants used fraud or coercion in causing to engage in commercial sex acts. See 18 U.S.C. § 1591(a)(2) ("... means of force, threats of force, fraud, coercion ... or any combination of such means will be used to cause the person to engage in a commercial sex act ..."); United States v. Paris, No. CR 03:06-CR-64(CFD), 2007 WL 3124724, at \*12 (D. Conn. Oct. 24, 2007) (collecting cases) ("Force, fraud and coercion are alternate means to accomplish a single element"); United States v. Marcus, 487 F. Supp. 2d 289, 308 (E.D.N.Y. 2007) (describing "force, fraud, or coercion" as single element of § 1591). + +Nevertheless, has pled coercion in her Amended Complaint. The Amended Complaint details how the Defendants coerced her with promises of an education, living quarters, + +and other benefits "in order to coerce her into sexual compliance" and "as an inducement to provide sex." See McCawley Decl. at Exhibit 1 at ¶ 48, 50. It also details how Defendants "threatened retaliation against her if Plaintiff did not perform as demanded" and "threatened Plaintiff with serious harm, as well as serious psychological, financial, and reputational harm, compelling Plaintiff to perform and continue performing the commercial sexual activity demanded by Defendants." Id. at ¶¶ 43, 48, 57. And the Amended Complaint alleges that the Defendants "used possession and control of Plaintiff's passport to induce and coerce Plaintiff into performing sexual acts with Epstein and others." Id. at ¶ 45, see also id. at ¶ 51. And the Amended Complaint alleges that "[d]uring many sexual encounters, Defendant Epstein gave Plaintiff no option, opportunity, or choice not to participate in the prescribed sexual acts." Id. at ¶ 46; see also id. at157 . There can be no doubt that statute. has properly pled coercion as defined by the sex trafficking + +acts and has properly pled a causal link between Defendants' fraudulent and coercive engaging in commercial sex acts. + +Has Properly Pled a Causal Link + +Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind. + +See McCawley Decl. at Exhibit 1 at ¶ 49. In order for to benefit, and continue benefitting from Defendants' services and favors, had to keep providing commercial sex acts to Epstein. the Amended Complaint makes it more than clear that her sex acts were the direct result of fraudulent statements, coercion, and force. + +"The term 'commercial + +sex act' means any sex act, on account of which anything of value is given to or received by any person." 18 U.S.C. § 1591(e)(3). As pled in the Amended Complaint, Defendant Epstein's "sex acts were commercial in nature, because the Defendants promised to provide financial and other compensation to the females in exchange for providing sex acts to Epstein." See McCawley Decl. at Exhibit 1 at 1 20. Defendants' contentions otherwise are unavailing. + +## C. .. Has Successfully Alleged Knowledge Against Defendants Groff and + +As it pertains specifically to Defendants Groff and has pled that Groff and not only had knowledge of Defendants' violations of the sex trafficking statute, but also made fraudulent and coercive promises to commercial sex acts: in order to have her engage in + +- Between October 2006 and May 2007, Defendants Maxwell, , and Groff each also confirmed and reiterated this promise to Plaintiff many times, each telling Plaintiff that Epstein would use his wealth and connections to advance Plaintiffs education. More specifically, each of the Defendants last verified this information that Epstein was using his connections to ensure Plaintiff was admitted into F.I.T. in exchange for Plaintiff's continued sexual cooperation with Epstein in March or April of 2007. See McCawley Decl. at Exhibit 1, Am. Compl. at1 38. +- All Defendants, including Maxwell, Epstein, Groff and knew that Plaintiff was actually being recruited for sexual purposes, and each knowingly and deliberately made false representations to ensure that Plaintiff would cooperate in fulfilling Epstein's sexual desires. Id. at 1 40. +- Defendants Groff and each also told Plaintiff that Defendant Epstein would advance Plaintiffs education and career in order to coerce Plaintiff into sex. Id. at + - 153. +- Defendant Groff monitored Plaintiffs progress in losing weight and continued to communicate with Plaintiff about Plaintiff's application to be admitted into F.I.T. as part of the Defendants' ruse to coerce Plaintiff to return to the United States for sex. Defendant Groff was aware of the coercion Epstein and Maxwell were applying to Plaintiff and acted to help further that coercion. Id. at 1 57. + +- As part of their scheme, Epstein and Groff told Plaintiff that she should fill out an application for admission to F.I.T., and supporting essay, and send it to Epstein for his review. (...) Groff also made the same representations to plaintiff on Epstein's behalf. Plaintiff reasonably relied on these representations by Epstein and Groff. Id. at y 59. + +# D. Has Specifically Alleged Reasonable Reliance + +has specifically pled that she reasonably relied on Defendants' representations that they would help her get into F.I.T. if she complied with their sex trafficking scheme. + +On the contrary, the entire Amended Complaint is brimming with allegations — which must be accepted as true — that explain why she reasonably relied on Defendants' representations. See McCawley Decl. at Exhibit 1, Am. Compl. at ¶ 40 ("Plaintiff reasonably relied on these representations and had a credible basis for such reliance, including the credible representations of Epstein and the other Defendants that they possessed extensive political, business, financial, social, and educational influence and connections."); see also id. at I 61. + +Epstein and his cohorts are wealthy and powerful, both in how they present themselves and how they actually operate. See McCawley Decl. at Exhibit 1 at TI 11, 12, 16, 22, 36-38, 40. II + +has pled how they portrayed themselves as having the means both to get her into her dream school and make sure that she never gets in, contingent on her cooperation with their sex trafficking scheme. Defendant's contention that this is not reasonable is unpersuasive — powerful, wealthy men like Epstein have tremendous ability to accomplish what they desire using their power and wealth. Accordingly, properly pled. allegations concerning reasonable reliance are + +#### E. Has Successfully Alleged Predicate Acts and Violation of Sections 1592, 1593A, and I594(a)-(c) + +was subjected to. It is hard to imagine circumstances more different from those that + +In addition to pleading violations under Section 1591, has also successfully pled violations of Sections 1592, 1593A, and 1594(a)-(c) of the sex trafficking statute in her Amended Complaint. She has pled: (1) that Defendants took her passport in order to coerce into performing commercial sex acts (1592); (2) that Defendants received value in the form of financial benefits from their knowing violations of 1592 and 1595(a) (1593); (3) that Defendants attempt to violate 1591 (1594(a)); (4) that Defendants conspired to violate 1592 (1594(b)); and (5) that Defendants conspired to violate 1591 (1594(c)). + +For Section 1592, pled facts alleging that Defendants Epstein, Maxwell, and both individually and together, took possession of her passport, in Paragraphs 45, 49, 54, and 69. Specifically: + +- The Defendants Epstein, Maxwell, and used possession and control of Plaintiff's passport to induce and coerce Plaintiff into performing sexual acts with Epstein and others. See McCawley Decl. at Exhibit 1, Am. Compl. at 145. +- On one occasion, after suffering verbal abuse and threats by Defendants Epstein, Maxwell, and Plaintiff attempted to escape from Defendant Epstein's private island. A search party led by Defendants Epstein and Maxwell located her and physically returned her to the main house on the island. Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind. Defendants further used possession and control of Plaintiff's passport, without lawful consent or authority, to restrict Plaintiff's liberty and thereby force her to provide sex to Epstein. Id. at 1 49. +- As part of the venture and enterprise, Defendants Epstein, Maxwell, and took possession of Plaintiff's passport when she was being trafficked by them, including when she travelled to Epstein's island in the U.S. Virgin Islands. The Defendants took possession of Plaintiff's passport in the course of sexually trafficking Plaintiff and with the intent to violate laws against sex trafficking, including 18 U.S.C. 1591 et. seq. The Defendants used their control of Plaintiff's passport in order to coerce compliance with their demands, including their demands that Plaintiff have sex with Epstein and others. Id. at 1 54. + +For Section I593A, pled facts alleging that all Defendants benefited financially from participating in the sex trafficking venture. See McCawley Decl. at Exhibit 1, Am. Compl. at 70. + +But the Defendants overlook the tact that the provision pertains not only to engaging in the underlying sexual events, but to retaining financial benefits. Thus, the statute provides that "[w]hoever knowingly benefits, financially or by receiving anything of value, from participation" in an illegal venture of the type at issue here has violated the applicable criminal chapter. The Amended Complaint alleges that the Defendants obtained financial and other benefits from their illegal enterprise "up to the present in some form or another." See McCawley Decl. at Exhibit 1 at 1 23; see also id. at 1[1 18, 30, 32, 66, 70 (all + +alleging benefits to Defendants). As an illustration, until the Defendants divest themselves of the gains from their illegal enterprise, they remain in violation of the law. Such allegations are all that is required to survive a motion to dismiss. + +The Defendants also fail to recognize that violations of Section I 593A are civilly actionable by operation of 18 U.S.C. § 1595. + +And, for Sections 1594(a)-(c), pled facts alleging that all Defendants attempted to traffic , and conspired to traffic her. For example, allegations of conspiracy are repeated throughout the Amended Complaint. See McCawley Decl. at Exhibit I at 11 10, 11, 19, 72, 73. In addition, has alleged that it was part of the criminal enterprise for the Defendants to take the passports of young females to coerce compliance with their sexual demands (Id. at ¶ 18) and that "Defendants Epstein, Maxwell, and used possession and control of Plaintiff's passport to induce and coerce Plaintiff into performing sexual acts with others"(Id.at1 45). And in addition, has alleged that "Defendant Epstein's wealth, influence, power and connections were used by Defendants Maxwell, and Groff, both as an inducement to provide sex (in exchange for promises of support to Plaintiff) and as a means of threatening punishment (in the event Plaintiff refused to comply with Defendants' instructions to provide sex to Epstein and others)." Id. at ¶ 50. For all these reasons — as well as the reasons explained above — has clearly stated a violation of Section 1594(a)-(c). + +# F. The Amended Complaint Meets the TwomblyllqbalPlcading Standards + +'To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to 'state a claim to relief that is plausible on its face."' Ashcroft v. lqbal, 556 U.S. 662, 678, 129 S. Q. 1937, 173 L Ed.2d 868 (2009) (quoting Bell Ad. Corp. v. Twombly, 550 U.S. 544, 570, 127 S. Ct. 1955, 167 L. Ed.2d 929 (2007)); Heskiaoff v. Sling Media. Inc., No. 17- 1094-CV, 2017 WL 5632078, at \*2 (2d Cir. Nov. 22, 2017) (Koeltl, J.). + +For all the foregoing reasons in this section, Amended Complaint clearly meets the basic pleading requirements from Twomblyllqbal because every allegation she has pled is "plausible on its face." She has sufficiently alleged facts to show that each of the Defendants has engaged in sex trafficking under the statute. + +Furthermore, the Amended Complaint does not engage in any improper "group pleading." The Amended Complaint clearly states which Defendants engaged in which acts: + +- "...Natalya was working to recruit young females for Epstein for sex when she approached and recruited Plaintiff." See McCawley Decl. at Exhibit I, Am. Compl. at 135. +- "Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology (known as "F.I.T.") in New York City or into a similar institute of higher learning offering a curriculum of fashion industry training." Id. at 1 38. +- "Defendant Maxwell told Plaintiff she would need to provide Defendant Epstein with body massages in order to reap the benefits of his and Maxwell's connections." Id. at + - 39. +- "Defendants Groff and each also told Plaintiff that Defendant Epstein would advance Plaintiffs education and career in order to coerce Plaintiff into sex. Defendant told Plaintiff that Epstein had done the same for her career." Id. at1 53. +- "...Defendants Epstein, Maxwell, and took possession of Plaintiff's passport when she was being trafficked by them, including when she travelled to Epstein's island in the U.S. Virgin Islands." Id. at 1 54. +- "Defendant Groff was aware of the coercion Epstein and Maxwell were applying to Plaintiff and acted to help further that coercion." Id. at157. + +The language of the Amended Complaint is clear: each and all of the Defendants committed violations of the sex trafficking statute against "Prior to discovery, plaintiff need + +not explain the details of each defendant's role in the planning, funding, and executing defendants' alleged joint telemarketing scheme. Nothing in Rule 8 prohibits collectively referring to multiple defendants where the complaint alerts defendants that identical claims are asserted against each defendant." *Hudak v. Berkley Grp., Inc.*, No. 3:13-CV-00089-WWE, 2014 WL 354676, at \*4 (D. Conn. Jan. 23, 2014); *see also Tardibuono-Quigley v. HSBC Mortg. Corp. (USA)*, No. 15-CV-6940 (KMK), 2017 WL 1216925, at \*8 (S.D.N.Y. Mar. 30, 2017) ("The Amended Complaint, although stating that the allegations pertain to 'Defendants' or 'Mortgage Defendants,' provides enough information to put PHH on notice of its alleged role in servicing Plaintiff's mortgage."); *c.f. Precision Assocs., Inc. v. Panalpina World Transp., (Holding) Ltd.*, No. CV-08-42 JG VVP, 2013 WL 6481195, at \*12 (E.D.N.Y. Sept. 20, 2013), report and recommendation adopted, No. 08-CV-00042 JG VVP, 2014 WL 298594 (E.D.N.Y. Jan. 28, 2014). + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED]. None of the Epstein Defendants, including [REDACTED], can claim that they are not on notice for the claims asserted against them. + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] Her Amended Complaint, which is at issue for purposes of the motions to dismiss, clearly and plainly articulates her claim for damages. + +[REDACTED] + +[REDACTED] + +**III. [REDACTED] CLAIM IS WELL WITHIN THE STATUTE OF LIMITATIONS** + +[REDACTED] claim is unquestionably within the statute of limitations, [REDACTED] + +[REDACTED] + +[REDACTED] claim was still “live” in 2008 when the 2008 statutory amendment was enacted extending the statute of limitations period to ten years. Under Second Circuit case law, *see, e.g., In re Enterprise Mortgage Acceptance Co., LLC Sec. Litig.*, 391 F.3d 401, 405-06 (2d Cir. 2004), this is sufficient to permit an extension of the statute of limitations. Indeed, a district court within this Circuit has specifically reached precisely this conclusion with regard to the statutory scheme at issue here. *See Lama v. Malik*, 192 F. Supp. 3d 313, 320-24 (E.D.N.Y. 2016) (court applying ten-year limitations period under 18 U.S.C. § 1595, even though conduct occurred before 2008 amendment, because plaintiff’s claim was still “live” in 2008). Accordingly, the ten-year statute of limitations applies here, not the four-year limit. [REDACTED] + +[REDACTED] + +[REDACTED] claim is well within the ten-year statute of limitations, as very specifically alleged within the Amended Complaint. For example, the Amended Complaint specifically alleges that “each of the Defendants last verified this information that Epstein was using his connections to ensure Plaintiff was admitted into F.I.T. in exchange for Plaintiff’s continued sexual + +cooperation with Epstein in March or April of 2007." See McCawley Decl. at Exhibit 1, Am. Compl. at 138. And the Complaint further alleges that, in February 2007, "in reliance on promises made by the Defendants, Plaintiff returned to New York City, in the Southern District of New York, and was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants Maxwell, =, Groff, and Epstein each fraudulently promised Plaintiff again that her sexual compliance would be rewarded with admission to F.I.T. or a comparable college, a promise which they each knew to be false." Id. at1 61. And finally, the Complaint also alleges an on-going cover-up of the criminal enterprise that occurred "[lin and after May 2007." Id. at 165. Because filed her complaint on January 26, 2017, any one of these allegations of actions by the conspirators during February to May (and even later) in 2007 are alone is sufficient to satisfy the ten-year statute of limitations. + +It is, of course, well-settled law that, in deciding a motion to dismiss, "the Court must limit its analysis to the four corners of the complaint." Geldzahler v. New York Med. Colt, 663 F. Supp. 2d 379, 386 (S.D.N.Y. 2009) (citing Vassilatos v. Ceram Tech Ina, Ltd., 92 Civ. 4574, 1993 + +WL 177780 at \*5 (S.D.N.Y. May 19, 1993) (citing *Kopec v. Coughlin*, 922 F.2d 152, 154–55 (2d Cir.1991)).3 + +[REDACTED] + +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[REDACTED] +[REDACTED] + +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] + +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +3 The Court may also consider documents attached to complaint or incorporated in the complaint by reference. *Geldzahler*, 663 F. Supp. 2d at 386. Those circumstances are not at issue here. + +[Redacted text block] + +[Redacted text block] + +[Redacted text block] + +[Redacted text block] + +[Redacted text block] + +First, [Redacted] specifically alleges in her Amended Complaint that she was subject to abuse by the Defendants until she left the United States in May 2017. For example, she has specifically alleged that “each of the Defendants last verified this information that Epstein was using his connections to ensure Plaintiff was admitted into F.I.T. *in exchange for Plaintiff’s continued sexual cooperation with Epstein in March or April or 2007.*” See McCawley Decl. at Exhibit 1, Am. Compl. at ¶ 38 (emphasis added). Her complaint plainly alleges conduct that occurred during the statute of limitations period ten years before the filing of her complaint on January 26, 2007 – which is all that this Court needs to review in ruling on a motion to dismiss. + +See McCawley Decl. at Exhibit I, Am. Compl. at 15. has clearly alleged sufficient facts to satisfy her statute of limitations obligations. + +#### IV. THIS COURT HAS JURISDICTION OVER THE DEFENDANTS + +This Court properly has jurisdiction over all of the Epstein Defendants, + +. As pled in the Amended Complaint. Epstein has a 51,000 square foot mansion located at 9 East 71st Street, New York, NY, in the Southern District of New York, during the relevant time periods in the complaint, and used this residence "to facilitate the illegal sex trafficking venture and enterprise described in this Complaint and in furtherance of the venture and enterprise." Id. at 1 12. Plaintiff also pled that the Defendants' trafficking conduct occurred in New York. Id. at 9¶'p 20, 28, 45, 52, 55, 60, 61, 63, 76. This trafficking conduct is specifically alleged to have occurred in New York City, within the Southern District of New York, after January 2007. Id. at 1 61. Further, while pleading residence is sufficient by itself to establish jurisdiction, it is also noteworthy that Epstein has numerous businesses, corporations, and other contacts in the Southern District of New York, including: + +- Epstein Interests, 575 Lexington Avenue, New York, NY 10022 +- Epstein Interests, 457 Madison Avenue, New York, NY 10022 +- Guardian Life, 355 Lexington Ave Floor II, New York, NY 10017 +- J Epstein Foundation, 457 Madison Avenue, New York, NY 10022 +- Milstein Properties, 201 E. 87th Street # 7C, New York, NY 10128 +- NES LLC, 9 E. 71" Street, New York, NY 10021 +- New York Strategy Group LLC, 457 Madison Avenue, New York NY 10022 +- New York Strategy Group LLC 401K Plan, 457 Madison Avenue Floor 7, New York, NY 10022 + +- Nine East 71' Street Corporation, 575 Lexington Avenue, New York, NY 100224 + +Further, Defendant has connections to the addresses of 457 Madison Avenue, New York, NY 10022. She also has a residence at 301 E. 66th Street, Apt. 10B, New York, NY 10065. This New York connection is alleged in the Amended Complaint. See McCawley Decl. at Exhibit I, Am. Compl. at ¶ 6 ("At all times material to this cause of action was a United States citizen, residing in New York, New York (within the Southern District of New York)."). + +And further, Defendant Groff has connections to New York — properly alleged in the Amended Complaint. Id. at ¶ 8 ("At all times material to this cause of action Leslie Groff was a United States citizen, residing in New York, New York (within the Southern District of New York)."). Groff was actively employed by Epstein during the period that was being trafficked and is believed to still be employed by Defendant Epstein. + +And Defendant Maxwell had a residence in New York for years before selling it in 2016. At all times material to the present case, Maxwell was living in New York and Maxwell's business, the Terra Mar Project, has its address in New York. And it is believed Maxwell still resides in New York. Although she has refused to provide her address. The Court is, of course, familiar with the difficulty in locating the elusive and peripatetic Ms. Maxwell from prior litigation associated with serving her with the Complaint in this case. But, for present purposes, it is enough to note that that the Amended Complaint alleged that "[a]t all times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York." See McCawley Decl. at Exhibit 1 at 1 6. + +4 Plaintiff also maintains that a brief jurisdictional deposition of Epstein would establish both jurisdiction and venue, as explained in further detail infra. + +Jurisdiction is plainly proper. + +# V. VENUE IS PROPERLY LAID IN THE SOUTHERN DISTRICT OF NEW YORK + +Venue is also properly laid in the Southern District of New York because a substantial part of the acts, events, and omissions giving rise to this cause of action occurred in this District. Id. at 1 9. As pled in the Amended Complaint and referenced above, Epstein had a residence in the Southern District of New York during the relevant time periods in the complaint. He used this residence "to facilitate the illegal sex trafficking venture and enterprise described in this Amended Complaint and in furtherance of the venture and enterprise." Id. at 1 12. Plaintiff also pled that the Defendants' trafficking conduct occurred in New York City, revolving around this residence. See McCawley Decl. at Exhibit 1 at fl 20, 28, 45, 52, 55, 60, 61, 63, 76. This trafficking conduct is specifically alleged to have occurred in New York City, within the Southern District of New York, after January 2007. Id. at 1 61. Venue is plainly proper — a fact that is underscore by Defendants' notable silence as to which judicial district they believe is a more appropriate venue. + +#### VI. THE COURT SHOULD IGNORE MATERIAL OUTSIDE THE COMPLAINT IN RULING ON THE MOTION TO DISMISS + +While the foregoing arguments make clear that the motion to dismiss borders on frivolous, specifically objects to all of the material outside of the Complaint to which Epstein refers.5 As counsel for the Epstein Defendants must well know, a motion to dismiss must be + +Should the Court decide not to consider material outside of the Complaint in deciding on the motions to dismiss, the Court is, of course, free to treat Plaintiff's use of the materials in the same way as the Defendants. would also request the opportunity to + +5 + +determined based on the allegations of the complaint – not other cherry-picked materials and unproved, disputed facts that the Defendants believe are useful to their case. *See, e.g., In re Giant Interactive Grp., Inc. Sec. Litig.*, 643 F. Supp. 2d 562, 573 (S.D.N.Y. 2009) (court not considering evidence outside of complaint in deciding motion to dismiss, denying motion) (“[T]he evidence advanced by Defendants is not within the four corners of the Complaint, and cannot be considered here.” (citing *Fonte v. Bd. of Managers of Cont’l Towers Condo.*, 848 F.2d 24, 25 (2d Cir. 1988)); *Bill Diodato Photography LLC v. Avon Prod., Inc.*, No. 12 CIV. 847 RWS, 2012 WL 3240428, at \*4 (S.D.N.Y. Aug. 7, 2012), on reconsideration, No. 12 CIV. 847 RWS, 2012 WL 4335164 (S.D.N.Y. Sept. 21, 2012) (“A Rule 12(b)(6) motion to dismiss challenges only the face of the pleading. Thus, in deciding such a motion to dismiss, ‘the Court must limit its analysis to the four corners of the complaint.’” (internal citations omitted)). Accordingly, the Court should not consider the outside-the-complaint materials, specifically the testimony and documents from the [REDACTED] v. *Maxwell* case. [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +**VII. IF NECESSARY, [REDACTED] ALSO RENEWS HER REQUEST FOR JURISDICTIONAL DISCOVERY** + +[REDACTED] also wishes the record to be clear that, before the Court even considers granting the motion to dismiss, she would be entitled to jurisdictional discovery for the reasons articulated in her November 29, 2017, letter motion to the Court. While the Court has indicated it + +--- + +submit additional evidence including, but not limited to, an affidavit if the Court is going to look beyond the four corners of the Amended Complaint. + +will determine the appropriate time for discovery to be conducted in this case, it remains readily apparent that even a one-hour telephonic deposition of Epstein will immediate make clear that this lawsuit is well-founded in all regards, including jurisdiction. + +So that the record is clear, once again proffers questions that she would ask as such a deposition and the anticipated answers she would receive from Epstein: + +| QUESTION | ANTICIPATED ANSWER | +|--------------------------------------------|----------------------------------------| +| Did you use your residence in the Southern | Either "yes" or invocation of Fifth | +| District of New York to coerce | Amendment. | +| Did you make threats to | to Either "yes" or invocation of Fifth | +| coerce her into have sex with you in your | Amendment. | +| things to | in order to obtain sex | +| representations to | after January | +| representations you made to | to | + +Of course, because Epstein will have an opportunity to reply to this response, he can state on the record whether any of the anticipated answers that would be given at the deposition are in any way incorrect. And, of course, all of these anticipated answers make clear that this lawsuit will succeed once the Court denies the motion to dismiss. + +#### CONCLUSION + +For all the foregoing reasons, the Court should den> Defendants' Motions to Dismiss in their entireties. + +Dated: February 26, 2018 + +Respectfully submitted, + +BOLES SCHILLER FLEXNER LLP + +/s/ Sigrid McCawley + +Sigrid S. McCawley (Admitted Pro Hac Vice) + +Meredith (Admitted Pro Hac Vice) + +Boies Schiller Flexner LLP + +401 E. Las Olas Blvd., Suite 1200 + +Ft. Lauderdale, FL 33301 + +(954) 356-0011 + +J. Esq. (Admitted Pro Hac Vice) + +Stanley Pottinger, Esq. + +POTT1NGER LLC + +425 North Andrews Avenue, Suite 2 + +Fort Lauderdale, Florida 33301 + +Tel: (954) 524-2820 + +Paul G. Cassell (Admitted Pro Hac Vice) + +S.J. Quinney College of Law + +University of Utah + +383 University St. + +Salt Lake City, UT 84112 + +(801) 585-52026 + +6 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. + +#### CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on February 26, 2018, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. + +Kimo S. Peluso Sher Tremonte, LLP 90Broad Street, 23rd Floor New York, NY 10004 k eluso@shertremonte.com Counsel for Haddon, P.C. + +Laura A. Menninger, Esq. Jeffrey Pagliuc E . HADDON, & 150 East 10th Avenue Denver, Colorado 80203 Email: Imenninger@hrnflaw.com jpagliuca@hmflaw.com + +John E. Stephenson, Jr. Jonathan D. Parente ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, GA 30309 John.stephenson@alston.com Jonathan.parente@alston.com + +Alexander S. Lorenzo ALSTON & BIRD LLP 90 Park Avenue New York, NY 10016 alexander.lorenzo@alston.com Counsel for Defendant + +Michael Justin Michael A. Keou h , P.C. STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 truniller@steptoe.com jchu@steptoe.com Counsel for Defendants, Jeffrey Epstein and Lesley Groff + +/s Sigrid McCawley Sigrid McCawley \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820095/EFTA02820095.metadata.json b/marker2/court-jane-doe-43/EFTA02820095/EFTA02820095.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..375886d34d9ff05635644c47e9d459fe9a280356 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820095/EFTA02820095.metadata.json @@ -0,0 +1,2010 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820095.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 38, + "chars": 60200, + "elapsed_seconds": 12.85, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 72.9 + ], + [ + 293.59381103515625, + 72.9 + ], + [ + 293.59381103515625, + 103.863037109375 + ], + [ + 68.544, + 103.863037109375 + ] + ] + }, + { + "title": "PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO \nDEFENDANTS' MOTIONS TO DISMISS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 133.416, + 353.96999999999997 + ], + [ + 478.9478454589844, + 353.96999999999997 + ], + [ + 478.9478454589844, + 385.4830322265625 + ], + [ + 133.416, + 385.4830322265625 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 238.06800000000004, + 71.28 + ], + [ + 374.5343933105469, + 71.28 + ], + [ + 374.5343933105469, + 86.2330322265625 + ], + [ + 238.06800000000004, + 86.2330322265625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 228.88800000000003, + 71.28 + ], + [ + 383.5578918457031, + 71.28 + ], + [ + 383.5578918457031, + 86.2330322265625 + ], + [ + 228.88800000000003, + 86.2330322265625 + ] + ] + }, + { + "title": "Statutes", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 67.932, + 71.28 + ], + [ + 116.73501586914062, + 71.28 + ], + [ + 116.73501586914062, + 86.103515625 + ], + [ + 67.932, + 86.103515625 + ] + ] + }, + { + "title": "Rules", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 67.932, + 200.07 + ], + [ + 104.17778015136719, + 200.07 + ], + [ + 104.17778015136719, + 215.103515625 + ], + [ + 67.932, + 215.103515625 + ] + ] + }, + { + "title": "INTRODUCTION", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 255.204, + 126.35999999999999 + ], + [ + 356.9389343261719, + 126.35999999999999 + ], + [ + 356.9389343261719, + 141.363037109375 + ], + [ + 255.204, + 141.363037109375 + ] + ] + }, + { + "title": "BACKGROUND", + "heading_level": null, + "page_id": 8, + "polygon": [ + [ + 259.488, + 208.98 + ], + [ + 353.0194091796875, + 208.98 + ], + [ + 353.0194091796875, + 224.2330322265625 + ], + [ + 259.488, + 224.2330322265625 + ] + ] + }, + { + "title": "ARGUMENT", + "heading_level": null, + "page_id": 10, + "polygon": [ + [ + 267.44399999999996, + 182.25 + ], + [ + 344.61444091796875, + 182.25 + ], + [ + 344.61444091796875, + 196.4830322265625 + ], + [ + 267.44399999999996, + 196.4830322265625 + ] + ] + }, + { + "title": "I. 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b/marker2/court-jane-doe-43/EFTA02820133/EFTA02820133.md new file mode 100644 index 0000000000000000000000000000000000000000..3a46260dbdf7874e4f86f5dffaa1e3105e9c06bb --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820133/EFTA02820133.md @@ -0,0 +1,232 @@ +# EXHIBIT 1 + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +CASE NO.: 1:17-CV-00616 + +JANE DOE 43, + +Plaintiff, + +VS. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL LESLEY GROFF, AND NATALYA + +Defendants. + +### FIRST AMENDED COMPLAINT + +Plaintiff JANE DOE 43, by and through her undersigned counsel, for her claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, Lesley Groff, and Natalya , alleges upon personal knowledge with respect to her own acts and status, and upon personal knowledge, information and belief as to all other matters, as follows: + +- 1. This cause of action arises under federal statutes and jurisdiction is proper under 28 U.S.C. section 1331. +- 2. Plaintiff files this Complaint under a pseudonym in order to protect her identity because this Complaint makes allegations of a sensitive sexual nature the disclosure of which, in association with her name, would cause further harm to her. + +3. At all times material to the events alleged in this cause of action the Plaintiff was a citizen of South Africa residing in New York, New York. + +4. At all times material to this cause of action Defendant Jeffrey Epstein had multiple residences, including in New York, New York (within the Southern District of New York) and the United States Virgin Islands. He is currently a citizen of the United States and claims to be a resident of the U.S. Virgin Islands. + +5. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in 1953. + +6. At all times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York and was a citizen of Great Britain and France. + +7. At all times material to this cause of action was a United States citizen, residing in New York, New York (within the Southern District of New York). + +8. At all times material to this cause of action Lesley Groff was a United States citizen, employed by New York based company and regularly conducting business in New York, New York (within the Southern District of New York). + +9. A substantial part of the acts, events, and omissions giving rise to this cause of action occurred in the Southern District of New York; venue is proper in that District. 28 U.S.C. section 1391(b)(2) + +10. At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, and Lesley Groff owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional, criminal, fraudulent, or tortious acts against her, including any acts in violation of 18 U.S.C. §1595. + +# FACTUAL ALLEGATIONS + +11. At all times material to this cause of action, Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is widely recognized as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes and to employ and conspire with a group of numerous others, including each of the named Defendants, to assist in committing those crimes and additional torts as well as to conceal the crimes and torts of the Epstein sex trafficking group from being discovered. + +12. Defendant Epstein displays his enormous wealth, power and influence to his employees; to the victims procured for sexual purposes; and to the public in order to advance and carry out his crimes and torts. At all relevant times, Defendant Epstein owned and continues to own, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats and one or more helicopters. For example, he owned (directly or indirectly) a Boeing aircraft (of make and model B-727-31H with tail number N908JE) and a Gulfstream aircraft (of make and model G-1159B with tail number N909JE). He also owned numerous properties and homes, including a 51,000-square-foot mansion in Manhattan; a \$30 Million, 7,500-acre ranch in New Mexico; a 70-acre private island formerly known as Little St. James in or near St. M, U.S. Virgin Islands; a home in Paris, France; and a mansion in Palm Beach County, Florida. The allegations herein primarily concern the defendant's conduct while at his townhouse in New York; on one or more of his private airplanes; and on his private island in the United States Virgin Islands. Epstein used all of the real and personal property described in this paragraph to facilitate the illegal sex trafficking venture and enterprise described in this Complaint and in furtherance of that venture and enterprise. + +13. Defendant Epstein has a compulsive sexual preference for young females as young as 13 and as "old" as 25. Through information and belief Defendant Epstein engages in sexual acts with this age range every day and developed, through the employment of and conspiracy with the other Defendants, a sex trafficking venture and enterprise designed to fulfill his sexual desires and conceal the operation of the venture and enterprise and conduct of its participants. As part of the venture and enterprise, Epstein also provided young females for sexual purposes to his friends in order to secure social, business, and other contacts as well as other things of value. + +14. Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise. She herself recruited young, including underage, females; oversaw and trained other recruiters on how best to recruit girls for sex; developed and executed schemes designed to recruit young females; and ensured that all participants of the Defendants' sex trafficking scheme acted in certain specific ways in order to advance the purposes of the scheme, including providing young females to Epstein for sexual purposes on a daily basis, and concealing these activities from law enforcement. + +15. Defendant recruited young females for Epstein for sexual purposes, brought gifts to females in order to entice those females to commit sex acts with Epstein and to assist in concealing the illegal sexual conduct of the venture and enterprise, and maintained Epstein's sex schedule in order to ensure that he was not without young females for any extended period of time. Defendant also handled travel arrangements for various females being exploited for sexual purposes. Defendant was an integral part of the sex trafficking venture and enterprise and reported directly up the enterprise's line of authority to Defendants Maxwell and Epstein. + +16. Defendant Epstein employed many recruiters of young females. The nature of the Defendants' sex trafficking venture and enterprise enabled victims themselves to elevate their status to that of a paid recruiter of other victims. Recruiters were taught by Defendants Epstein, Maxwell and to inform targeted victims that Epstein possessed extraordinary wealth, power, resources and influence; that he was a philanthropist who would help female victims advance their careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact, however, these representations were fraudulent. The young females were actually required to perform intimate sexual acts at the Defendants' direction and the Defendants did not help nor intend to help advance the victims' careers. Victims were also paid to bring Epstein other young females for sex and were told by Defendants Epstein, Maxwell, and that those young females who brought other females would further benefit from bringing other girls. + +17. Defendant Groff was an integral part of the illegal venture and enterprise. Groff coordinated schedules between Defendant Epstein and the various young females used for sex; made travel arrangements for the young females; tended to the living needs of those females; communicated and coordinated with Defendants Epstein, Maxwell and to assist in facilitating young females being available in locations where the other Defendants were traveling; and she carried messages to the young females from the other Defendants including false representations in order to maintain the young females' compliance with the rules of sexual compliance imposed by this structured sex-trafficking group. Groff was aware of the activities of the venture and enterprise, including the fraudulent representations and other coercion that was being applied to secure the females' compliance with demands of sex. + +18. The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein's compulsive need for sex with young females by preying on their personal, psychological, financial, and related vulnerabilities. The Defendants' tactics included promising the victims money, shelter, transportation, gifts, employment, admission into educational institutions, educational tuition, protection, and other things of value in exchange for sex. Defendants also took possession of the victims' passports to coerce compliance with their demands. Defendants also trafficked young females to Epstein's friends and acquaintances in order to secure financial and other benefits as well as social, educational, and business connections. + +19. Defendants' sex trafficking venture and enterprise operated in a hierarchal structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top. Defendants Epstein and Maxwell operated the sex trafficking scheme dating back to at least the mid-nineties, and over the years perfected their roles and the roles of others, both in terms of the ability to increase the volume of young females recruited for sex and in insulating the enterprise from criminal investigation or prosecution. Defendant Groff conspired with Defendant Epstein and Maxwell since at least 2002 and continues to work for Defendant Epstein today. Defendant began working with the Epstein-run sex trafficking venture and enterprise as early as 2001 and her role in their venture and enterprise was well-defined and primarily consisted of conspiring in the commission and cover-up of sex crimes. Underlings included the other named Defendants as well as unnamed coconspirators such as various housekeepers and butlers; an airplane pilot; and various employees, assistants and associates. Wittingly and unwittingly, such underlings performed their respective roles with the purpose and effect of insuring that the enterprise supplied young females to Defendant Epstein and others for sexual purposes. At all times materials to this complaint, the venture and enterprise was a group of two or more individuals associated in fact and deed. + +20. Defendants Epstein and Maxwell, with help from assistants, associates and underlings, recruited and procured hundreds of girls over the decades of the operation of their scheme. Such recruitment and procurement included fraud, coercion, threats, intimidation, fear, the threat of coercion, and a combination of these and similar tactics. Following the Defendants' recruitment and procurement of the young females to join Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent promises, coercion, and threats of coercion in order to entice and coerce the females into sex and, once sexual activities ensued, to cause them to remain in the enterprise. The Defendants also transported females in + +interstate and foreign commerce and in ways that affected interstate and foreign commerce. The sex acts were commercial in nature, because the Defendants promised to provide financial and other compensation to the females in exchange for providing sex acts to Epstein. + +21. Defendants specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females to provide sex for Epstein. + +22. Additionally, Defendants always made clear to every young female that they were wealthy, well-connected and could either help or hurt the females depending on their degree of cooperation. In fact, Defendants Epstein and Maxwell have been known to threaten young females with physical harm. It is unknown exactly how long the Defendants' criminal and illegal venture and enterprise operated, although it was at least continuously and actively in operation from the mid-1990's through and including the calendar year 2007. + +23. Defendant Epstein has continued the venture and enterprise up to the present time in some form or another and with additional co-conspirators and participants. + +24. In 2005, Defendant Epstein and numerous co-conspirators within the venture and enterprise were the subjects of a Palm Beach, Florida Police Department criminal investigation which revealed that Defendant Epstein had engaged in sexual activities with dozens of young teenage school children. Each child identified in that particular investigation was lured into Defendant Epstein's Palm Beach mansion with a promise that she would receive money for providing him with a body massage, although once there, each young female was made to engage in sexual acts in order to receive the promised compensation. Several were also made to engage in sex with another of Defendant Epstein's female traveling sex companions who Epstein referred to as his lesbian sex slave and bragged about purchasing her from her family when she herself was underage. + +25. In 2006, the Palm Beach Police Department investigation was turned over to the FBI and the United States Attorney's Office for the Southern District of Florida. The United States Attorney's Office investigated Defendant Epstein and his co-conspirators for their violations of numerous federal statutes, including 18 U.S.C. Section 1591, one of the statutory bases for this complaint. + +26. The United States Attorney's investigation continued from 2006 through September 2007, at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office deferring federal prosecution of Defendant Epstein and his numerous co-conspirators, including Defendants and Groff, each named by the Federal Government as coconspirators, for identified federal sex crimes against more than 30 minors. + +27. From late 2006 through September 2007, Epstein's team of lawyers negotiated with the federal government in an effort to avoid a fifty-three-page Federal felony indictment from being filed against Epstein. During these negotiations, Defendant Epstein decamped from Palm Beach to New York and the U.S. Virgin Islands in order to convey an image to prosecutors that he and his coconspirators had stopped committing sex crimes. + +28. Remarkably, however—as this case will highlight—Defendant Epstein and his co-Defendants, including the other defendants named herein, did not abandon their sex trafficking venture and enterprise even while they were under state and federal investigation for crimes committed in violation of 18 U.S.C. section 1591, among other laws, and even as Defendants and their attorneys were busy arguing Epstein's innocence and publicly defaming his victims as liars. Rather, Defendants merely changed their location. Instead of targeting local Palm Beach Florida school girls, the Defendants transported young females from other places in the U.S. (including the Southern District of New York) and abroad and brought them to Defendant Epstein's mansion in New York City and his private island in the Virgin Islands. + +29. In June of 2008, Epstein pleaded guilty to Florida state felony sex offenses for procuring a minor for prostitution and soliciting prostitution by minors and registered as a Sex Offender for Life. + +30. Defendants Epstein and Maxwell developed and implemented a sophisticated system designed to insulate them from criminal and civil liability by protecting them from potential testimony of knowledgeable subordinates. Defendants and Groff adapted to the system and also carried it out for years in exchange for significant pay, benefits, and protection from prosecution. The system included requiring subordinates to sign confidentiality agreements barring disclosure of criminal activity; maintaining records of underage females who were abused by Epstein; requiring subordinates and victims to refrain from speaking with law enforcement officials; requiring them to notify Defendant Epstein's lawyers in the event they (subordinates and victims) were contacted by law enforcement officials; requiring them to accept the representation of attorneys paid for by Defendant Epstein; requiring them to invoke the Fifth Amendment in response to questions they might be asked by investigators and prosecutors; requiring them to invoke the Fifth Amendment in order to refuse to turn over incriminating and non-incriminating evidence to law enforcement officers; requiring them to destroy evidence or refuse to reveal knowledge of destroyed evidence; and requiring them generally to refuse all cooperation with law enforcement officials or investigations. + +31. In 2005, Defendant Epstein and other co-conspirators, aware that law enforcement officials were preparing imminently to execute a search warrant for his home, removed computer systems that logged information about Epstein and his co-conspirators' illegal and criminal conduct; the identities of witnesses; nude photographs of young females; scheduling books; message pads; tangible items such as vibrators and toys; and other incriminating matter. + +32. The sex recruiting and trafficking venture and enterprise designed to procure young females for sexual purposes and to conceal those activities was developed and fine-tuned over time, and each of the named Defendants had a well-defined role and improved in his/her role over time, with practice and experience. By the time Plaintiff was recruited into victimization, each Defendant had years of experience perfecting methods of coercion, understanding Epstein's requirements, and becoming more loyal to the continuance and survival of the venture and enterprise. All of the Defendant's knew about the activities of the venture and enterprise and worked in concert for the goals of the venture and knowingly benefitted, financially and by receiving things of value, from their participation in the venture and enterprise. + +33. A typical way the Defendants procured young females for sex with Defendant Epstein was to make false promises of a modeling opportunity, offer a better life, offer payment for a formal education, or offer other money or consideration. + +34. Beginning in approximately October 2006 and continuing through April 2007, Defendants recruited Plaintiff into their sexual enterprise by fraudulently promising to use their connections and resources to secure her admission to an institution of higher education at the expense of Defendant Epstein. + +35. One of the enterprise's many recruiters, Natalya was working to recruit young females for Epstein for sex when she approached and recruited Plaintiff. + +36. informed Plaintiff that she would introduce Plaintiff to Defendant Epstein, whom she described as a wealthy philanthropist who regularly used his wealth, influence and connections to help financially poor females like Plaintiff achieve their personal and professional goals and aspirations. + +37. reported to her superiors, Defendants , Groff and Maxwell, and was paid for her recruitment of young females, including Plaintiff. + +38. introduced Plaintiff to Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology (known as "F.I.T.") in New York City or into a similar institute of higher learning offering a curriculum of fashion industry training. Between October 2006 and May 2007, Defendants Maxwell, , and Groff each also confirmed and reiterated this promise to Plaintiff many times, each telling Plaintiff that Epstein would use his wealth and connections to advance Plaintiff's education. More specifically, each of the Defendants last verified this information that Epstein was using his connections to ensure Plaintiff was admitted into F.I.T. in exchange for Plaintiff's continued sexual cooperation with Epstein in March or April of 2007. + +39. Defendant Maxwell told Plaintiff she would need to provide Defendant Epstein with body massages in order to reap the benefits of his and Maxwell's connections. + +40. All Defendants, including Maxwell, Epstein, Groff and , knew that Plaintiff was actually being recruited for sexual purposes, and each knowingly and deliberately made false representations to ensure that Plaintiff would cooperate in fulfilling Epstein's sexual desires. These false and fraudulent representations included Defendants' telling Plaintiff that Epstein would use his connections to have her admitted into F.I.T. or a similar institute, college, university or school of higher learning and provide her with employment opportunities. Plaintiff reasonably relied on these representations and had a credible basis for such reliance, including the credible representations of Epstein and the other Defendants that they possessed extensive political, business, financial, social, and educational influence and connections. Epstein and the other Defendants represented to Plaintiff in manners that were persuasive, credible, and reasonable to Plaintiff, as they would have been to any other person similarly situated, that they had the political, business, financial, social, educational, and other influence and + +connections sufficient to arrange for and insure her admission into F.I.T. or a similar school of higher learning. + +41. Maxwell and Epstein also threatened Plaintiff that, while they had the ability to advance her education and career, they also had the ability to make sure that Plaintiff would not obtain formal education or modeling agency contracts if she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein, Groff, and Maxwell. + +42. Plaintiff reasonably believed that her compliance with Defendants' demands was crucial to her physical, psychological, financial, and reputational well-being and survival. + +43. Defendant Maxwell instructed Plaintiff how to massage Epstein using the techniques that Maxwell knew that Epstein preferred. During Plaintiff's first massage, Defendant Epstein converted it into a sexual act and made it known to Plaintiff that further sex would be required in order for her to obtain the assistance he promised her and to avoid Defendants' threatened retaliation against her if Plaintiff did not perform as demanded. + +44. Maxwell and Epstein informed Plaintiff that other young females in Epstein's company were there also to perform sexual acts for Epstein and his friends. Groff and helped to secure the presence of the other young females for these purposes. + +45. Plaintiff was instructed dozens of times to provide body massages to Epstein, both at his townhouse in New York and on his private island in the U.S. Virgin Islands. Each time she was so instructed she was also required to perform a sexual act with Epstein. The Defendants all participated in arranging for Plaintiff to be transported in interstate and foreign commerce, and affecting interstate and foreign commerce, for these sexual purposes. The Defendants Epstein, Maxwell, and used possession and control of Plaintiff's passport to induce and coerce Plaintiff into performing sexual acts with Epstein and others. + +46. During many sexual encounters, Defendant Epstein gave Plaintiff no option, opportunity, or choice not to participate in the prescribed sexual acts. + +47. Defendant Maxwell frequently controlled the assignment, or "rotation," of Plaintiff and the other young females concerning the time, place and manner of the sex acts they were told to provide to Defendant Epstein. Defendant Maxwell also gave instructions on how to perform certain sexual techniques on Epstein. Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with other females. + +48. Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaintiff with serious harm, as well as serious psychological, financial, and reputational harm, compelling Plaintiff to perform and continue performing the commercial sexual activity demanded by Defendants. + +49. On one occasion, after suffering verbal abuse and threats by Defendants Epstein, Maxwell, and MN, Plaintiff attempted to escape from Defendant Epstein's private island. A search party led by Defendants Epstein and Maxwell located her and physically returned her to the main house on the island. Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind. Defendants further used possession and control of Plaintiff's passport, without lawful consent or authority, to restrict Plaintiff's liberty and thereby force her to provide sex to Epstein. + +50. Defendant Epstein's wealth, influence, power and connections were used by Defendants Maxwell, =, and Groff, both as an inducement to provide sex (in exchange for promises of support to Plaintiff) and as a means of threatening punishment (in the event Plaintiff refused to comply with Defendants' instructions to provide sex to Epstein and others). + +51. In addition to Plaintiffs being trafficked on Epstein's private airplane, Defendants Groff, Maxwell and , with the knowledge of and instruction by Defendant Epstein, arranged Plaintiffs living accommodations, private car travel, and commercial air travel on numerous occasions for the purpose of causing Plaintiff to commit commercial sex acts. These Defendants worked in concert with one another to recruit, procure, entice, and otherwise cause many other females to engage in commercial sex acts, through their use of threats, fraud, and coercion. Among these means of coercion were the Defendant's possession and control of the females' passports and other immigration documents. This coercion was most salient, and especially effective, while the females, including Plaintiff, were on Epstein's island. + +52. In furtherance of their venture and enterprise, Defendants provided living quarters for Plaintiff at 301 East 66th Street, New York, in the Southern District of New York; a car service for Plaintiff to use as needed; a cell phone; and other valuable consideration in order to maintain Plaintiffs sexual compliance. Each of the Defendants told Plaintiff she would obtain the benefits of a place to live and phone and transportation as long as she remained compliant with their demands that she service Epstein sexually. Each of the Defendants also told her that if she was not compliant, these benefits would be taken from Plaintiff. + +53. The relationship between Plaintiff and Defendants Epstein and Maxwell was defined and characterized by Defendant Epstein's and Defendant Maxwell's frequent and persistent fraudulent representations that they would provide Plaintiff with a formal education and career advancement if she provided sex to Defendant Epstein and others in the times, places and manners demanded by Defendants. Defendants Groff and each also told Plaintiff that Defendant Epstein would advance Plaintiffs education and career in order to coerce Plaintiff into sex. Defendant told Plaintiff that Epstein had done the same for her career. As a result of these and other representations by Defendants, Plaintiff reasonably relied on these representations. In fact, however, these representations were knowingly false, were not acted upon by Defendants, and were made by Defendants Epstein, Groff, , and Maxwell solely for the purpose of maintaining Plaintiffs financial dependence on, emotional vulnerability to, and sexual compliance with Defendant Epstein's demands. The other Defendants intentionally repeated these representations and intentionally made statements designed to convince Plaintiff that the representations were true and could be relied upon. These representations and statements were made to Plaintiff in furtherance of the sex trafficking venture and enterprise for which they were each employed. + +54. As part of the venture and enterprise, Defendants Epstein, Maxwell, and took possession of Plaintiff's passport when she was being trafficked by them, including when she travelled to Epstein's island in the U.S. Virgin Islands. The Defendants took possession of Plaintiff's passport in the course of sexually trafficking Plaintiff and with the intent to violate laws against sex trafficking, including 18 U.S.C. 1591 et. seq. The Defendants used their control of Plaintiff's passport in order to coerce compliance with their demands, including their demands that Plaintiff have sex with Epstein and others. + +55. In January 2007, as part of their illegal venture and enterprise, Defendants sent Plaintiff from New York City, in the Southern District of New York, to South Africa to recruit, for a promised fee, one or more aspiring female models supposedly for Epstein to use as a personal assistant. The Defendants did not care whether the prospective female was qualified to work as a personal assistant because each knew that the female recruit would be immediately placed into the same sexually vulnerable position as Plaintiff (and the dozens of other victims of the sex trafficking enterprise) and would be induced and coerced into being used for sex through fraudulent representations and other means. + +56. Defendants Epstein and Maxwell continuously and frequently demanded that Plaintiff fulfill this task of bringing another female back to the United States and Defendants' control as a condition of Plaintiff's receiving the education, career and related benefits promised by Defendants Epstein and Maxwell. Based upon Plaintiff's experience with Defendants, however, she knew that the requested female model would not be placed in a legitimate position of employment with Defendant Epstein but would, instead, be forced into sexual servitude. Plaintiff also knew that this objective was the only purpose of Defendants , Groff, Maxwell and Epstein's demand for Plaintiff's recruitment efforts. As a result, Plaintiff deliberately refused to perform the recruitment assignment. + +57. As part of their ongoing scheme, Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts with Epstein and others. While Plaintiff was in South Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be permitted to return to the United States to receive her promised education unless she underwent a diet and lowered her body weight from 57 kilograms (approximately 125 pounds) to 52 kilograms (approximately 114 pounds). Epstein and Maxwell promised Plaintiff that, if she complied, she would receive her promised education. Defendant Groff monitored Plaintiffs progress in losing weight and continued to communicate with Plaintiff about Plaintiff's application to be admitted into F.I.T. as part of the Defendants' ruse to coerce Plaintiff to return to the United States for sex. Defendant Groff was aware of the coercion Epstein and Maxwell were applying to Plaintiff and acted to help further that coercion. Believing she had no practical choice in the matter, Plaintiff attempted to comply with the order but, given her physical height and body structure and her already existing body weight, the diet imposed upon her placed her in serious physical jeopardy, including kidney malfunction and extreme emotional and psychological distress. + +58. As part of their scheme, Defendants Epstein and Maxwell called Plaintiffs parents in South Africa to tell them that Defendant Epstein would take good care of Plaintiff when she returned to the United States, and that Defendants Maxwell and Epstein would use their connections and influence to have her admitted to F.I.T. or another well-regarded fashion school or school of higher learning. + +59. As part of their scheme, Epstein and Groff told Plaintiff that she should fill out an application for admission to F.I.T., and supporting essay, and send it to Epstein for his review. Pursuant to these instructions, Plaintiff completed an application, and supporting essay, and sent it to Epstein. As part of his scheme, Epstein told Plaintiff that he had reviewed these materials. His statements were intended to convince Plaintiff, and had the effect of convincing plaintiff (as they would have convinced any reasonable person), that her admission to F.I.T. was a "done deal" if she would comply with his instructions. Groff also made the same representations to plaintiff on Epstein's behalf. Plaintiff reasonably relied on these representations by Epstein and Groff. + +60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had contacts at F.I.T. and at modeling agencies who could ensure her admission to F.I.T. and advance Plaintiff's career. As part of their scheme, Epstein and Maxwell told Plaintiff about Epstein's vast wealth and specifically identified him as a billionaire. Epstein and Maxwell told Plaintiff that they had extensive + +contacts, in addition to those identified above, throughout New York City and elsewhere. + +61. In February of 2007, in reliance on promises made by the Defendants, Plaintiff returned to New York City, in the Southern District of New York, and was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants Maxwell, Groff, and Epstein each fraudulently promised Plaintiff again that her sexual compliance would be rewarded with admission to F.I.T. or a comparable college, a promise which they each knew to be false. In fact all four Defendants had for years worked solely to recruit females for sex and to conceal the operation of the sex scheme, and in 2007 were under Federal investigation for their conspiracy to engage in Federal sexual crimes like those committed against Plaintiff. Plaintiff knew that if she did not comply, Defendants Maxwell and Epstein would use their power, influence and connections in order to ensure that Plaintiff was unable to gain admission to F.I.T. or a comparable school, and that they would destroy her career, just as they had destroyed the careers of others who had failed to comply with their demands. + +62. Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiff's continued compliance with Epstein's sexual demands; however, they failed and refused to perform their promises to help Plaintiff be admitted to F.I.T. or another school, or to provide financial support for college admission or on-going education, false promises they repeatedly made in order to coerce her into commercial sex acts. + +63. Defendants' sexual demands on Plaintiff continued while she was in New York City, in the Southern District of New York, or in other locations in close proximity to the Defendants. In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, each of the Defendants continued to pressure her to lose excessive amounts of body weight and offered her no opportunity to decline or resist their instructions. + +64. In May, 2007, Plaintiff left the United States and did not return. Between returning from South Africa in February 2007 and leaving in May 2007, Defendants =, Groff, and Maxwell each continued to repeatedly make false representations to Plaintiff, including false and fraudulent representations that she would be admitted to F.I.T. if she continued to engage in sex with Epstein. Defendant Epstein continued to make similar false and fraudulent promises in order to have sex with Plaintiff. + +65. In and after May 2007, Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's coverup included efforts to intimidate witnesses who might provide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done. + +66. Unknown to Plaintiff, Defendants' representations and promises to Plaintiff were all false and fraudulent. Plaintiff reasonably relied on the representations and promises of the Defendants. Plaintiff also considered the Defendants' threats against the current and future well-being and safety of Plaintiff to be real and credible. All such representations, promises, and threats were made solely for the purpose of coercing and otherwise inducing Plaintiff into prolonged sexual compliance. Defendants knowingly benefitted financially and received things of value as a result of coercing and inducing Plaintiff into sexual compliance and otherwise participating in their illegal venture and enterprise. + +## COUNT I CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C. 1595 + +67. Plaintiff adopts and realleges paragraphs 1 through 66 above. + +68. Defendants individually and together, within the special maritime and territorial jurisdiction of the United States, in interstate and foreign commerce, and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, maintained, patronized, solicited, threatened, forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by Defendants were undertaken with knowledge and/or reckless disregard of the fact that their threats of force, fraud, coercion, and combinations of such means would be used, and were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In so doing, Defendants violated 18 U.S.C. §1591. + +69. Additionally, Defendants Epstein, Maxwell, and In individually and together, knowingly concealed, removed, confiscated, and possessed Plaintiff's passport and associated immigration documents, in the course of violating 18 U.S.C. § 1591, and with the intent of violating 18 U.S.C. § 1591, and to prevent, restrict, attempt to restrict, without lawful authority, Plaintiff's liberty to move or travel, in order to maintain the sexual services of Plaintiff, while Plaintiff was a victim of a severe form of sex trafficking, as defined in section 103 of the Trafficking Victims Protection Act of 2000, enacted in 22 U.S.C. § 7102. In so doing, Defendants violated 18 U.S.C. § 1592. These Defendants also obstructed, and attempted to obstruct and to interfere with the enforcement of 18 U.S.C. § 1592. + +70. Additionally, Defendants knowingly benefitted, financially and by receiving things of value, from participating in a venture (the Epstein sex trafficking venture enterprise) which had engaged in acts in violation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in such violations. In so doing, Defendants violated 18 U.S.C. § 1593A. + +71. Additionally, Defendants attempted to violate 18 U.S.C. § 1591. In so doing, Defendants violated 18 U.S.C. § 1594(a). + +72. Additionally, Defendants conspired with each other, and with other persons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants violated 18 U.S.C. § 1594(6). + +73. Additionally, Defendants conspired with each other, and with other persons known and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendants violated 18 U.S.C. § 1594(c). + +74. By virtue of their violations of 18 U.S.C. §§ 1591, 1592, 1593A, and 1594, Defendants are subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their violations. + +75. Certain property of Defendant Epstein's was essential to the commission of the federal crimes and torts described herein, including the use of multiple private aircraft including a Boeing aircraft (of make and model B-727-31H with tail number N908JE) and a Gulfstream aircraft (of make and model GA 159B with tail number N909JE). Such aircraft, along with other of Defendants' property, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. + +76. Additionally, Defendant Epstein's New York mansion, located at 9 East 71st Street, New York, New York, in the Southern District of New York, and his private island located in the United States Virgin Islands, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. + +77. As a direct and proximate result of Defendants' commission of the aforementioned criminal offenses enumerated in 18 U.S.C. § 1591, 1592, 1593A, and 1594, and the associated civil remedies provided in § 1595, Plaintiff has in the past suffered and will continue to suffer injury and pain; emotional distress; psychological and psychiatric trauma; mental anguish; humiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of enjoyment of life; invasion of privacy; and other damages associated with Defendants' actions. Plaintiff will incur further medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to these losses, Plaintiff has incurred attorneys' fees and will be required do so in the future. + +WHEREFORE, Plaintiff demands judgment against Defendants for compensatory and general damages, attorney's fees, punitive damages and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury. + +Dated: June 5, 2017. + +Respectfully Submitted, + +JAFFE, WEISSING. FISTOS, LEHRMAN, P.L. + +B : /s/ J. J. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954)-524-2820 Fax: (954)-524-2822 Email: brad@pathtojustice.com PRO HAC VICE + +BOLES, SCHILLER & FLEXNER LLP David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 (919) 749-8200 Fax: (914) 749-8300 Email: dboies@bsfllp.com + +Sigrid McCtile Meredith Boies Schiller & Flexner LLP 401 East Las Olas Blvd., Ste. 1200 Fort Lauderdale, Florida 33301 (954) 356-0011 Fax: Email: smccawley@bsfllp.com Email: mschultz@bsfllp.com PRO HAC VICE + +Paul G Cassell S.J. Quinney College of Law at the University of Utah 383 S. University Street Salt Lake City, UT 84112-0730 (801)-585-5202 Fax: (801)-585-2750 Email: cassellp@law.utah.edu. PRO HAC VICE + +This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation + +**CERTIFICATE OF SERVICE** + +**I HEREBY CERTIFY** that on the 5th day of June, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. + +STEPTOE & [REDACTED], LLP + +Michael C. [REDACTED] + +Justin Y.K. [REDACTED] + +[mmiller@steptoe.com](mailto:mmiller@steptoe.com), [cjenkins@steptoe.com](mailto:cjenkins@steptoe.com), [pparker@steptoe.com](mailto:pparker@steptoe.com) + +[jchu@steptoe.com](mailto:jchu@steptoe.com), [cjenkins@steptoe.com](mailto:cjenkins@steptoe.com), [pparker@steptoe.com](mailto:pparker@steptoe.com), [psafirstein@steptoe.com](mailto:psafirstein@steptoe.com) + +*Attorneys for Defendants* + +*Jeffrey Epstein & Lesley Groff* + +ALSTON & BIRD, LLP + +John E. Stephenson, Jr. + +Alexander S. Lorenzo + +[alex\[REDACTED\].lorenzo@alston.com](mailto:alex[REDACTED].lorenzo@alston.com), [autodocket-nyc@alston.com](mailto:autodocket-nyc@alston.com), + +[managingclerksoffice-nyc@alston.com](mailto:managingclerksoffice-nyc@alston.com), [john.stephenson@alston.com](mailto:john.stephenson@alston.com) + +*Attorneys for Defendant* [REDACTED] + +By: /s/ [REDACTED] J. 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the best of my knowledge as follows: + +- I. I am a Partner with the law firm of Boies, Schiller & Flexner LLP and duly licensed to practice in Florida and before this Court pursuant to this Court's Order granting my Application to Appear Pro Hac Vice. +- 2. I respectfully submit this Declaration in Support of Plaintiff's Memorandum of Law in Opposition of Defendants' Motion to Dismiss2. + - 3. Attached hereto as Exhibit 1 is a true and correct copy of Plaintiff's First + +IPlaintiff originally filed this action under the pseudonym "Jane Doe 43," but is now proceeding under her real name. + +2 Plaintiff response is to Defendants' Motion to Dismiss [DE 80 and 83] and Supplemental Motion to Dismiss [DE 104, 105 and 111]. + +Amended Complaint filed on June 05, 2017. + +- 4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of + +- 5. Attached hereto as Sealed Exhibit 3 is a true and correct copy of an + +I declare under penalty of perjury that the foregoing is true and correct. + +Dated: February 26, 2018. + +Respectfully Submitted, + +BOLES, SCHILLER & FLEXNER LLP + +By: /s/ Sigrid McCawley + +Sigrid McCawley (Pro Hac Vice) + +Meredith (Pro Hac Vice) + +Boies Schiller & Flexner LLP + +401 E. Las Olas Blvd., Suite 1200 + +Ft. Lauderdale, FL 33301 + +(954) 356-0011 + +J.r(Pro Hac Vice) + +POTTINGER LLC + +425 North Andrews Avenue, Suite 2 + +Fort Lauderdale, Florida 33301 + +(954) 524-2820 + +Paul G. Cassell (Pro Hac Vice) + +S.J. Quinney College of Law + +University of Utah + +383 University St. + +Salt Lake City, UT 84112 + +(801) 585-52023 + +3 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on the 26th day of February, 2018, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. + +Kimo S. Peluso Sher Tremonte, LLP 90Broad Street, 23rd Floor New York, NY 10004 k luso@shertremonte.com Counsel for Haddon, & P.C. + +Laura A. Menninger, Esq. Jeffrey Pagliuca. E . HADDON, & 150 East 10th Avenue Denver, Colorado 80203 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com + +John E. Stephenson, Jr. Jonathan D. Parente ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, GA 30309 John.stephenson@alston.com Jonathan.parente@alston.com + +Alexander S. Lorenzo ALSTON & BIRD LLP 90 Park Avenue New York, NY 10016 alexander lorenzo@alston com Counsel for Defendant + +Michael Justin Y.1% Michael A. Keou h , P.C. STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoe.com jchu@steptoe.com Counsel for Defendants, Jeffrey Epstein and Lesley Groff + +> /s/ Sigrid McCawley Sigrid McCawley \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820167/EFTA02820167.metadata.json b/marker2/court-jane-doe-43/EFTA02820167/EFTA02820167.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b47c3671c92dd42c8f253c8b9b797190bd90382a --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820167/EFTA02820167.metadata.json @@ -0,0 +1,228 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820167.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3280, + "elapsed_seconds": 1.44, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 72.9 + ], + [ + 293.59381103515625, + 72.9 + ], + [ + 293.59381103515625, + 103.863037109375 + ], + [ + 68.544, + 103.863037109375 + ] + ] + }, + { + "title": "DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF \nPLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO \nDEFENDANTS' MOTIONS TO DISMISS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 134.02800000000002, + 302.94 + ], + [ + 478.9478454589844, + 302.94 + ], + [ + 478.9478454589844, + 348.363037109375 + ], + [ + 134.02800000000002, + 348.363037109375 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 223.38, + 85.05 + ], + [ + 388.9223937988281, + 85.05 + ], + [ + 388.9223937988281, + 100.10302734375 + ], + [ + 223.38, + 100.10302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 26 + ], + [ + "Text", + 7 + ], + [ + "ListItem", + 3 + ], + [ + "SectionHeader", + 2 + ], + [ + "Footnote", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 30 + ], + [ + "Text", + 25 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "ListItem", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Footnote", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 93 + ], + [ + "Line", + 47 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820167" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820170/EFTA02820170.md b/marker2/court-jane-doe-43/EFTA02820170/EFTA02820170.md new file mode 100644 index 0000000000000000000000000000000000000000..646f49bc011965ce12646531d43c5ee36ab5eb58 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820170/EFTA02820170.md @@ -0,0 +1,25 @@ +![](_page_0_Picture_1.jpeg) + +February 28, 2018 + +## VIA CM/ECF + +Honorable John O. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et al., Case No.: 17-cv-00616 (JCK) + +Dear Judge Koeltl: + +Sigrid S. McCawley, Esq. E-mail: smccawley@bsflIri.com + +This letter motion seeks the Court's permission to file an unredacted copy of Plaintiff's Opposition to Defendants' Motion to Dismiss and Defendants' Supplemental Motion to Dismiss (DE 115) under seal pursuant to paragraph 1(c) of the Court's Confidentiality Stipulation and Order (DE 100) dated January 19, 2018. + +Plaintiff has redacted any references to deposition and deposition exhibits as provided in the Court's Confidentiality Stipulation and Order (DE 100). Accordingly, Plaintiff respectfully requests that the she may file her unredacted brief and exhibits under seal. + +SSM/ + +cc: All Counsel of Record + +Respectfully submitted, + +Is/ Sigrid McCawlev Sigrid S. 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Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007 + +Sigrid S. McCawley, Esq. E-mail: smccawlev@bsfllo.com + +February 28, 2018 + +APPLICATION GRANTED SO ORDERED + +6,9-67 3/1a"( John G. Koeltl, 0 + +Re: Jane Doe 43 v. Jeffrey Epstein, et at, Case No.: 17-cv-00616 (JCK) + +Dear Judge Koeltl: + +This letter motion seeks the Court's permission to file an unredacted copy of Plaintiff's Opposition to Defendants' Motion to Dismiss and Defendants' Supplemental Motion to Dismiss (DE 115) under seal pursuant to paragraph 1(c) of the Court's Confidentiality Stipulation and Order (DE 100) dated January 19, 2018. + +Plaintiff has redacted any references to deposition and deposition exhibits as provided in the Court's Confidentiality Stipulation and Order (DE 100). 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Menninger (with exhibits), Defendant Ghislaine Maxwell will move the Court, pursuant Rules 8, 9(b), and I2(b)(2) and (6), and 12(1) of the Federal Rules of Civil Procedure, and before the Honorable John G. Koeltl, at the United States Courthouse, 500 Pearl Street, New York, New York 10007, as soon as counsel may be heard, for an Order (1) granting Ms. Maxwell's Motion to Dismiss the Amended Complaint, (2) striking portion of the Amended Complaint if the Motion to Dismiss is not granted and (3) any other relief the Court deems just and proper. + +Dated: Denver, Colorado March 13, 2018. + +Respectfully submitted, + +/s/ Laura A. Menninger + +Laura A. 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HADDON, AND P.C. 150 East 10 Avenue Denver, CO 80203 303.831.7364 + +## TABLE OF CONTENTS + +| TABLE OF CONTENTS | | i | +|------------------------|-----------------------------------------------------------------------------------|-----| +| TABLE OF AUTHORITIES | | ii | +| INTRODUCTION | | 1 | +| FACTUAL BACKGROUND | | 1 | +| I. | The amended complaint story | 1 | +| II. | previous account | 3 | +| ARGUMENT | | 4 | +| I. | This Court should strike paragraphs 11-33 of the amended complaint | 4 | +| II. | The amended complaint fails to state a claim for relief | 4 | +| A. | The Trafficking Victims Protection Act does not apply to the consensual, adult | | +| | relationship described in the amended complaint | 5 | +| B. | The amended complaint fails to state a claim for relief | 8 | +| i. | The amended complaint impermissibly lumps all Defendants together in violation of | | +| | Rule 8 | 8 | +| ii. | The amended complaint fails under lqbal and Twombly | 9 | +| iii. | The amended complaint fails to plead fraud | I I | +| | a. The amended complaint fails to plead fraud with particularity | I I | +| | b. The amended complaint fails to plead reasonable reliance | 13 | +| iv. | The amended complaint fails to plead coercion | 14 | +| v. | The amended complaint fails to plead a causal link | 16 | +| vi. | Sections 1592, 1593A, and 1594(a)—(c) do not provide relief | 16 | +| III. | As to Ghislaine Maxwell, any further amendment of the complaint would be futile | 18 | +| IV. | The amended complaint is untimely | 20 | +| V. | This court is not the proper forum | 25 | +| CONCLUSION | | 25 | +| CERTIFICATE OF SERVICE | | 27 | + +## TABLE OF AUTHORITIES + +# Cases + +| Abarca v. Little, | 54 F. Supp. 3d 1064, 1068 (D. Minn. 2014) | 20 | +|------------------------------------------|-------------------------------------------------------------|-------------------| +| Abbey v. Skokos, | No. 11-1037-cv, 2013 WL 336010, at*1 (2d Cir. Jan 30, 2013) | 14 | +| Abu Dhabi Commercial Bank v. | Stanley & Co., Inc., 651 F. Supp. 2d 155, 170 | | +| (S.D.N.Y. 2009) | | 11 | +| Am. Sales Co., Inc. v. AstraZeneca AB, | No. 10 Civ. 6062, 2011 WL 1465786, at *5 (S.D.N.Y. | | +| Apr. 14, 2011) | | 9 | +| Ashcroft v. Iqbal, | 556 U.S. 662, 678 (2009) | 9, 10, 11, 14 | +| Atuahene v. City of Hartford, | 10 Fed. App'x 33, 34 (2d Cir. 2001) | 9 | +| Bell Atlantic Corp. v. Twombly, | 550 U.S. 544, 570 (2007) | 9, 10, 11, 12, 20 | +| Caputo v. Pfizer, Inc., | 267 F.3d 181, 191 (2d Cir. 2001) | I 1 | +| Chickasaw Nation v. United States, | 534 U.S. 84, 94 (2001) | 21 | +| v. S.A.C. Trading Corp., | 711 F.3d 353, 359 (2d Cir. 2013) | 11 | +| Crigger v. Fahnstock & Co., Inc., | 443 F.3d 230, 234 (2d Cir. 2006) | 13 | +| Fernandez-Vargas v. | 548 U.S. 30, 37 (2006) | 21 | +| Greenberg v. Chrust, | 198 F. Supp. 2d 578, 583 (S.D.N.Y. 2002) | 13 | +| Gucci Am., Inc. v. Weixing Li, | 768 F.3d 122, 141 (2d Cir. 2014) | 25 | +| INS v. St. Cyr, 533 U.S. 289, 316 (2001) | | 21 | +| Landgraf v. USI Film Products, | 511 U.S. 244 (1994) | 23 | +| Lindh v. | , 521 U.S. 320, 326 (1997) | 22 | +| =I v. City of New York, | No. 07 Civ. 7834, 2008 WL 1826483, at *1 (S.D.N.Y. Apr. 23, | | +| 2008) | | 9 | +| O & G Carriers, Inc. v. | | | +| | 799 F. Supp. 1528, 1538 (S.D.N.Y. 1992) | 9 | +| v. Nat'l Prop. Analysts Farmers, | 936 F.2d 674, 676 (24 Cir. 1991) | 11 | + +| Oluch v. Orina, 101 F. Supp. 3d 325, 330 (S.D.N.Y. 2015) | 24 | +|--------------------------------------------------------------------------|----------| +| Schlaifer=& Co. v. Estate of Andy Warhol, 119 F.3d 91, 98 (2d Cir. 1997) | 13 | +| Stronger v. California, 539 U.S. 607, 616-17 (2003) | 22 | +| United States v. Marcus, 487 F. Supp. 2d. 289, 306-07 (E.D.N.Y. 2007) | 6, 7, 16 | +| United States v. Sec. Indus. Bank, 459 U.S. 70, 79-80 (1982) | 21 | +| United States v. Walls, 784 F.3d 543, 548 (9th Cir. 2015) | 5 | + +## Statutes + +| 18 U.S.C. § 1591 | 5, 11, 12, 14, 15, 16 | +|------------------|-----------------------| +| 18 U.S.C. § 1592 | 17 | +| 18 U.S.C. § 1593 | 17 | +| 18 U.S.C. § 1594 | 20 | +| 18 U.S.C. § 1595 | 5, 20, 21 | +| 18 U.S.C. § 3293 | 22 | +| 28 U.S.C. § 1658 | 20 | + +# Rules + +Ghislaine Maxwell submits this memorandum of law in support of her motion to dismiss: + +# INTRODUCTION + +The amended complaint paints a picture but not a claim for relief. Charitably construed, the amended complaint describes a mutually beneficial, sexual relationship between two consenting adults. It does not plead a claim for unlawful sex trafficking. What's more, no further amendment could cure the deficiencies identified in the various motions to dismiss and reiterated below. As thoroughly explained in Mr. Epstein and Ms. Groff's motion to dismiss,. own sworn testimony and the evidence presented in her counsel's previous case against Ms. Maxwell conclusively establish that was not trafficked for sex. (Doc. # 104-1, p. 2-4). This case should be dismissed with prejudice. + +# FACTUAL BACKGROUND + +has told at least two widely divergent versions of her brief, decade-old relationship with Jeffrey Epstein: the story portrayed in her amended complaint, and the account she provided in her counsel's prior litigation. The former version fails to state a claim, even on its own terms. The latter demonstrates the futility of allowing any further amendment to the complaint currently pending before this Court. + +# I. THE AMENDED COMPLAINT STORY + +met Mr. Epstein in October 2006. (Am. Compl. 1 34). was then an emancipated and adult 22 year old. Mr. Epstein was considerably older, in his fifties. (Id. ¶ 11). He was unmarried and quite wealthy. worth more than a billion dollars. (Id. fi 11,60). + +Shortly after they met, and Mr. Epstein began a consensual, sexual relationship. (Id. 143). Mr. Epstein lavished gifts and advantages on , providing her a cell phone, a luxury car service, and an apartment on the Upper East Side. (Id. 1 52). Ms. + +and Mr. Epstein engaged in consensual sex "dozens of times" in numerous places, from New York to Mr. Epstein's private island in the U.S. Virgin Islands. (M.1 45). + +alleges that Mr. Epstein promised "he would use his wealth and influence to have I I admitted into The Fashion Institute of Technology (known as "F.I.T.") in New York City or into a similar institute of higher learning offering a curriculum of fashion industry training." (Id. qq 38). . Maxwell "confirmed and reiterated this promise." (Id.) If did not provide Mr. Epstein with continued "sexual favors," Mr. Epstein and Ms. Maxwell told her they "had the ability to make sure that [she] would not obtain formal education or modeling agency contracts...." (Id.1 41). + +traveled to South Africa in January 2007, allegedly at the request of Mr. Epstein on a "recruiting assignment" to find a South African model he could hire as an assistant. (Id .1 38). alleges that she knew the individual recruited would not "be placed in a legitimate position of employment with Defendant Epstein." (Id. 1 56). As a result, refused to complete the "recruitment." (Id. ¶1 55-56). + +By this point, was fully aware of Defendants' alleged scheme. Nevertheless, and of her own volition, she returned to the United States and resumed her relationship with Mr. Epstein. (Id. 1 61). claims that Mr. Epstein and Ms. Maxwell again committed to help her secure her admission to F.I.T. (Id.) The amended complaint does not, however, allege that ever actually applied for admission at F.I.T. or any other similar institute of higher learning offering a curriculum of fashion industry training. Even so, accuses Mr. Epstein and Ms. Maxwell of "fail[ing] and refus[ing] to perform" that promise. (Id. q 62). left the United States for good in May 2007. (Id. 1 64). + +Some ten years later, despite never applying, [REDACTED] filed the complaint in this action, alleging that Defendants fraudulently induced and coerced her into a sexual relationship with Mr. Epstein and failed to keep their end of the bargain—secure admission to F.I.T. + +**II. [REDACTED] PREVIOUS ACCOUNT** + +[REDACTED] is not the victim she portrays herself to be. To the contrary, [REDACTED] own admissions reveal her sophistication in the ways of fostering romantic relationships with wealthy men. [REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +Rather than a Dickensian tale of a vulnerable, naïve, young women, forced into a life of slavery and sexual servitude, this case actually presents the end game of a sophisticated, ambitious woman, accustomed to an expensive lifestyle provided by numerous male benefactors. As elaborated below, the amended complaint fails to state a claim for relief, a failure [REDACTED] cannot avoid through the convenience of yet another opportunity to re-plead her case. + +#### ARGUMENT + +#### I. THIS COURT SHOULD STRIKE PARAGRAPHS 11-33 OF THE AMENDED COMPLAINT + +The first half of amended complaint is replete with harassing, impertinent, and scandalous allegations having nothing to do with this case. (Am. Compl. 11 11- 33). The allegations relate to prior proceedings against Mr. Epstein, not involving and are included solely to distract from the amended complaint's lack of substance. Apart from an allegation that Mr. Epstein and the other Defendants foiled her ability to secure admission to F.I.T., even though she never applied, offers little in support of her trafficking claim. Ms. Maxwell joins the other defendants in their request that this Court strike paragraphs I I through 33 of the amended complaint under Rule 12(f).' (Doc. # 104-1, p. 5-6; Doc. # Ill, p. 3 n.3). Although the amended complaint fails to state a claim on its own terms, striking the "immaterial, impertinent, [and] scandalous" material brings that failure into stark relief. + +## II. THE AMENDED COMPLAINT FAILS TO STATE A CLAIM FOR RELIEF + +This Court should dismiss amended complaint with prejudice. The Trafficking Victims Protection Act (TVPA) does not apply to the conduct alleged: the amended complaint impermissibly lumps all Defendants together; it does not plead fraud with + +&#x27; This is not the first time Plaintiff's counsel has filed pleadings containing gratuitous and impertinent material concerning Ms. Maxwell. See Menninger Decl. Ex B (4/712015 Order Denying Motion to Join and Motion to Amend) at 4-6. In case number 9:08-cv-80736-KAM in the Southern District of Florida, the Court struck a Rule 21 motion in its entirety as well as significant portions of the "corrected" Rule 21 motion before denying it on the merits. Id. The court also suggested that Plaintiffs counsel might be subject to sanctions under Rule II. Id. at 7. + +particularity; it fails to plead reasonable reliance, coercion, or causation; it fails to state a claim under 18 U.S.C. §§ 1592, 1593A, or 1594; it is barred by the statute of limitations; and it improperly lays venue in the Southern District of New York. + +### A. The Trafficking Victims Protection Act does not apply to the consensual, adult relationship described in the amended complaint + +asserts a cause of action under the Trafficking Victims Protection Act (TVPA), 18 U.S.C. § 1595. At the time of the alleged events in this case, the TVPA provided: + +whoever knowingly . . . recruits, entices, harbors, transports, provides, or obtains by any means a person .. . knowing that force, fraud, or coercion . . . will be sued to cause the person to engage in a commercial sex act . shall be punished as provided in subsection (b). + +18 U.S.C. § 1591(a) (2006). Section 1595 creates a civil remedy for violations of section 1591. + +"The TVPA is part of a comprehensive regulatory scheme that criminalizes and attempts to prevent slavery, involuntary servitude, and human trafficking for commercial gain." United States v. Walls, 784 F.3d 543, 548 (9th Cir. 2015). Congress enacted the TVPA in recognition that "human trafficking, particularly of women and children in the sex industry, `is a modern form of slavery ...."' Id. (quoting 22 U.S.C. § 7101(b)(O). + +The amended complaint alleges nothing of this sort. It does not allege that was held as a slave, subject to involuntary servitude, or trafficked for the Defendants' commercial gain. Instead, it describes a consensual sexual relationship between Mr. Epstein and who voluntarily entered into the relationship and enjoyed many perks as a result, including financial support, an apartment, transportation, and a cell phone. (Am. Compl. 1 52). It was a relationship was never forced to continue against her will. was free to come and go as she pleased, as evidenced by her trip home to London and South Africa in January 2007, and her voluntary return to the United States in February 2007. (Id. Ti 55, 61). + +claims her motivation to return to the United States was primarily based on an alleged unfulfilled promise—made by Mr. Epstein, and "confirmed and reiterated" by Ms. Maxwell —"that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology (known as "F.I.T.") in New York City or into a similar institute of higher learning offering a curriculum of fashion industry training." (Id.11 38, 61, 62). + +Conspicuously absent from the amended complaint, however, are any allegations that ever applied to F.I.T. or a similar school, or that she was denied admission based Defendants' conduct. Sex trafficking this is not. + +In arguing to the contrary, relies on United States v. Marcus, 487 F. Supp. 2d 289 (E.D.N.Y. 2007), rev'd, 628 F.3d 36 (2d. Cir. 2010). She characterizes Marcus as affirming application of the TVPA to acts arising out of a relationship that "began as an adult, consenting relationship." (Doc. # 116, p. 9). But that is not so. To the contrary, Marcus makes clear that consensual conduct does not violate the TVPA. 628 F.3d at 45 n.I I. + +In Marcus, an initially consensual relationship rapidly turned into a non-consensual relationship involving violence, torture, and sexual abuse. Id. at 39-40, 45. The court correctly instructed the jury that consensual conduct did not violate the statute. /d. at 45 n. I I. In turn. the evidence overwhelmingly supported the jury's conclusion that the defendant engaged in rampant, non-consensual violence and abuse. For example, + +Marcus tied [the victim's] hands together with rope, made [the victim] lie down on a coffee table, and told [the victim] he was going to put a safety pin through her labia. Because she began to scream and cry, Marcus put a washcloth in [the victim's] mouth and whipped her with a kitchen knife in + +an unsuccessful attempt to force her to stop crying. Marcus proceeded to put the safety pin through [the victim's] labia and attached a padlock to it, closing her vagina. + +*Id.* at 40. Marcus's victim was forced to remain with him for two years. 487 F. Supp. at 292. + +The non-consensual relationship in *Marcus* stands in stark contrast to the relationship described in the amended complaint. [REDACTED] makes no allegation of physical abuse, violence, or torture. Rather, the amended complaint musters nothing more than conclusory and non-specific allegations of threats of "serious harm," unadorned by any factual explanation of what those "threats" entailed. (Am. Compl. ¶ 8).2 Where the amended complaint is specific, it describes a mutually beneficial relationship between an older, wealthy man, and a young, worldly, ambitious woman, who is upset that her benefactor did not secure her admission to a fashion school to which she never applied. Where the TVPA clearly applied to the violent and non-consensual relationship at issue in *Marcus*, it plainly does not apply to the consensual + +--- + +2 The amended complaint's reliance on conclusory, generalized allegations of "threats," "harm, and "coercion," demonstrate the necessity of striking the scandalous and immaterial allegations dominating the first half of the complaint. *Supra* Part I; *see* Fed. R. Civ. P. 12(f). It is apparent [REDACTED] hopes to compensate for her complaint's lack of substance by bootstrapping into this case these irrelevant and impertinent allegations. + +relationship described by the amended complaint. The Marcus decision offers no support to. argument. + +Indeed, unsupported assertion that she was "trafficked" for sex against her will does a disservice to the thousands of people in the United States who, each year, actually suffer from sex trafficking. Sex trafficking is a form of modern day slavery. Sex Trafficking, NATIONAL HUMAN TRAFFICKING HOTLINE, https://humantraffickinghotline.org/typetrafficking/sex-trafficking (last visited March 9, 2018). "Sex traffickers frequently target victims and then use violence, threats, lies, false promises, debt bondage, or other forms of control and manipulation to keep victims involved in the sex industry for their own profit." Id. Sex traffickers do not allow their victims to travel freely, as did, and sex trafficking victims do not move from relationship to relationship reaping the benefits of a wealthy lifestyle, as did. Real sex trafficking is not glamorous; it is not a wealthy lifestyle funded by a rich boyfriend. See, e.g., Sex Trafficking Story, Escort Services, NATIONAL HUMAN TRAFFICKING HOTLINE, https://humantraffickinghotline.org/resources/sex-trafficking-storyescort-services-paula (last visited March 9, 2018). + +For these reasons, as well as those given in the motions to dismiss filed by Mr. Epstein, Maxwell here adopts, the allegations in the amended complaint fall outside the scope of the TVPA. The case should be dismissed with prejudice. + +# B. The amended complaint fails to state a claim for relief + +Assuming the TVPA applies to the facts alleged by which it doesn't, this case should be dismissed because the amended complaint fails to state a claim on its own terms. + +## i. The amended complaint impermissibly lumps all Defendants together in violation of Rule 8 + +As explained by Mr. Epstein, Ms. Groff, and in their respective motions to dismiss, the amended complaint is incurably infected with "group pleading." (Doc. # 104-I, p. 15-16; Doc. # III, p. 8-9). Rule 8 requires a complaint to provide "specification as to the particular activities by any particular defendant." Am. Sales Co., Inc. v. AstraZeneca AB, No. 10 Civ. 6062, 2011 WL 1465786, at \*5 (S.D.N.Y. Apr. 14, 2011). A court must dismiss a complaint that fails to "indicate clearly the defendants against whom relief is sought and the basis upon which the relief is sought against the particular defendants." v. City of New York, No. 07 Civ. 7834, 2008 WL 1826483, at \*1 (S.D.N.Y. Apr. 23, 2008). + +Here, the amended complaint repeatedly attributes conduct to all Defendants without providing supporting factual allegations sufficient to put Ms. Maxwell on notice as to what conduct is attributed to her. (See, e.g., Am. Compl. II 34, 40, 55, 57, 63). already failed once to correct this deficiency when given the opportunity. Her repeated violation of Rule 8 requires this Court to dismiss the amended complaint. See Atuahene v. City of Hartford, 10 Fed. App'x 33, 34 (2d Cir. 2001) (dismissing plaintiff's complaint which "Iump[ed] all the defendants together and provide[d] no factual basis to distinguish their conduct"); O & G Carriers, Inc. v. M, 799 F. Supp. 1528, 1538 (S.D.N.Y. 1992) (same). + +# II. The amended complaint fails under Iqbal and Twombly + +"To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to 'state a claim to relief that is plausible on its face.'" Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The plausibility pleading requirement requires a complaint to articulate facts supporting the reasonable inference of liability. Id.; Twombly, 550 U.S. at 556. A complaint that relies on a recitation of the elements of a cause of action or legal conclusions, "unadorned" by factual support, cannot survive a motion to dismiss. Iqbal, 556 U.S. at 678. + +“A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” *Id.* A complaint must do more than establish a “possibility” that the defendant is liable; it must show that liability is “plausible.” *Id.* “Where a complaint pleads facts that are ‘merely consistent with’ a defendant’s liability, it ‘stops short of the line between possibility and plausibility of entitlement to relief.’” *Id.* (quoting *Twombly*, 550 U.S. at 557). The amended complaint falls far short of these standards. Dismissal is therefore required. + +To the extent the amended complaint differentiates between the named Defendants, its allegations are implausible. Buried in [REDACTED] thirty-one page amended complaint are a mere five general, conclusory allegations against Ms. Maxwell. + +- • Ms. Maxwell told [REDACTED] that Mr. Epstein promised to help [REDACTED] get into F.I.T. or a similar institute, but that promise went unfulfilled. (Am. Compl., ¶¶ 38–41, 50, 53, 59–62). +- • Ms. Maxwell told [REDACTED] to provide Mr. Epstein with body massages in order for Mr. Epstein to help [REDACTED] get into F.I.T., and Ms. Maxwell instructed [REDACTED] how to perform the tasks. (*Id.* at 39–47).3 +- • Ms. Maxwell “ordered” [REDACTED] to have sex with Mr. Epstein. (*Id.* at 47–48, 61). +- • Ms. Maxwell “used possession and control of [REDACTED] passport to induce and coerce [REDACTED] into performing sexual acts with [Mr. Epstein] and others.” (*Id.* at 45, 54). +- • Ms. Maxwell “intimidated, threatened, humiliated and verbally abused” [REDACTED] in order to coerce her into sexual compliance. (*Id.* at 43–50). + +These allegations are insufficient under *Iqbal* and *Twombly*. + +--- + +3 [REDACTED] +[REDACTED] +[REDACTED] + +Section 1951 only affords civil liability when the actor "knowingly ... recruits, entices, harbors, transports, provides, or obtains by any means a person ... knowing that force, fraud, or coercion ... will be used to cause the person to engage in a commercial sex act." 18 U.S.C. § 1591(a) (2006). The factual allegations above, however, fail to create a plausible inference that Ms. Maxwell is liable under the statute; they do not show that Ms. Maxwell recruited, enticed, harbored, or transported knowing that force. fraud, or coercion would be used to cause her to engage in a commercial sex act. allegations "do not permit the court to infer more than the mere possibility of misconduct." See Abu Dhabi Commercial Bank v. Stanley & Co., Inc., 651 F. Supp. 2d 155, 170 (S.D.N.Y. 2009). The amended complaint, therefore, must be dismissed. + +# iii. The amended complaint fails to plead fraud + +### a. The amended complaint fails to plead fraud with particularity + +complaint alleges fraud. (See, e.g., Am. Compl.,11 40, 58-64). As a result, she must meet the heightened pleading requirements of Rule 9(b), above and beyond the plausibility standard articulated in lqbal and Twombly. Fed. R. Civ. P. 9(b). Rule 9(b) requires allegations of fraud to be pleaded "with particularity." Id. + +To satisfy this requirement, a complaint must "specify the time, place, speaker, and content of the alleged misrepresentations," "explain how the misrepresentations were fraudulent and plead those events which give rise to a strong inference that the defendant[] had an intent to defraud, knowledge of the falsity, or a reckless disregard for the truth." + +v. S.A.C. Trading Corp., 711 F.3d 353, 359 (2d Cir. 2013) (quoting Caputo v. Pfizer, Inc., 267 F.3d 181, 191 (2d Cir. 2001)). "An ample factual basis must be supplied to support the [fraud] charges." v. Nat 'I Prop. Analysts Partners, 936 F.2d 674, 676 (2d Cir. 1991); see also Rosner v. Bank of China, No. 06-cv-13562, 2008 WL 5416380, at \*5 (S.D.N.Y. Dec. 18, + +2008), CV, 349 F. App'x 637 (2d Cir. 2009) (requiring a plaintiff, under Rule 9(b), to plead specific facts which give rise to "strong inference of actual knowledge" of the alleged fraud). Rule 9(b) does not license plaintiffs "to base claims of fraud on speculation and conclusory allegations." 936 F.2d at 676. + +The sum total of fraud claim is as follows: She claims that "[a]ll Defendants," including Ms. Maxwell, violated 18 U.S.C. § 1591 because they fraudulently promised her that Mr. Epstein, using his "wealth and influence," would help her get into the F.I.T. and advance her career. (Am. Compl. 11 38, 40, 41, 58, 60, 61). According to the Defendants "knew that [she] was actually being recruited for sexual purposes" and made the false representation "to ensure that [she] would cooperate in fulfilling Epstein's sexual desires." (Id.) does not allege, however, that Mr. Epstein (or the other Defendants) promised to circumvent the entire application process, that she need not even apply, and that she would then mysteriously be admitted to F.I.T. or a similar institute of higher education. + +allegations fail to satisfy Rule 9(b) because she includes no facts to support her fraud claim, much less an "ample factual basis." See M, 936 F.2d at 676. The amended complaint lacks facts showing when or where Ms. Maxwell allegedly made any promises, the content of any promises, nor does it explain how any misrepresentations were fraudulent. Moreover, nothing in the amended complaint supports the "strong inference" that Ms. Maxwell made a promise with the requisite intent to defraud. See , 711 F.3d at 359. + +points to her conclusory allegations that Ms. Maxwell made promises that were "knowingly false" and "not acted upon." (Am. Compl. 1 53). She does not aver that Ms. Maxwell's promise was "knowingly false" when made. And "fraudulent intent cannot be inferred merely from the non-performance of a party's representations." Greenberg v. Chrust, + +198 F. Supp. 2d 578, 583 (S.D.N.Y. 2002) ("[T]he failure to fulfill a promise to perform future acts is not grounds for a fraud action." (quoting 25 F.3d at 1172)). These conclusory allegations, therefore, are insufficient to state a fraud claim under Rule 9. + +fraud claim fails for yet another reason: She never applied to F.I.T. Ms. Maxwell cannot be liable for fraudulently stating that Mr. Epstein would secure her admission to F.I.T. when never even applied. + +For these reasons, as well as those given by Mr. Epstein, Ms. Groff, and M=, (Doc. # 104-1, p. 9-16; Doc. # Ill, p. 7-13), this Court should dismiss the amended complaint. + +## b. The amended complaint fails to plead reasonable reliance + +A fraud claim must plead facts establishing reasonable reliance on the allegedly fraudulent promise. Crigger v. Fahnstock & Co., Inc., 443 F.3d 230, 234 (2d Cir. 2006). Here, however, merely states, in conclusory terms, that she "reasonably relied" on the alleged fraudulent misrepresentations. (Am. Compl. 1 53). She does not include any facts to support this assertion. Thus, has not shown reliance on the alleged promise. + +Nor has she shown that any such reliance was reasonable. had only just met Mr. Epstein when he allegedly told her that he would use his wealth and connections to get her admitted into F.I.T. or a similar institution. (Id.1 36, 38). It is preposterous that a reasonable person would rely on such a promise from a person she barely knew. No reasonable person would rely on the promise of a virtual stranger claiming he would secure her admission to college so long as she gave him sexual favors. See Schlaifer & Co. v. Estate of Andy Warhol, 119 F.3d 91, 98 (2d Cir. 1997) (refusing to find reasonable reliance when "circumstances may be so suspicious as to suggest to a reasonably prudent plaintiff that the defendant's representations may be false, and that the plaintiff cannot reasonably rely on those + +representations"); see also Abbey v. Skokos, No. 11-1037-cv, 2013 WL 336010, at \*1 (2d Cir. Jan 30, 2013) (stating that a plaintiff's reliance is unreasonable if "through minimal diligence" she should have discovered the truth). Further, does not allege that she knew Mr. Epstein had gotten others into F.I.T., that he was on the faculty or staff there, or had particular connections to the school, or any reason to believe Ms. Maxwell would have any additional bases for making any such promises. The lack of detail regarding the promise; the subject of the agreement (sexual favors); and the promise of admission into an institution of higher education would cause any reasonable person to question, not rely, on has failed to carry her burden of pleading reasonable reliance. + +### iv. The amended complaint fails to plead coercion + +As set forth in the motions to dismiss filed by Mr. Epstein, Ms. Groff, and M=, the amended complaint fails to include factual allegations to support the contention that Defendants used "coercion" to traffic . Section 1591 defines coercion, as: + +- (A) threats of serious harm or physical restraint against any person; [or] +- (B) any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person. + +18 U.S.C. § 1591(e)(2). Serious hams can be "physical or nonphysical, including psychological, financial, or reputational harm," but it must be "sufficiently serious, under all the surrounding circumstances, to compel a reasonable person of the same background and in the same circumstances to perform or to continue performing commercial sexual activity in order to avoid incurring that harm." 18 U.S.C. § 1591(eX4). As explained below, the amended complaint does not contain any factual allegations of coercive conduct. The most it includes is language cribbed from the statute and conclusory allegations which are not presumed as true and provide no support for contentions. (See, e.g., Am. Compl. 1 48); see lqbal, 556 U.S. at 681. + +First, the complaint does not show that Defendants made "threats of serious harm to or physical restraint" against claims "Maxwell and Epstein threatened [her] that .. . they [] had the ability to make sure that [she] would not obtain formal education or modeling agency contracts" if she did not comply with their requests. (Am. Comp1.1 41); see also (M.11 50, 52). The suggestion that a well-traveled, educated, adult woman could believe that Mr. Epstein, much less his alleged cohort Ms. Maxwell, had the ability to prevent every institution of higher education from accepting her, and every modeling agency in the world from hiring her, is ridiculous. See 18 U.S.C. § 1591(e)(4). This statement, as a matter of law, is not a threat. + +To continue the parade of conclusory allegations, argues that "Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance." (Am. Compl. 1 48). Instead of putting forth facts to support her claim, the amended complaint merely parrots the statutory definition of serious harm. (Id. ("Defendants Epstein and Maxwell "threatened [her] with serious psychological, financial, and reputational harm, compelling Plaintiff to perform and continue performing the commercial sexual activity demanded by Defendants.")); see also 18 U.S.C. § 1591(e)(4). Every alleged threat in the amended complaint suffers from these deficiencies. (See, e.g., Am. Comp1.11 50). + +The next allegation is focused on Mr. Epstein's wealth and the fact that he bankrolled a luxurious lifestyle for in New York. The amended complaint contends that these facts in combination—or in and of themselves, the amended complaint is unclear—were part of a scheme or plan that caused to believe that she must perform sexual acts with Mr. Epstein or suffer unspecified "serious harm." (Id. qy 50-52). But neither wealth nor the revocation of a lifestyle constitutes serious harm. The amended complaint does not include a + +single fact convening Mr. Epstein's wealth and his generosity towards of serious harm. See 18 U.S.C. § 1591(e)(4). into a threat + +Finally, variously and inconsistently claims that some or all of the "Defendants" withheld her passport and restricted her travel, without specifying when her passport was taken from her. (Am. Compl. 45, 49, 51, 54). The amended complaint does not, however, allege that attempted to travel internationally but was stopped only because the "Defendants" withheld her passport. In fact, the amended complaint shows exactly the opposite. was allowed to, and did, travel of her own accord, even when acting in defiance of Defendants' alleged threats of serious harm. (Id. 1 56). + +## v. The amended complaint fails to plead a causal link + +As explained in Mr. Epstein and Ms. Groff s motion to dismiss, the amended complaint fails to demonstrate that the alleged fraudulent and coercive conduct "caused" to engage in a commercial sex act. (Doc. # 104-1, p. 19). See United States v. Marcus, 487 F. Supp. 2d. 289, 306-07 (E.D.N.Y. 2007), rev'd on other grounds, 538 F.3d 97 (2d Cir. 2008) (To violate Section 1591, a "commercial sex act ... [must] be a product of force, fraud or coercion."). consented to enter into a relationship with Mr. Epstein and acted of her own free will during the relationship. Then, when she terminated the relationship, she felt deprived and dissatisfied with the termination of the benefits that came along with dating a billionaire financier. A partner's generosity is not a "commercial sex act" that 18 U.S.C. § 1591 intends to punish. + +# vi. Sections 1592, 1593A, and 1594(a)—(c) do not provide relief + +Neither does the amended complaint state a claim for relief under sections 1952, 1953A, or 1954. On this score, Ms. Maxwell adopts and incorporates the arguments made by Mr. Epstein, Ms. Groff, and MI=. (Doc. # 104-1, p. 20-22; Doc. # Ill, p. 15-16 & n.9—n.10). + +First, cannot state a claim under section 1592 because she has no claim under section 1591. A violation of the former must be predicated on a violation of the latter. 18 U.S.C. § 1592 (requiring proof that the defendant "knowingly destroy[ed], conceal[ed], remove[d], confiscat[ated] or possesse[d] any actual or purported passport" "in the course of violating section ... 1591" or "with the intent to violate section ... 1591"). Here, because ■ **cannot plausibly allege that Ms. Maxwell violated section 1591, (supra Parts** ILA— II.B.v), she cannot seek relief under section 1592 either. + +Second, section 1593A requires proof that a defendant "benefit[ted], financially or by receiving anything of value," from participating in the improper venture. 18 U.S.C. § 1593A. The amended complaint fails to identify even a single financial benefit or thing of value received by Ms. Maxwell. In fact, the only person who benefitted and received a financial benefit from the relationship is + +does not seriously contend otherwise. In fact, in response to the motions to dismiss, all she has to say is this: + +For Section 1593A, pled facts alleging that all Defendants benefited financially from participating in the sex trafficking venture. . . . Thus, the statute provides that "[w]hoever knowingly benefits, financially or by receiving anything of value, from participation" in an illegal venture of the type at issue here has violated the applicable criminal chapter. The Amended Complaint alleges that the Defendants obtained financial and other benefits from their illegal enterprise "up to the present in some form or another." . . . As an illustration, until the Defendants divest themselves of the gains from their illegal enterprise, they remain in violation of the law. Such allegations are all that is required to survive a motion to dismiss. + +4 In any event, section 1593A was enacted in December 2008, after the events in this case. It cannot provide a basis for relief. (Doc. # 104-1. p. 21-22; Doc. # III, p. 16 n.10). + +(Doc. # 115, p. 17–18). Nowhere in this defense of the amended complaint does [REDACTED] even attempt to identify the “gains” Ms. Maxwell allegedly received. As with the amended complaint, “these are merely legal conclusions” without any factual allegations to support them. *See Twombly*, 550 U.S. at 565. + +Finally, section 1594(a)–(c) provides no relief to [REDACTED]. At the time of the events alleged in the amended complaint, section 1594(a) prohibited “attempts” to violate section 1591. The amended complaint does not, however, allege that Ms. Maxwell *attempted* anything unlawful; it alleges she *succeeded* in acting unlawfully. This is not an attempt case. But even if it were, the amended complaint would come up short, because it fails to state a claim for relief under section 1951. *Supra* Parts II.A–II.B.v. + +For their part, sections 1595(b) and (c) have nothing to do with this civil case. Those sections, as they existed in 2006 and 2007, applied to sentencing and forfeiture proceedings in criminal cases for unlawful sexual trafficking. They did not and do not provide any form of relief in this civil action. [REDACTED] ignores this in her response to the motions to dismiss. (Doc. # 115, p. 18). Ignoring this fact is reason enough to dismiss any claims asserted under these provisions. + +### **III. AS TO GHISLAINE MAXWELL, ANY FURTHER AMENDMENT OF THE COMPLAINT WOULD BE FUTILE** + +A comparison of plaintiff’s amended complaint with her deposition testimony demonstrates that [REDACTED] has no factual basis from which to amend and correct her pleading deficiencies. + +First, [REDACTED] claims the promise to get her into F.I.T. went unfulfilled. (Am. Compl. ¶¶ 38-41, 50, 53, 59-62). Yet, [REDACTED] + +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +Second, [REDACTED] Maxwell instructed her how to perform massages on Mr. Epstein in exchange for help with her FIT admission. But she admitted [REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +Third, [REDACTED] alleges she was “ordered” by Ms. Maxwell to have sex with Mr. Epstein. Yet, when asked for [REDACTED] + +[REDACTED] + +--- + +5 At her counsel’s suggestion and behest, [REDACTED] was deposed in February 2017, following the filing of her original Complaint in this case. (Doc. 116-1, Ex. 2). + +Fourth, [REDACTED]. Maxwell, together with the other defendants, "used possession and control of [her] passport" to induce and coerce her into sexual acts. (Am. Compl. ¶ 45, 54) Yet she admits that [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +Finally, [REDACTED] contends that [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +(Doc. #116-1, Ex. 2, *passim* and pp. 179-80). + +No point would be served by allowing [REDACTED] yet another opportunity to re-plead her case. Her amended complaint is deficient as described above, and when she had the opportunity during her deposition to support her allegations with facts, she had nothing of consequence to say. Ms. Maxwell is not and cannot be liable for sex trafficking. + +**IV. THE AMENDED COMPLAINT IS UNTIMELY** + +Whatever the merit of the amended complaint (and there is none), this Court should dismiss it for yet another reason: It is time-barred. + +The motions to dismiss filed by Mr. Epstein, Ms. Goff, and [REDACTED]. Maxwell here adopts and incorporates by reference the arguments made in those motions. (Doc. # 104-1, p. 24–29; Doc. # 111, p. 16–18). In brief, at the time of the events alleged in the amended complaint (late 2006 and early 2007), the applicable statute of limitations was four years. *See* 28 U.S.C. § 1658(a) (2006); *Abarca v. Little*, 54 F. Supp. 3d 1064, 1068 (D. Minn. 2014). The complaint was filed on January 26, 2017, after the expiration of that four-year period. + +In response to the motions to dismiss, invokes the Trafficking Victims Protection Reauthorization Act (TVPRA)—enacted in 2008, and effective June 20, 2009—which provides a ten-year statute of limitations. Pub. L. No. 110-457, § 221(2)(B), 122 Stat. 5044, 5067 (codified at 18 U.S.C. § 1595(c)). argues that because her claim had not expired on June 20, 2009, "that is sufficient to permit an extension of the statute of limitations." (Doc. # 115, p. 22). argument fails, however, because it confuses power with intent. Congress has the power to extend a statute of limitations for unexpired claims, but it did not manifest an intent to do so here. + +Statutory interpretation is always a question of intent. Chickasaw Nation v. United States, 534 U.S. 84, 94 (2001). In turn, a bedrock principle of statutory interpretation is that Congress does not intend its statutes to have retroactive effect absent a clear, express statement to the contrary. INS v. St. Cyr, 533 U.S. 289, 316 (2001); accord Fernandez-Vargas v. , 548 U.S. 30, 37 (2006) ("[A] statute shall not be given retroactive effect unless such construction is required by explicit language or by necessary implication." (quotation omitted)); United States v. Sec. Indus. Bank, 459 U.S. 70, 79-80 (1982) ("The presumption is very strong that a statute was not meant to apply retrospectively, and it ought never to receive such a construction if it is susceptible of any other." (quotation omitted)). "The principle that statutes operate only prospectively ... is familiar to every law student." Sec. Indus. Bank, 459 U.S. at 79. + +Here, all agree that the TVPRA contains no clear statement of intent to apply the amended statute of limitations to claims that had already accrued at the time of its enactment. Nor is there a dispute that claim had accrued by the time of the 2008 amendment. Thus, absent compelling evidence of an intent to the contrary, the 2008 amendment does not apply to this case. See St. Cyr, 533 U.S. at 316. has no such evidence. + +In fact, the available evidence points to precisely the opposite conclusion: Congress intended the amended statute of limitations to apply only to claims accruing after its effective date. "[I]n determining a statute's temporal reach, generally, [the] normal rules of construction apply," including "other construction rules" that may "remove the possibility of retroactivity." Lindh v. , 521 U.S. 320, 326 (1997). In this case, if Congress had intended such a result, it knew full well how to extend a limitations period for claims that have already accrued but not yet expired. See Stronger v. California, 539 U.S. 607, 616-17 (2003) (passing a law expressly "extending unexpired limitations periods" is a "tailored approach to extending limitations periods ... taken in modern statutes"). All Congress had to do was utilize language similar to that which it has employed many times before. See, e.g., 18 U.S.C. § 3293 (notes on effective date of 1990 amendment) ("The amendments made by subsection (a) shall apply to any offense committed before the date of the enactment of this section, if the statute of limitations applicable to that offense had not run as of such date."); id. (notes on effect of 1989 amendment) ("(3) EFFECT OF AMENDMENTS ON OFFENSES FOR WHICH THE CURRENT PERIOD OF LIMITATIONS HAD NOT RUN.—The amendments made by this subsection shall apply to an offense committed before the effective date of this section, if the statute of limitations applicable to that offense under this chapter had not run as of such date."). But Congress deliberately chose not to do so when it reauthorized the TVPA in 2008, thereby confirming its intent not to extend the limitations period of accrued but not-yet-expired claims . At the very least, because Congress decided not to include such standard language in the TVPRA, cannot overcome the presumption against retroactivity. + +pins her hopes on one case from the Eastern District of New York, Lama v. Malik, which she mischaracterizes as "Second Circuit precedent ... directly on point." (Doc. + +#115, p. 22 (emphasis added)). That decision applied the 2008 amendment to a claim accruing before the amendment was enacted. 192 F. Supp. 3d 313, 321 (E.D.N.Y 2016). This Court should decline to follow the decision in Lama, however, because it misapplied the Supreme Court's decision in Landgraf v. US! Film Products, 511 U.S. 244 (1994). + +Under Landgraf, "the court's first task is to determine whether Congress has expressly prescribed the statute's proper reach." Id. at 280. The Lama court concluded Congress had not expressly prescribed the temporal reach of the 2008 amendment because it did not contain an express provision precluding retroactive application. 192 F. Supp. 3d at 321-22. But that reasoning flips the analysis on its head. The proper starting point is a presumption against retroactivity, rebuttable only if there is an express statement providing for retroactive application. The improper starting point, the one employed by the court in Lama, is a presumption in favor of retroactivity, rebuttable only if there is an express statement precluding retroactive application. And as explained above, cannot overcome the presumption against retroactivity in this case because Congress chose not to employ readily available, time-tested statutory language authorizing an extension of the statute of limitations for claims that had already accrued but not yet expired. Properly employed, therefore, the interpretive framework of Landgraf dictates a conclusion that "Congress has expressly prescribed the [TVPRA's] proper reach"—it applies only to claims accruing after it became effective. 51 U.S. at 280. Accordingly, the ten-year statute of limitations in the TVPRA does not apply to case. + +But even if the ten-year statute of limitations were to apply, complaint is time-barred. Because filed her complaint on January 26, 2017, she cannot state a claim for relief based on conduct occurring more than ten years before that date, i.e., January 26, 2007. That reality renders irrelevant the factual allegations in the first sixty paragraphs of the + +amended complaint, which allege conduct before and including January 2007. In turn, nothing in the six paragraphs that follow (which allege conduct after January 2007) supports a claim under any section of the TVPA. In particular, [REDACTED], voluntarily and of her own free will, left the United States in January 2007 and returned in February 2007. (Am. Compl. ¶ 61). Because [REDACTED] had the “physical freedom” to travel outside the “control” of Mr. Epstein, she cannot state a claim based on anything after her voluntary departure in January 2007. *See, e.g., Oluch v. Orina*, 101 F. Supp. 3d 325, 330 (S.D.N.Y. 2015) (Section 1595 claim accrued when plaintiff first left defendant’s home); *Abarca*, 54 F. Supp. 3d at 1070 (Section 1595 claim accrued when plaintiff traveled home to Mexico and had “physical freedom”). + +To be sure, as explained in the motions to dismiss filed by Mr. Epstein, Ms. Groff, and [REDACTED] might have had accrued no later than January 2007, and therefore expired before she filed the first complaint on January 26, 2017. (Doc. # 104-1, p. 24-29; Doc. # 111, p. 16-18). The amended complaint alleges that in January 2017, [REDACTED] went on a “recruiting” trip to South Africa to find an administrative assistant for Mr. Epstein. [REDACTED] says she refused to complete this assignment, knowing that any recruit would not be given a bona fide job. Instead, the recruit would be forced to provide Mr. Epstein with sexual favors, like [REDACTED] claims she was forced to do. These allegations demonstrate that, at least by the time of the January 2007 trip to South Africa, [REDACTED] was no longer relying on any promises from Mr. Epstein or Ms. Maxwell of career or educational advancement. According to [REDACTED] herself, she knew full well of Defendants alleged scheme to traffick her for sex. Because her complaint was filed more than ten years later, it is untimely. + +[REDACTED] + +[REDACTED] + +[REDACTED] + +Any way you view it, therefore, [REDACTED] filed her complaint after the statute of limitations expired. This Court should dismiss the amended complaint with prejudice. + +**V. THIS COURT IS NOT THE PROPER FORUM** + +As explained in the previously filed motions to dismiss, which Ms. Maxwell incorporates by reference, the amended complaint fails to establish the necessary “suit-related conduct” in New York. *See Walden v. Fiore*, 134 S. Ct. 1115, 1121–22 (2014). The acts allegedly giving rise to liability occurred outside the applicable statute of limitations, whether it be four years or ten years. (Doc. # 104-1, p. 24–30; Doc. # 111, p. 18). As a result, [REDACTED] allegations against Ms. Maxwell do not “arise out of or relate to” to Ms. Maxwell’s contacts with New York, as is required to support jurisdiction. *See Gucci Am., Inc. v. Weixing Li*, 768 F.3d 122, 141 (2d Cir. 2014). Additionally, because the amended complaint does not allege that Ms. Maxwell is domiciled in New York, this Court cannot exercise general jurisdiction over her in this case. Accordingly, this Court lacks personal jurisdiction over Ms. Maxwell and venue is improper. + +**CONCLUSION** + +For these reasons, Ms. Maxwell respectfully requests that this Court dismiss this case with prejudice. + +Dated: March 13, 2018. + +Respectfully submitted, + +/s/ Laura A. Menninger + +Laura A. Mennen lir (LK,) + +HADDON, AND P.C. + +150 East 10 Avenue + +Denver, CO 80203 + +Phone: 303.831.7364 + +Fax: 303.832.2628 + +lmenninger@hmflaw.com + +Attorneys for Ghislaine Maxwell + +#### CERTIFICATE OF SERVICE + +I certify that on March 13, 2018, I served the accompanying Memorandum of Law in Support of Ghislaine Maxwell's Motion to Dismiss on the following counsel of record: + +Sigrid S. McCawley Meredith Boles, Schiller & Flexner, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com + +J. POTTINGER LLC 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL. 33301 brad@pathtojustice.com + +John E. Stephenson, Jr. Jonathan D. Parente Alexander S. Lorenzo ALSTON & BIRD, LLP 90 Park Avenue New York, NY 10016 john.stephenson@alston.com jonathan.parente@alston.com alexander.lorenzo@alston.com + +Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu + +Michael C. Justin Y.K. Michael A. Keou h STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoe.com jchu@steptoe.com mkeough@steptoe.com + +Is! Nicole Nicole \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820174/EFTA02820174.metadata.json b/marker2/court-jane-doe-43/EFTA02820174/EFTA02820174.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f605f78ebb93e5d8c89f65a62c479aeef171d9c8 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820174/EFTA02820174.metadata.json @@ -0,0 +1,1850 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820174.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 31, + "chars": 53875, + "elapsed_seconds": 11.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.168, + 70.47 + ], + [ + 418.4738464355469, + 70.47 + ], + [ + 418.4738464355469, + 100.10302734375 + ], + [ + 192.168, + 100.10302734375 + ] + ] + }, + { + "title": "MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE MAXWELL'S \nMOTION TO DISMISS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 74.66399999999999, + 387.18 + ], + [ + 537.6165771484375, + 387.18 + ], + [ + 537.6165771484375, + 420.5009460449219 + ], + [ + 74.66399999999999, + 420.5009460449219 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 238.06800000000004, + 71.28 + ], + [ + 374.134521484375, + 71.28 + ], + [ + 374.134521484375, + 86.2330322265625 + ], + [ + 238.06800000000004, + 86.2330322265625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 229.5, + 71.28 + ], + [ + 383.5723571777344, + 71.28 + ], + [ + 383.5723571777344, + 86.2330322265625 + ], + [ + 229.5, + 86.2330322265625 + ] + ] + }, + { + "title": "Cases", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 68.544, + 98.82 + ], + [ + 105.0146484375, + 98.82 + ], + [ + 105.0146484375, + 113.9830322265625 + ], + [ + 68.544, + 113.9830322265625 + ] + ] + }, + { + "title": "Statutes", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 68.544, + 307.79999999999995 + ], + [ + 117.06278991699219, + 307.79999999999995 + ], + [ + 117.06278991699219, + 322.56353759765625 + ], + [ + 68.544, + 322.56353759765625 + ] + ] + }, + { + "title": "Rules", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 68.544, + 423.63 + ], + [ + 104.31626892089844, + 423.63 + ], + [ + 104.31626892089844, + 438.80352783203125 + ], + [ + 68.544, + 438.80352783203125 + ] + ] + }, + { + "title": "INTRODUCTION", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 254.59199999999998, + 98.82 + ], + [ + 356.96490478515625, + 98.82 + ], + [ + 356.96490478515625, + 114.363037109375 + ], + [ + 254.59199999999998, + 114.363037109375 + ] + ] + }, + { + "title": "FACTUAL BACKGROUND", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 228.276, + 346.68 + ], + [ + 383.79827880859375, + 346.68 + ], + [ + 383.79827880859375, + 362.9830322265625 + ], + [ + 228.276, + 362.9830322265625 + ] + ] + }, + { + "title": "I. 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-0,0 +1,107 @@ +# EXHIBIT B + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO.:08-CV-80736-KAM + +JANE DOE I and JANE DOE 2, + +Petitioners, + +vs. + +UNITED STATES OF AMERICA, + +Respondent. + +#### ORDER DENYING PETITIONERS' MOTION TO JOIN UNDER RULE 21 AND MOTION TO AMEND UNDER RULE 15 + +This cause is before the Court on Jane Doe 3 and Jane Doe 4's Corrected Motion Pursuant to Rule 21 for Joinder in Action ("Rule 21 Motion") (DE 280), and Jane Doe 1 and Jane Doe 2's Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners ("Rule 15 Motion") (DE 311). Both motions are ripe for review. For the following reasons, the Court concludes that they should be denied. + +## I. Background + +This is an action by two unnamed petitioners, Jane Doe 1 and Jane Doe 2, seeking to prosecute a claim under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771. (DE 1). Generally, they allege that the respondent Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein, who subjected them to various sexual crimes while they were minors. (Id.). Petitioners initiated this action in July 2008. (K.). + +On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280). Petitioners (Jane Doe I and Jane Doe 2) support the Rule 21 Motion. (K. at I I). Jane Doe 3 and Jane Doe 4 argue that they "have suffered the same violations of their rights under the [CVRA] as the" Petitioners, and they "desire to join in this action to vindicate their rights as well." (Id. at I). The Government vehemently opposes joinder under Rule 21. (DE 290). The Government argues that Rule 15 is the proper procedural device for adding parties to an action, not Rule 21. at I). + +"[G]ut of an abundance of caution," Petitioners filed a motion to amend their petition under Rule 15, conforming the petition to the evidence and adding Jane Doe 3 and Jane Doe 4 as petitioners. (DE 311 at 2). The Government opposes the Rule 15 Motion as well. (DE 314). Among other things, the Government argues that amending the petition to include Jane Doe 3 and Jane Doe 4 should be denied because of their undue delay in seeking to join the proceedings, and the undue prejudice that amendment will cause. (kb. + +After considering the parties' submissions and the proposed amended petition, the Court finds that justice does not require amendment in this instance and exercises its discretion to deny the amendment. + +# II. Discussion + +"The decision whether to grant leave to amend a complaint is within the sole discretion of the district court." Laurie v. Ala. Ct. Crim. Apps., 256 F.3d 1266, 1274 (11th Cir. 2001). "The court should freely give leave when justice so requires." Fed. R. Civ. P. 15(a)(2). Justice does not require amendment in several instances, "includ[ing] undue delay, bad faith, dilatory motive + +on the pan of the movant, . . . undue prejudice to the opposing party by virtue of allowance of the amendment, [and] futility of amendment?" Laurie, 256 F.3d at 1274 (quoting Foman v. 371 U.S. 178, 182 (1962)). In addition to considering the effect of amendment on the parties, the court must consider "the importance of the amendment on the proper determination of the merits of a dispute." 6 & Fed. Prac. & Fed. P. § 1488, p. 814 (3d ed. 2010). Justice does not require amendment where the addition of parties with duplicative claims will not materially advance the resolution of the litigation on the merits. See Herring v. Delta Air Lines, Inc., 894 F.2d 1020, 1024 (9th Cir. 1989). + +# A. Rule 21 Motion + +Jane Doe 3 and Jane Doe 4's first attempt to join in this proceeding was brought under Rule 21. (DE 280). "If parties seek to add a party under Rule 21, courts generally use the standard of Rule 15, governing amendments to pleadings, to determine whether to allow the addition." 12 & Fed. Prac. & Fed. P., p. 432 (3d ed. 2013); see also Galustian v. Peter, 591 F.3d 724, 729-30 (4th Cir. 2010) (collecting cases and noting that Rule 15(a) applies to amendments seeking to add parties); v. U.S. West, Inc., 3 F.3d 1357, 1365 (10th Cir. 1993) ("A motion to add a party is governed by Fed. R. Civ. P. 15(a) ...."). + +Rule 21, "Misjoinder and Non-joinder of Parties," provides the court with a tool for correcting the "misjoinder" of parties that would otherwise result in dismissal. Fed. R. Civ. P. 21. Insofar as Rule 21 "relates to the addition of panics, it is intended to permit the bringing in of a person, who through inadvertence, mistake or for some other reason, had not been made a party and whose presence as a party is later found necessary or desirable." United States v. Com. Bank of N. Am., 31 F.R.D. 133, 135 (S.D.N.Y. 1962) (internal quotation marks omitted). + +In their Rule 21 Motion, Jane Doe 3 and Jane Doe 4 do not claim that they were omitted from this proceeding due to any "inadvertence" or "mistake" by Petitioners; rather, they seek to join this proceeding as parties that could have been permissively joined in the original petition under Rule 20 ("Permissive Joinder of Parties"). As courts generally use the standards of Rule 15 to evaluate such circumstances, the Court will consider the joinder issue as presented in the Rule 15 Motion.' The Court will consider the arguments presented in the Rule 21 Motion as if they are set forth in the Rule 15 Motion as well. Because the arguments are presented in the Rule 15 Motion (and because the Court is denying the Rule 15 Motion on its merits, as discussed below), the Rule 21 Motion will be denied. + +The Court also concludes that portions of the Rule 21 Motion—and related filings—should be stricken from the record. Pending for this Court's consideration is a Motion for Limited Intervention filed by Alan M. Dershowitz, who seeks to intervene to "strike the outrageous and impertinent allegations made against him and [to) request[] a show cause order to the attorneys that have made them." (DE 282 at 1). The Court has considered Mr. Dershowitz's arguments, but it finds that his intervention is unnecessary as Federal Rule of Civil Procedure 12(f) empowers the Court "on its own" to "strike from a pleading an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter." Fed. R. Civ. P. 12(f). + +Petitioners' Rule 21 Motion consists of relatively little argumentation regarding why the Court should permit them to join in this action: they argue that (I ) they were sexually abused by + +The Court notes that, regardless of which motion it considers, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter No. 08-cv-478 FJS ATB, 2010 WL 4774238, at \*5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). + +Jeffrey Epstein, and (2) the Government violated their CVRA rights by concealing the nonprosecution agreement with them. (DE 280 at 3; see id. at 7-8). However, the bulk of the Rule 21 Motion consists of copious factual details that Jane Doe 3 and Jane Doe 4 "would prove" "[i]f allowed to join this action." (1. at 3, 7). Specifically, Jane Doe 3 proffers that she could prove the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein sexually trafficked her to several high-profile non-party individuals, "including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders." (a. at 3-6). She names several individuals, and she offers details about the type of sex acts performed and where they took place. id. at 5).2 + +At this juncture in the proceedings, these lurid details are unnecessary to the determination of whether Jane Doe 3 and Jane Doe 4 should be permitted to join Petitioners' claim that the Government violated their rights under the CVRA. The factual details regarding with whom and where the Jane Does engaged in sexual activities are immaterial and impertinent to this central claim (i.e., that they were known victims of Mr. Epstein and the Government owed them CVRA duties), especially considering that these details involve non-parties who are not related to the respondent Government. These unnecessary details shall be stricken. + +The original Rule 21 Motion (DE 279) shall be stricken in its entirety, as it is wholly superseded by the "corrected" version of the Rule 21 Motion (DE 280). From the corrected Rule 21 Motion, the Court shall strike all factual details regarding Jane Doe 3 between the following sentences: "The Government then concealed from Jane Doe #3 the existence of its NPA from + +2 Jane Doe 4's proffer is limited to sexual acts between Mr. Epstein and herself. DE 280 at 7-8). + +Jane Doe #3, in violation of her rights under the CVRA" (tl. at 3); and "The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the NPA" OA at 6). As none of Jane Doe 4's factual details relate to non-parties, the Court finds it unnecessary to strike the portion of the Rule 21 Motion related to her circumstances. Regarding the Declaration in support of Petitioners' response to Mr. Dershowitz's motion to intervene (DE 291-1), the Court shall strike paragraphs 4, 5, 7, 11, 13, 15, 19 through 53, and 59, as they contain impertinent details regarding non-parties. Regarding the Declaration of Jane Doe 3 in support of the Rule 21 Motion (DE 310-1), the Court shall strike paragraphs 7 through 12, 16, 39, and 49, as they contain impertinent details regarding nonparties. Jane Doe 3 is free to reassert these factual details through proper evidentiary proof, should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a matter presented for the Court's consideration. + +As mentioned, Mr. Dershowitz moves to intervene "for the limited purposes of moving to strike the outrageous and impertinent allegations made against him and requesting a show cause order to the attorneys that have made them." (DE 282 at I). As the Court has taken it upon itself to strike the impertinent factual details from the Rule 21 Motion and related filings, the Court concludes that Mr. Derschowitz's intervention in this case is unnecessary. Accordingly, his motion to intervene will be denied as moot.' Regarding whether a show cause order should + +This also moots Mr. Dershowitz's Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention. (DE 317). Denying Mr. Dershowitz's motion to intervene also renders moot Petitioners' motion (DE 292) to file a sealed document supporting its response to Mr. Dershowitz's motion. It will accordingly be denied as moot, and DE 293 (the sealed response) will be stricken from the record. + +issue, the Court finds that its action of striking the lurid details from Petitioners' submissions is sanction enough. However, the Court cautions that all counsel are subject to Rule 11's mandate that all submissions be presented for a proper purpose and factual contentions have evidentiary support, Fed. R. Civ. P. 11(b)(1) and (3), and that the Court may, on its own, strike from any pleading "any redundant, immaterial, impertinent, or scandalous matter," Fed. R. Civ. P. 12(t). + +## B. Rule 15 Motion + +Between their two motions (the Rule 21 Motion and Rule 15 Motion), Jane Doe 3 and Jane Doe 4 assert that "they desire to join in this action to vindicate their rights [under the CVRA] as well." (DE 280 at 1). Although Petitioners already seek the invalidation of Mr. Epstein's non-prosecution agreement on behalf of all "other similarly-situated victims" (DE 189 at 1; DE 311 at 2, 12, 15, 18-19), Jane Doe 3 and Jane Doe 4 argue that they should be fellow travelers in this pursuit, lest they "be forced to file a separate suit raising their claims" resulting in "duplicative litigation" (DE 280 at 11). The Court fmds that justice does not require adding new parties this late in the proceedings who will raise claims that are admittedly "duplicative" of the claims already presented by Petitioners. + +The Does' submissions demonstrate that it is entirely unnecessary for Jane Doe 3 and Jane Doe 4 to proceed as parties in this action, rather than as fact witnesses available to offer relevant, admissible, and non-cumulative testimony. (See, e.g., DE 280 at 2 (Jane Doe 3 and Jane Doe 4 "are in many respects similarly situated to the current victims"), 9 ("The new victims will establish at trial that the Government violated their CVRA rights in the same way as it violated the rights of the other victims."), 10 (Jane Doe 3 and Jane Doe 4 "will simply join in motions that the current victims were going to file in any event."), 11 (litigating Jane Doe 3 and + +Jane Doe 4's claims would be "duplicative"); DE 298 at 1 n.1 ("As promised . . . Jane Doe No. 3 and Jane Doe No. 4 do not seek to expand the number of pleadings filed in this case. If allowed to join this action, they would simply support the pleadings already being filed by Jane Doe No. 1 and Jane Doe No. 2."); DE 311 at 5 n.3 ("[A]ll four victims (represented by the same legal counsel) intend to coordinate efforts and avoid duplicative pleadings."), 15 (Jane Doe 3 and Jane Doe 4 "challenge the same secret agreement—i.e., the NPA that the Government executed with Epstein and then concealed from the victims. This is made clear by the proposed amendment itself, in which all four victims simply allege the same general facts.")). As the Does argue at length in their Rule 15 Motion, Jane Doe l's original petition "specifically allege[s] that the Government was violating not only her rights but the rights of other similarly-situated victims." (DE 311 at 2). The Court fails to see why the addition of "other similarly-situated victims" is now necessary to "vindicate their rights as well." (DE 280 at 1). + +Of course, Jane Doe 3 and Jane Doe 4 can participate in this litigated effort to vindicate the rights of similarly situated victims—there is no requirement that the evidentiary proof submitted in this case come only from the named parties. Petitioners point out as much, noting that, regardless of whether this Court grants the Rule 15 Motion, "they will call Jane Doe No. 3 as a witness at any trial." (DE 311 at 17 n.7). The necessary "participation" of Jane Doe 3 and Jane Doe 4 in this case can be satisfied by offering their properly supported—and relevant, admissible, and non-cumulative—testimony as needed, whether through testimony at trial (m DE 280 at 9) or affidavits submitted to support the relevancy of discovery requests° (m + +The non-party Jane Does clearly understand how to submit affidavits. DEs 291-1, 310-1). + +id. at 10). Petitioners do not contend that Jane Doe 3 and Jane Doe 4's "participation in this case" can only be achieved by listing them as parties. + +As it stands under the original petition, the merits of this case will be decided based on a determination of whether the Government violated the rights of Jane Doe 1, Jane Doe 2, and all "other similarly situated victims" under the CVRA. Jane Doe 3 and Jane Doe 4 may offer relevant, admissible, and non-cumulative evidence that advances that determination, but their participation as listed parties is not necessary in that regard. See Herring, 894 F.2d at 1024 (District court did not abuse its discretion by denying amendment where "addition of more plaintiffs . . . would not have affected the issues underlying the grant of summary judgment."); cf Arthur v. Stem, 2008 WL 2620116, at \*7 (S.D. Tex. 2008) (Under Rule 15, "courts have held that leave to amend to assert a claim already at issue in [another lawsuit] should not be granted if the same parties are involved, the same substantive claim is raised, and the same relief is sought.").5 And, as to Jane Doe 4 at least, adding her as a party raises unnecessary questions about whether she is a proper party to this action .° + +Petitioners also admit that amending the petition to conform to the evidence—by including references to the non-prosecution agreement itself—is "unnecessary" as the "existing petition is broad enough to cover the developing evidence in this case." (DE 311). The Court + +5 The Court expresses no opinion at this time whether any of the attestations made by Jane Doe 3 and Jane Doe 4 in support of their motion will be relevant, admissible, and noncumulative. + +6 The Government contends that Jane Doe 4 is not a true "victim" in this case because she was not known at the time the Government negotiated the non-prosecution agreement, and accordingly she was not entitled to notification rights under the CVRA. DE 290 at 10). Any "duplicative" litigation filed by Jane Doe 4 would necessarily raise the issue of whether she has standing under the CVRA under these circumstances. + +agrees, and it concludes that justice does not require amending the petition this late in the proceedings. + +## HI. Conclusion + +Accordingly, it is hereby ORDERED AND ADJUDGED as follows: the Rule 21 Motion (DE 280) is DENIED; the Rule 15 Motion (DE 311) is DENIED; Intervenor Dershowitz's Motion for Limited Intervention (DE 282) and Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention (DE 317) are DENIED AS MOOT; Petitioners' Motion to Seal (DE 292) is DENIED AS MOOT; the following materials are hereby + +STRICKEN from the record: + +- DE 279, in its entirety. +- DE 280, all sentences between the following sentences: "The Government then concealed from Jane Doe #3 the existence of its NPA from Jane Doe #3, in violation of her rights under the CVRA" (DE 280 at 3); and "The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the NPA" (DE 280 at 6). +- DE 291-1, paragraphs 4, 5, 7, 11, 13, 15, 19 through 53, and 59. +- DE 310-1, paragraphs 7 through 12, 16, 39, and 49. +- DE 293, in its entirety. + +DONE AND ORDERED in at West Palm Beach, Palm l3each County, + +Florida, this 6th day of April, 2015. + +KENNETH A. 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a/marker2/court-jane-doe-43/EFTA02820217/EFTA02820217.md b/marker2/court-jane-doe-43/EFTA02820217/EFTA02820217.md new file mode 100644 index 0000000000000000000000000000000000000000..113f89330769e3b06f12948875e5db0e4322040e --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820217/EFTA02820217.md @@ -0,0 +1,51 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +X + +Plaintiff, v. + +17-cv-00616-JGK + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF, and NATALYA + +Defendants. + +X + +## Declaration of Laura t. Nlenninger in Support of Defendant Nlotion to Disinis,, + +I, Laura A. Menninger, declare as follows: + +1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, & P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell's Motion to Dismiss. + +2. Attached as Sealed Exhibit A is a true and correct copy + +3. Attached as Exhibit B is a true and correct copy of the April 7, 2015 Order of the U.S. District Court for the Southern District of Florida denying Petitioners' Motion to Join under Rule 21 and Motion to Amend under Rule 15 in Case No. 9:08-cv-80736-KAM. + +4. Consistent with the Confidentiality Stipulation and Order, (Doc. # 100), Ms. + +Maxwell has redacted her Memorandum of law in Support of her Motion to Dismiss and moved to seal hereto Exhibit A. + +I declare under penalty of perjury that the foregoing is true and correct. + +Dated: March 13, 2018. + +s/ Laura A. Menninger + +Laura A. Menninger + +## CERTIFICATE OF SERVICE + +I certify that on March 13, 2018, I served the accompanying Declaration of Laura A. Menninger in Support of Defendant Ghislaine Maxwell's Motion to Dismiss on the following counsel of record: + +Sigrid S. McCawley Meredith Boies, Schiller & Flexner, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com + +J. POTTINGER LLC 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com + +John E. Stephenson, Jr. Jonathan D. Parente Alexander S. Lorenzo ALSTON & BIRD, LLP 90 Park Avenue New York, NY 10016 john.stephenson@alston.com jonathan.parente@alston.com alexander.lorenzo@alston.com + +Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu + +Michael C. r Justin Y.K. Michael A. Keou h STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoe.com jchu@steptoe.com mkeough@steptoe.com + +Is/ Nicole Nicole \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820217/EFTA02820217.metadata.json b/marker2/court-jane-doe-43/EFTA02820217/EFTA02820217.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3da11267dd6117846e0e2ec9aa194ebfd67050bc --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820217/EFTA02820217.metadata.json @@ -0,0 +1,204 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820217.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2282, + "elapsed_seconds": 0.82, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 193.392, + 71.28 + ], + [ + 418.5074768066406, + 71.28 + ], + [ + 418.5074768066406, + 100.10302734375 + ], + [ + 193.392, + 100.10302734375 + ] + ] + }, + { + "title": "Declaration of Laura t. 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Menninger + +150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 vtAv.hmecnv.com Imenningenthmflaw.com + +March 13, 2018 + +## Via ECF + +Hon. John G. Koeltl United States District Judge United States District Court Daniel Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 + +Re: Jane Doe 43 v. Jeffrey Epstein, et at, 17-cv-00616 (16K) + +Dear Judge Koeltl: + +This letter motion seeks the Court's permission to file an un-redacted copy of Defendant Ghislaine Maxwell's Motion to Dismiss, and Exhibit A to the Declaration of Laura A. Menninger in Support of the Motion to Dismiss, under seal pursuant to paragraph 1(c) of the Court's Confidentiality Stipulation and Order (Doc. #100) dated January 19, 2018. + +Ms. Maxwell has redacted any references to deposition exhibits as provided in the Court's Confidentiality Stipulation and Order (Doc. #100). Accordingly, Ms. Maxwell respectfully requests that she may file her unredacted brief and exhibit under seal. + +Respectfully submitted, + +HADDON, AND P.C. + +Is/ Laura A. Menninger + +Laura A. Menninger + +Hon. John G. Koeltl March 13, 2018 Page 2 + +## CERTIFICATE OF SERVICE + +I certify that on March 13 2018, I served the accompanying Letter Motion on the following counsel of record: + +Sigrid S. McCawley Meredith Boles, Schiller & Flexner, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com + +POTT1NGER LLC 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@ pathtojustice.com + +John E. Stephenson, Jr. Jonathan D. Parente Alexander S. Lorenzo ALSTON & BIRD, LLP 90 Park Avenue New York, NY 10016 john.stephenson@alston.com jonathan.parente@alston.com alexander.lorenzo@alston.com + +Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu + +Michael C. r Justin Y.K. Michael A. Karim STEPTOE & ,LLP 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoe.com jchu@steptoe.com mkeough@steptoe.com + +/s/ Nicole Nicole \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820220/EFTA02820220.metadata.json b/marker2/court-jane-doe-43/EFTA02820220/EFTA02820220.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cb9fb65a3ec9f3d8a5594f2383f4ca00d7513f2e --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820220/EFTA02820220.metadata.json @@ -0,0 +1,153 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820220.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2082, + "elapsed_seconds": 0.82, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Via ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 123.62400000000002, + 213.03000000000003 + ], + [ + 174.42080688476562, + 213.03000000000003 + ], + [ + 174.42080688476562, + 227.60302734375 + ], + [ + 123.62400000000002, + 227.60302734375 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 250.308, + 104.49 + ], + [ + 415.94989013671875, + 104.49 + ], + [ + 415.94989013671875, + 119.2330322265625 + ], + [ + 250.308, + 119.2330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 35 + ], + [ + "Text", + 12 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 86 + ], + [ + "Line", + 43 + ], + [ + "Text", + 8 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820220" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820220/_page_0_Picture_1.jpeg b/marker2/court-jane-doe-43/EFTA02820220/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ca2d531f5ac112bfc058a22b3edb14c256832cc0 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820220/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:57bd0f4131155de657db4798f26a5a8749bf15ee88d4809244fc2dc7817c8fae +size 6380 diff --git a/marker2/court-jane-doe-43/EFTA02820222/EFTA02820222.md b/marker2/court-jane-doe-43/EFTA02820222/EFTA02820222.md new file mode 100644 index 0000000000000000000000000000000000000000..c1a0edd5488e905c5d038c2379bdb70dd4083433 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820222/EFTA02820222.md @@ -0,0 +1,25 @@ +March 28, 2018 + +## VIA ECF + +Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 + +Dear Judge Koeltl: + +We are counsel for Jeffrey Epstein and Lesley Groff in the above-referenced matter and write to request the Court set a briefing schedule as set forth below. This schedule has been agreed to by the parties and will allow for the completion of briefing on all of the three motions to dismiss by May 21, 2018. + +| Date | Paper Due | +|----------------|------------------------------------------| +| April 23, 2018 | Replies by defendants Epstein, Groff and | +| May 7, 2018 | Opposition to defendant Maxwell's motion | +| May 21, 2018 | Reply by defendant Maxwell | + +We therefore respectfully request the Court to set the above briefing schedule as agreed to by the parties. + +Respectfully submitted, + +t QCfitt-• + +Michael C. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820222/EFTA02820222.metadata.json b/marker2/court-jane-doe-43/EFTA02820222/EFTA02820222.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..220fdd8b32bf8cb8354e7e75fd9e482f93f4b236 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820222/EFTA02820222.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820222.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1013, + "elapsed_seconds": 0.72, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 67.32000000000001, + 214.4815673828125 + ], + [ + 124.17080688476562, + 214.4815673828125 + ], + [ + 124.17080688476562, + 230.84999999999997 + ], + [ + 67.32000000000001, + 230.84999999999997 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 33 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 4 + ], + [ + "SectionHeader", + 1 + ], + [ + "Table", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820222" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820223/EFTA02820223.md b/marker2/court-jane-doe-43/EFTA02820223/EFTA02820223.md new file mode 100644 index 0000000000000000000000000000000000000000..008092a6599890cf18dc6e4d94d558ca29181d94 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820223/EFTA02820223.md @@ -0,0 +1,37 @@ +1114 Avenue of the Americas Now York, NY 10036 212 506 3900 male wwwoteptoe.com + +VIA EC\*? + +Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +![](_page_0_Picture_5.jpeg) + +USDC SONY DOCUMENT ELECTRONICALLY FILED + +DOCU DATE a — + +., \_ • + +March 28, 2018 + +APPLICATION GRANTED SO ORDERED + +ohn G. Koelil, U.S.D.J. + +Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 + +Dear Judge Koeltl: + +We are counsel for Jeffrey Epstein and Lesley Groff in the above-referenced matter and write to request the Court set a briefing schedule as set forth below. This schedule has been agreed to by the parties and will allow for the completion of briefing on all of the three motions to dismiss by May 21, 2018. + +| Date | Paper Due | +|----------------|------------------------------------------| +| April 23, 2018 | Replies by defendants Epstein, Groff and | +| May 7, 2018 | Opposition to defendant Maxwell's motion | +| May 21, 2018 | Reply by defendant Maxwell | + +We therefore respectfully request the Court to set the above briefing schedule as agreed to by the parties. + +Respectfully submitted, + +Michael C. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820223/EFTA02820223.metadata.json b/marker2/court-jane-doe-43/EFTA02820223/EFTA02820223.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a3eb2a73e8d7b0d3adf63e19e335cbef02092957 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820223/EFTA02820223.metadata.json @@ -0,0 +1,68 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820223.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1230, + "elapsed_seconds": 1.05, + "image_assets": [ + "_page_0_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 84 + ], + [ + "Line", + 42 + ], + [ + "Text", + 16 + ], + [ + "PageHeader", + 4 + ], + [ + "Picture", + 1 + ], + [ + "Table", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820223" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820223/_page_0_Picture_5.jpeg b/marker2/court-jane-doe-43/EFTA02820223/_page_0_Picture_5.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..7d0bf3173eaf4791ecbc0a57496dc319a17a4a53 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820223/_page_0_Picture_5.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4b85f172cd49946bed58867e78022931c38cbc8d6a09664ed65c79545736bae4 +size 4391 diff --git a/marker2/court-jane-doe-43/EFTA02820224/EFTA02820224.md b/marker2/court-jane-doe-43/EFTA02820224/EFTA02820224.md new file mode 100644 index 0000000000000000000000000000000000000000..9b4c3c64d9f5fb45c3261f513248262f4abc0eb6 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820224/EFTA02820224.md @@ -0,0 +1,27 @@ +Michael C 212 506 3955 mmillen2steptoe.com + +1114 Avenue of the Americas New York, NY 10036 212 506 3900 main www.steptoe.com + +![](_page_0_Picture_3.jpeg) + +April 20, 2018 + +## VIA ECF + +Hon. John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-cv-616 + +Dear Judge Koeltl: + +We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") in the abovereferenced matter and write to request permission to file a15-page reply brief in support of Defendants' supplemental motion to dismiss. + +The brief that Defendants plan to submit will provide rounds for dismissal that are applicable not olio Defendants, but also to defendant ('e). We understand that plans to adopt certain of the arguments to be set forth in Defendants' brief, instead of repeating them in her brief. We further understand that will separately file a brief, but primarily to set forth additional grounds for dismissal that are applicable to her. We expect that the total pages of the two briefs will be no more than 20 pages. + +Defendants and will file their reply briefs on April 23, 2018 pursuant to the Court's Order of March 29, 2018 (ECF#124). + +Defendants therefore respectfully request permission t y brief. + +Michael C. Counsel for Defendants Jeffrey + +Epstein and Lesley Groff \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820224/EFTA02820224.metadata.json b/marker2/court-jane-doe-43/EFTA02820224/EFTA02820224.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4793bdaf01fb0e605c85a6674b8198b2c07e46c5 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820224/EFTA02820224.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820224.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1375, + "elapsed_seconds": 0.81, + "image_assets": [ + "_page_0_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 62.424, + 192.77999999999997 + ], + [ + 117.91460418701172, + 192.77999999999997 + ], + [ + 117.91460418701172, + 205.74 + ], + [ + 62.424, + 205.74 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 293 + ], + [ + "Line", + 36 + ], + [ + "Text", + 14 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820224" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820224/_page_0_Picture_3.jpeg b/marker2/court-jane-doe-43/EFTA02820224/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..fbc704717e36052c49d79709692aa06d3afeea6e --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820224/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:bc209702e81994e64ac9362e151b25c077a4c7f30da2144c4e13233d0e6483f2 +size 4943 diff --git a/marker2/court-jane-doe-43/EFTA02820225/EFTA02820225.md b/marker2/court-jane-doe-43/EFTA02820225/EFTA02820225.md new file mode 100644 index 0000000000000000000000000000000000000000..0708486c76f906a369069f50f74b9078ddc37f62 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820225/EFTA02820225.md @@ -0,0 +1,29 @@ +Michael C 212 506 3055 rnmIlforesteploo.com + +1114 Avenue of Itto An entes New York. NY 10036 212 506 3900 main MOW CONDO corn + +4(1191( John G. Koettl, U.S.D.J. + +April 20, 2018 + +VI A ECE + +Hon. John O. United States District Court United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +Steptoe \_ APPUCATIENUAIM SO ORDERED + +Re: Jane Doe 43 v. Jeffrey Epstein, et al. Civil Action No. 17-ev-616 + +Dear Judge Kochi: + +We represent Defendants Jeffrey Epstein and Lesley Groff ("Defendants") in the abovereferenced matter and write to request permission to file a 15-page reply brief in support of Defendants' supplemental motion to dismiss. + +The brief that Defendants plan to submit will provide rounds for dismissal that are applicable not only to Defendants, but also to defendant ). We understand that plans to adopt certain of the arguments to ie set forth in fendants' brief, instead of repeating them in her brief. We further understand that will separately file a brief, but primarily to set forth additional grounds for dismissal that are applicable to her. We expect that the total pages of the two briefs will be no more than 20 pages. + +Defendants and will file their reply briefs on April 23, 2018 pursuant to the Court's Order of March 29, 2018 (ECI-11124). + +l)efcndants therefore respectfully request permission 15-page re y brief. + +(cattily st 'tied, + +USDC SDNY C. DOCUMENT Counsel for Defendants Jeffrey ELECTRONICALLY FILED Epstein and Lesley Groff DACE DATE FILEMtret O j\_-• \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820225/EFTA02820225.metadata.json b/marker2/court-jane-doe-43/EFTA02820225/EFTA02820225.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..da462ced668f470531a42cc5b9b0f8c4da734102 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820225/EFTA02820225.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820225.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1497, + "elapsed_seconds": 0.9, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 315 + ], + [ + "Line", + 42 + ], + [ + "Text", + 18 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820225" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820226/EFTA02820226.md b/marker2/court-jane-doe-43/EFTA02820226/EFTA02820226.md new file mode 100644 index 0000000000000000000000000000000000000000..d9ae44cf2c3ca72045b68d26de8f2faa68c54617 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820226/EFTA02820226.md @@ -0,0 +1,102 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT NEW YORK + +x + +JANE DOE 43, + +I7-ev-00616-JGK + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +Defendant. + +x + +#### REPLY MEMORANDUM OF LAW IN SUPPORT OF SUPPLEMENTAL MOTION TO DISMISS + +John E. Stephenson, Jr. (admitted pro hac vice) Jonathan D. Parente (pro hac vice forthcoming) ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, Georgia 30309 (404) 881-7000 john.stephenson@alston.com jonathan.parente@alston.com Alexander S. Lorenzo ALSTON & BIRD LLP 90 Park Avenue New York, New York 10016 (212) 210-9400 alexander.lorenzo@alston.com + +## TABLE OF CONTENTS + +| INTRODUCTION | 1 | +|------------------------------------------------|---------------| +| ARGUMENT | I | +| I. cannot state a plausible claim that | violated sex | +| trafficking laws. | I | +| II. Any purported claim against is time-barred | 5 | +| CONCLUSION | 5 | + +#### TABLE OF AUTHORITIES + +| CASES 4 Hour Wireless v=, 2002 WL 31654963 (S.D.N.Y. 2002) Ashcroft v. lqbal, 556 U.S. 662 (2009) Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) Daly v. Castro Llanes, | Page(s) 2 I, 5 1 | +|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------| +| 30 F. Supp. 2d 407 (S.D.N.Y. 1998) Harris v. | 2 | +| 572 F.3d 66 (2d Cir. 2009) RULES | 5 | +| Federal Rule of Civil Procedure 9(b) STATUTES | 2 | +| 18 U.S.C. § 1591(a)(1) (2006) | 2 | +| 18 U.S.C. § 1591(c)(2) (2006) | 4 | +| 18 U.S.C. § 1592 (2006) | 4 | +| 18 U.S.C. § 1593A | 4 | +| 18 U.S.C. § 1594 (2000) | 4 | + +### INTRODUCTION + +This case arises out of an adult relationship between and billionaire Jeffrey Epstein. More than ten years after-the-fact, has tried and failed (and then tried again and failed again) to plead sex-trafficking claims against five different individuals. One of them is Epstein's personal assistant. showed in her opening brief why could never state a viable civil claim under the federal trafficking laws, especially not one against cannot create a cause of action against out of thin (fact-less) air. The opposition brief does nothing to change that. has proven unable to salvage her legally deficient claims, ignoring key questions and falling short in her efforts to explain away the Amended Complaint's conclusory and time-barred allegations. + +incorporates by reference—and expressly adopts—the arguments advanced in Jeffrey Epstein and Lesley Groff s April 23, 2018 reply memorandum in support of their motion to dismiss. also files this separate reply to highlight additional reasons why the claims against in particular cannot survive. + +### ARGUMENT + +# cannot state a plausible claim that violated sex-trafficking laws. + +The Amended Complaint is label after conclusion after label after conclusion. That sort of formulaic recitation of the elements—"[n]aked assertions devoid of further factual enhancement"-will not do. Ashcroft v. lqbal 556 U.S. 662, 678 (2009) (quoting Twombly). + +As far as can glean from the threadbare allegations, means to claim that at some point during the six-month window "[b]etween October 2006 and May 2007" (with at least two other defendants) "confirmed and reiterated" someone else's promise that Epstein "would use his wealth and influence to have Plaintiff admitted into the Fashion Institute of Technology (known as 'F.I.T.') in New York City." (Am. Comp/. ¶¶ 36-38.) But that is not nearly enough to meet Rule 9(b)'s heightened "particularity" standard. Among other things, needed to "specifically identify() the allegedly fraudulent statements" by allege "where and when the statements were made." 4 Hour Wireless v. and specifically 2002 WL + +31654963, at \*2 (S.D.N.Y. 2002). Plus, "where multiple defendants are involved, the complaint is required to describe specifically each defendant's alleged participation in the fraud." Daly v. Castro Llanes, 30 F. Supp. 2d 407, 414 (S.D.N.Y. 1998). The reason that has not done those things is she cannot do them. + +The "fraud" claim. There are other problems for a fraud-based claim against , too. must at least allege that knew that "force, fraud, or coercion" would be used to cause to have sex with Epstein. See 18 U.S.C. § 1591(a)( I) (2006) (requiring that defendant "knowingly" engage in trafficking "knowing that force, fraud, or coercion . . . will be used to cause the person to engage in a commercial sex act"). That has not happened. Even having been on notice of the issue, the best could muster is an occasional "knowing" label and the allegation that "knew that Plaintiff was actually being recruited for sexual purposes." (Am. Compl. 1 40.) But one allegation has little to do with the other: Even if were aware that was introduced to Epstein "for sexual purposes," that says nothing about whether knew that Epstein or others never meant to keep any promises to help gain admission into F.I.T. or a similar fashion school. has never plausibly alleged the latter. + +Nor does it matter that supposedly "confirmed and reiterated" that "Epstein would use his wealth and connections to advance Plaintiff's education." (Am. Compl. 1 38.) The Amended Complaint's allegations suggest that, as far as would have known, Epstein intended to keep the alleged promises of assistance. There is certainly no plausible inference to be drawn that knew the opposite—that false promises were used to "defraud" into having sex with Epstein. After all, we know that Epstein gave a cell phone, a car service, a large Upper East Side apartment, and other "things of value" over the course of their relationship. (Id.11 52, 62.) And to the extent told that Epstein had helped out with her own career (id.153), that would have been 100% true. The takeaway? Even assuming that "reiterated" promises first made to induce to have sex with Epstein, there is no basis (alleged, or otherwise) to infer that knew that those were fraudulent promises. + +After pointed dial out in her opening brief, all but ignored it. As far as any claim against opposition brief serves only to confirm that she cannot plead that which is required of her. Indeed, a section in that brief titled has successfully alleged knowledge against Defendants Groff and fails to deliver as advertised. (Opp. Br. at 14-15.) That subsection simply quotes in full five different paragraphs from the Amended Complaint—nothing more, nothing less. The first three paragraphs allege only that (along with others) repeated the promises at issue "to ensure that Plaintiff would cooperate in fulfilling Epstein's sexual desires." (Id. (quoting Am. Compl. yq 38, 40, 53.)) The last two paragraphs have nothing to do with and apparently relate to "coercion" theory rather than her "fraud" theory. (Id. (quoting Am. Compl. 57. 59.)) None of the excerpted allegations could even arguably fill in the knowledge gap as it relates to + +The "coercion" claim. Where fraud claims are bad, her coercion claims against are even worse. For starters, supposedly in defense of coercion-based trafficking claim, the opposition explains that "the Amended Complaint details how the Defendants coerced her with promises of an education, living quarters, and other benefits `in order to coerce her into sexual compliance' and 'as an inducement to provide sex."' (Opp. Br. at 12- 13.) But promises inducing another to act are not the stuff of coercion. The statute defines "coercion" to include "threats of serious harm" or "physical restraint" or a plan "intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person." 18 U.S.C. § 1591(cX2) (2006); see Coercion, Oxford English Dictionary (2018) ("the action or practice of persuading someone to do something by using force or threats"). Either way, "coercion" theory must be different from her "fraud" theory. + +If instead means to press a coercion theory about how certain defendants allegedly "threated Plaintiff with serious harm, as well as serious psychological, financial, and reputational harm, compelling Plaintiff to perform and continue performing the commercial sexual activity," then those claims have no connection to . (Opp. Br. at 13.) The opposition brief cites parts of the Amended Complaint that mention only other defendants but not . (Id. + +(citing Am. Compl. 911 43, 48, 57.)) is never identified as having any involvement in this so-called "coercion." She never participated in any of the alleged "intimidat[ing]" or "threaten[ing]." (Am. Compl. 1 48.) Nor is it alleged that knew that other defendants allegedly told that they "had the ability to make sure I I would obtain no formal education or modeling agency contract if she failed to provide the sexual favors desired." (Id. 141.) Here again, highlighted this deficiency in her opening brief, and responded with silence. Perhaps says nothing because she has nothing to say. + +The Section 1592 claim. Section 1592 makes it unlawful to "knowingly destroy, conceal, remove, confiscate, or possess" another's passport to restrict that person's "liberty to move or travel" or "in the course of a violation" of other trafficking laws. 18 U.S.C. § 1592(a) (2006). As explained in her opening brief, the Amended Complaint is deficient in that it simply parrots back the language from this statute. response? To parrot back those same exact conclusory allegations once again in her opposition. (Opp. Br. at 17 (quoting Am. Compl. 1145. 49, 54.)) The problem is the complete lack of factual support. There is no specific allegation about who took passport, when they took it, how they took it, or how any "control" of passport may have been used to cause her to perform sexual acts. See Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009) ("[T]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.") (quoting lqbal).1 + +&#x27; The Amended Complaint likewise fails to state a claim in relation to any other predicate act. claims that the defendants violated Section I593A (Compl 170), but that provision was first enacted in 2008—after the alleged wrongful conduct. Regardless, there arc no facts to support a plausible allegation that "knowingly benefit[tcd], financially or by receiving anything of value, from participation" in a criminal venture. 18 U.S.C. § 1593A. + +claims and arguments about Section 1594 are also off the mark because those provisions are inapplicable to her civil claims. At the time, Section 1594(a) related to "attempts" to violate Section 1591, and Section 1591(b)-(c) provided only for criminal sentencing and criminal forfeiture. 18 U.S.C. § I594(a)-(c) (2000). + +## I1. Any purported claim against is time-barred. + +For the reasons explained in opening brief, Epstein and Grofrs opening brief, and Epstein and Groff's reply brief, sex-trafficking claims are time-barred. has no cause of action for the alleged wrongs that took place more than ten years ago. + +writes separately to emphasize yet another issue that counsel has either missed or chosen to ignore. own allegations confirm that by the time that she first left the United States in January 2007 and was abroad with her parents (Am. Compl. 1 55), "she knew" already "based upon Plaintiff's experience" that the defendants were engaged in an alleged fraudulent scheme, and she no longer believed to be "legitimate" any promises of education or career assistance. (M.156.) Against that backdrop, half-hearted effort to plead around the limitations period with incomplete, conclusory allegations suggesting that may have somehow then relied on additional F.I.T.-related promises after she returned to New York in February 2007 should be rejected out of hand. + +## CONCLUSION + +For these reasons, the claims against should be dismissed with prejudice. + +Dated: Atlanta, Georgia + +April 23, 2018 + +By: /s/ John E. Stephenson, Jr. John E. Stephenson, Jr. (admitted pro hac vice) Jonathan D. Parente (pro hac vice forthcoming) ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, Georgia 30309 (404) 881-7000 john.stephenson@alston.com jonathan.parente@alston.com + +Alexander S. 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Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 + +Plaintiff originally filed this action under the pseudonym "Jane Doe 43," but is now proceeding under her real name. + +### TABLE OF CONTENTS + +| | Pane | +|---------------------------------------------------------------------|----------------------------------------------------------------------------| +| TABLE OF AUTHORITIES | ii | +| INTRODUCTION | 1 | +| ARGUMENT | 2 | +| I. | THE FACTS AND BACKGROUND REGARDING THE PRIOR PROCEEDINGS ARE | +| PROPER AND SHOULD NOT BE STRICKEN | 2 | +| II. | HAS PROPERLY PLED A CLAIM FOR RELIEF FOR VIOLATIONS | +| OF THE SEX TRAFFICKING STATUTE | 3 | +| A. | The Trafficking Victims Protection Act Applies to the Coercive and Abusive | +| Conduct of Defendants | 4 | +| I | Has Not Improperly Lumped All Defendants Together in Violation | +| of Rule of Civil Procedure 8. | 5 | +| C. The Amended Complaint Meets the Twomblyllqbal Pleading Standards | 7 | +| D. | Has Successfully Pled Fraud with Particularity 11 | +| E. | Has Specifically Alleged Reasonable Reliance 11 | +| F. Has Properly Pled Coercion | 11 | +| G. Has Properly Pled a Causal Link | 13 | +| H. | Has Successfully Alleged Predicate Acts and Violation of Sections | +| 1592, 1593A, and 1594(a)-(c) | 14 | +| III. MAXWELL'S ARGUMENTS CONCERNING FURTHER AMENDMENT OF THE | | +| COMPLAINT ARE UNAVAILING | 14 | +| IV. | CLAIM IS WELL WITHIN THE STATUTE OF | +| LIMITATIONS | 20 | +| V. THIS COURT HAS JURISDICTION OVER THE DEFENDANT MAXWELL | 23 | +| VI. VENUE IS PROPERLY LAID IN THE SOUTHERN DISTRICT OF NEW YORK | 24 | +| CONCLUSION | 24 | +| CERTIFICATE OF SERVICE | 26 | + +## TABLE OF AUTHORITIES + +| Cases | Page | +|---------------------------------------------------------------------------------------------------------------------------------------------------|-------------| +| Abu Dhabi Commercial Banks v. [REDACTED] Stanley & Co., Inc.,
651 F. Supp. 2d 155 (S.D.N.Y. 2009)..... | 7 | +| Ashcroft v. Iqbal,
556 U.S. 662, 129 S. Ct. 1937, 173 L. Ed.2d 868 (2009)..... | 7 | +| Cruz v. Maypa,
773 F.3d 138 (4th Cir. 2014) ..... | 22 | +| Hudak v. Berkley Grp., Inc.,
No. 3:13-CV-00089-WWE, 2014 WL 354676 (D. Conn. Jan. 23, 2014) ..... | 6 | +| I.B. Trading, Inc. v. Tripoint Glob. Equities, LLC,
No. 17-CV-1962 (JGK), 2017 WL 5485318 (S.D.N.Y. Nov. 15, 2017)..... | 2, 11, 21 | +| Lama v. Malik,
192 F. Supp. 3d 313 (E.D.N.Y. 2016) ..... | 21 | +| Landgraf v. USI Film Products,
511 U.S. 244 (1994)..... | 21 | +| [REDACTED] v. City of New York,
No. 07-cv-7384 DG, 2008 WL 1826483 (S.D.N.Y. Apr. 23, 2008) ..... | 7 | +| Oluoch v. Orina,
101 F.Supp.3d 325 (S.D.N.Y. 2015) ..... | 22 | +| Precision Assocs., Inc. v. Panalpina World Transp., (Holding) Ltd.,
No. CV-08-42 JG VVP, 2013 WL 6481195 (E.D.N.Y. Sept. 20, 2013)..... | 6 | +| Schramm v. Krischell,
84 F.R.D. 294 (D. Conn. 1979) ..... | 3 | +| Tardibuono-Quigley v. HSBC Mortg. Corp. (USA),
No. 15-CV-6940 (KMK), 2017 WL 1216925 (S.D.N.Y. Mar. 30, 2017)..... | 6 | +| Twahir v. Village Care of New York, Inc.,
2011 WL 2893466 (S.D.N.Y July 12, 2011) ..... | 14 | +| United States v. Marcus,
487 F. Supp. 2d 289 (E.D.N.Y. 2007) ..... | 5, 12 | + +## United States v. Paris, + +| No. CR 03:06-CR-64(CFD), 2007 WL 3124724 (D. | Conn. Oct. 24, 2007) | +|----------------------------------------------|----------------------| +| 18 U.S.C. § 1591 | 3, 5 | +| 18 U.S.C. § 1591(a) (2006) | 4 | +| 18 U.S.C. § 1591(a)(2) | 12 | +| 18 U.S.C. § 1595 | 1, 14, 21 | +| 18 U.S.C. §§ 1592 | 2 | +| 18 U.S.C. §1593A | 2 | +| 18 U.S.C. §1594 | 2 | +| Fed. R. Civ. P. 9(b) | 11 | +| Fed. R. Civ. P. 12(b)(6) | 14 | +| Fed. R. Civ. P. 12(t) | 3 | +| Rule 12(b) | 4 | + +Plaintiff p'), by and through her undersigned counsel, opposes Defendant Ghislaine Maxwell's Motion to Dismiss, and states as follows. + +## INTRODUCTION + +The Court will recall that service of process issues have delayed this case for more than a year. After Maxwell's law firm (Haddon, and ), the Haddon firm hired another law firm to attempt to avoid service (DE 69). Now, it turns out that Ms. Maxwell is back to being represented by the very same counsel that originally tried to serve back a year ago in February, 2017. + +After creating significant delay with her service of process objection, Defendant Maxwell now files her own Motion to Dismiss, which in actuality is little more than a disguised sur-reply brief attempting to distinguish case law cited in Opposition to Defendant Epstein and Groff's Motion to Dismiss. But her arguments are just as misplaced as her co-defendants. + +Defendant Maxwell cannot run away from the fact that complaint properly alleges that Maxwell was the mastermind behind convicted sex offender Jeffrey Epstein's sex trafficking scheme. Instead, Maxwell wrongfully attempts to dive into the facts at the Motion to Dismiss stage by taking selective clips from deposition in a different case. But in doing so, Maxwell leaves out the key testimony that implicates her in the abuse. Moreover, in ruling on a motion to dismiss, the Court must take all allegations in the Amended Complaint as true and all inferences are drawn in favor of the plaintiff in determining whether she has stated a cause of action. has properly pled all elements of her claim under 18 U.S.C. § 1595, and the associated underling statutes. Maxwell has not met the standard for a motion to dismiss. Accordingly, Maxwell's motion to dismiss should be denied in its entirety. + +### ARGUMENT + +"In deciding a motion to dismiss pursuant to Rule 12(b)(6), the allegations in the Amended Complaint are accepted as true, and all reasonable inferences must be drawn in the plaintiffs' favor. The Court's function on a motion to dismiss is 'not to weigh the evidence that might be presented at a trial but merely to determine whether the complaint itself is legally sufficient.' The Court should not dismiss the Amended Complaint if the plaintiffs have stated 'enough facts to state a claim to relief that is plausible on its face.' A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." I.B. Trading, Inc. v. Tripoint Glob. Equities, LLC, No. 17- CV-1962 (JGK), 2017 WL 5485318, at \*1 (S.D.N.Y. Nov. 15, 2017) (internal citations omitted). + +has successfully pled all elements necessary to support her claim for relief. As addressed in detail in the sections below, the Trafficking Victims Protection Act (TVPA) does apply to the conduct alleged; the amended complaint does not impermissibly lump all Defendants together; it does plead fraud with particularity; it successfully plead reasonable reliance, coercion, and causation; it properly states a claim under 18 U.S.C. §§ 1592, 1593A, or 1594; it is not barred by the statute of limitations; and it properly lays venue in the Southern District of New York. + +## I. THE FACTS AND BACKGROUND REGARDING THE PRIOR PROCEEDINGS ARE PROPER AND SHOULD NOT BE STRICKEN. + +Maxwell repeats her Co-Defendants' assertion that factual allegations contained in the Amended Complaint should be stricken, yet offers no legal arguments or citations in support of this assertion. Maxwell Mot. to Dismiss at 4. Indeed, Maxwell's concluding statement that betrays a motivation to strike this material not because it is "immaterial" but because they materially + +underlie the claims in this action. Id. Maxwell has clearly not met the standard to strike, and has properly included these contextually necessary facts in her Amended Complaint. + +As explained in Opposition to Defendants' Motion to Dismiss, (DE 115), a court will only strike pleadings if the material is "redundant, immaterial, impertinent, or scandalous." Fed. R. Civ. P. 12(f). "Such motions are not favored and will not be granted unless it is clear that the allegations in question can have no possible bearing on the subject matter of the litigation. If there is any doubt as to the possibility of relevance, a judge should err on the side of denying a Rule 12(f) motion, especially if the presence of the material at issue does not prejudice the moving party." Schramm v. Krischell, 84 F.R.D. 294, 299 (D. Conn. 1979) (denying motion to strike). + +Here, has properly included allegations that are directly relevant to her claim of sex trafficking. Paragraphs I I through 33 of her Amended Complaint are crucial to pleading the circumstances surrounding her trafficking, and the coercion and force the defendants applied in trafficking her. See McCawley Decl. at Exhibit 1, Plaintiff Amended Complaint (DE 45). These allegations explain how (among other things) Epstein uses his wealth and power to sexually abuse young girls, and how his co-Defendants helped recruit them. incorporates herein the arguments she made in her Opposition to Defendants' Motion to Dismiss (DE 115 at p. 6) which raised this identical argument. Accordingly, the Court should deny Defendants' motion to strike. + +## HAS PROPERLY PLED A CLAIM FOR RELIEF FOR VIOLATIONS OF THE SEX TRAFFICKING STATUTE + +has properly pled a claim for violations under 18 U.S.C. § 1591 — which clearly covers the Maxwell's conduct — and has pled in detail fraud, reasonable reliance, coercion, a causal link, knowledge, and predicate acts. Defendant Maxwell does not meet the standard for dismissal under Rule 12(b), and her motion to dismiss must be denied. + +## A. The Trafficking Victims Protection Act Applies to the Coercive and Abusive Conduct of Defendants + +As an initial matter, Maxwell erects and demolishes a strawman. She argues that the TVPA forbids sex slavery and then proving (to her satisfaction) that did not have her "hands [tied] together with a rope" (Resp. at 6, quoting facts from Marcus case) Maxwell concluded that must be deemed to have been in an "adult consensual relationship." Resp. at 7-8. Maxwell does not understand the scope to TVPA, which extends a cause of action to victims forced to engage in commercial sex through means of "force, fraud, or coercion." 18 U.S.C. § 1591(a) (2006). Indeed, the very website Maxwell relies on, National Human Trafficking Hotline, debunks many of Maxwell's arguments as "myths": + +Myth 4: There must be elements of physical restraint, physical force, or physical bondage when identifying a human trafficking situation. + +Reality: Trafficking does not require physical restraint, bodily harm, or physical force. Psychological means of control, such as threats, fraud, or abuse of the legal process, are sufficient elements of the crime. Unlike the previous federal involuntary servitude statutes (U.S.C. 1584), the new federal crimes created by the Trafficking Victims Protection Act (TVPA) of 2000 were intended to address "subtler" forms of coercion and to broaden previous standards that only considered bodily harm. + +Myth 9: If the trafficked person consented to be in their initial situation or was informed about what type of labor they would be doing or that commercial sex would be involved, then it cannot be human trafficking or against their will because they "knew better." + +Reality: Initial consent to commercial sex or a labor setting prior to acts of force, fraud, or coercion (or if the victim is a minor in a sex trafficking situation) is not relevant to the crime, nor is payment. + +Myth 10: Foreign national trafficking victims are always undocumented immigrants or here in this country illegally. + +Reality: Not all foreign national victims are undocumented. Foreign national trafficked persons can be in the United States through either legal or illegal means. Although some foreign national victims are undocumented, a significant percentage may have legitimate visas for various purposes. + +Id. at hup://humantraffickinghotline.org/what-human-trafficking/myths-misconceptions + +Defendant Maxwell is unable to distinguish the Marcus case. In United States v. Marcus, 487 F. Supp. 2d 289, 304 (E.D.N.Y. 2007), rev'd on other grounds, 538 F.3d 97 (2d Cir. 2008), the defendant was convicted under 18 U.S.C. § 1591 for acts of sex trafficking in what began as an adult, consenting relationship. He appealed his sentence and tried to argue that the sex trafficking statute was "never meant to regulate conduct that occurs within a domestic, intimate relationship." Id. at 304. The court was unconvinced, finding this argument "nonsensical." Id. It held that a commercial sex act is "quite broadly defined" under the statute, and so long as the elements of the statute are present, the "mere existence of a past or present domestic, intimate relationship" does not preclude meeting the definition under the statute. Id. Defendant Maxwell's only basis for distinguishing this case is that the abuse involved there was more vulgar than the abuse suffered here. Maxwell's argument is unavailing because the TVPA does not require horrific physical abuse for a claim to proceed and, in any event. has not yet had the opportunity to present the extent of the sexual abuse she suffered. + +Has Not Improperly Lumped All Defendants Together in Violation of Rule of Civil Procedure 8. + +The Amended Complaint does not engage in any improper "group pleading." The Amended Complaint clearly states which Defendants engaged in which acts, as illustrated by the following: + +- "...Natalya was working to recruit young females for Epstein for sex when she approached and recruited Plaintiff." See McCawley Decl. at Exhibit I, Am. Compl. at 1 35. +- "Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology (known as + +"F.I.T.") in New York City or into a similar institute of higher learning offering a curriculum of fashion industry training." Id. at 1 38. + +- "Defendant Maxwell told Plaintiff she would need to provide Defendant Epstein with body massages in order to reap the benefits of his and Maxwell's connections." Id. at 1 39. +- "Defendants Groff and each also told Plaintiff that Defendant Epstein would advance Plaintiffs education and career in order to coerce Plaintiff into sex. Defendant told Plaintiff that Epstein had done the same for her career." Id. at 1 53. +- "...Defendants Epstein, Maxwell, and took possession of Plaintiffs passport when she was being trafficked by them, including when she travelled to Epstein's island in the U.S. Virgin Islands." Id. at 1 54. +- "Defendant Groff was aware of the coercion Epstein and Maxwell were applying to Plaintiff and acted to help further that coercion." Id. at 1 57. + +Maxwell herself lists five separate specific allegations in the Complaint against herself in her Twomblyllqbal Argument. See Maxwell Mot. to Dismiss at 10. That she views them as somehow "implausible" and "conclusory" has no bearing on the fact that each lays out specific conduct that Maxwell is alleged to have committed and thus clearly satisfies Rule 8 in attributing specific conduct to Maxwell. + +The language of the Amended Complaint is clear: each and all of the Defendants committed violations of the sex trafficking statute against "Prior to discovery, plaintiff need not explain the details of each defendant's role in the planning, funding, and executing defendants' alleged joint telemarketing scheme. Nothing in Rule 8 prohibits collectively referring to multiple defendants where the complaint alerts defendants that identical claims are asserted against each defendant." Hudak v. Berkley Grp., Inc., No. 3:13-CV-00089- WWE, 2014 WL 354676, at •4 (D. Conn. Jan. 23, 2014); see also Tardibuono-Quigley v. HSBC Mong. Corp. (USA), No. 15-CV-6940 (KMK), 2017 WL 1216925, at \*8 (S.D.N.Y. Mar. 30, 2017) ("The Amended Complaint, although stating that the allegations pertain to 'Defendants' or + +'Mortgage Defendants,' provides enough information to put PHH on notice of its alleged role in servicing Plaintiffs mortgage."); c.f. Precision Assocs., Inc. v. Panalpina World Transp., (Holding) Ltd., No. CV-08-42 JG VVP, 2013 WL 6481195, at \*12 (E.D.N.Y. Sept. 20, 2013), report and recommendation adopted, No. 08-CV-00042 JG VVP, 2014 WL 298594 (E.D.N.Y. Jan. 28, 2014). + +The cases Maxwell cites are readily distinguished. For example, in v. City of New York, No. 07-cv-7384 DG, 2008 WL 1826483, at \*1 (S.D.N.Y. Apr. 23, 2008), the pro se Plaintiff filed a form complaint that did not contain any allegations against Defendant, North General Hospital nor did the Plaintiff contest the dismissal of Defendant North General Hospital from the action. Those situation here, of course, is vastly different. + +## C. The Amended Complaint Meets the TwomblyllqbalPleading Standards + +"To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to 'state a claim to relief that is plausible on its face."' Ashcroft v. lqbal, 556 U.S. 662, 678, 129 S. Ct. 1937, 173 L Ed.2d 868 (2009) (internal quotation omitted). • + +Amended Complaint clearly meets the basic pleading requirements from Twomblyllqbal because every allegation she has pled is "plausible on its face." + +Here again, Maxwell appears to want to merely debate the ultimate credibility of ■ **allegations, disguised here as an argument about "plausibility" under TwomblylIqbal. Maxwell has offered no actual argument as to why the allegations in the Amended Complaint are "implausible." Further, those allegations do far more than "create a plausible inference that Ms. Maxwell is liable under the statute" (Maxwell Mot to Dismiss at 11), they lay out numerous explicit acts by Maxwell that together satisfy the statutory requirements. There is no need for any 'inference' to understand, for example, the simple statement that "Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance."** See McCawley Decl. at Exhibit 1, Am. Compl. at 1 48. The very case Maxwell cites, Abu Dhabi Commercial Banks v. Stanley & Co., Inc., 651 F. Supp. 2d 155, 170 (S.D.N.Y. 2009), makes clear that "[a] claim is facially plausible...when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." The plausibility of Defendant Maxwell's misconduct is clearly established by (among others) these allegations: + +- "Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise. She herself recruited young, including underage, females; oversaw and trained other recruiters on how best to recruit girls for sex; developed and executed schemes designed to recruit young females; and ensured that all participants of the Defendants' sex trafficking scheme acted in certain specific ways in order to advance the purposes of the scheme, including providing young females to Epstein for sexual purposes on a daily basis, and concealing these activities from law enforcement." See McCawley Decl. at Exhibit 1, Am. Compl. at 114 +- "Defendant Epstein employed many recruiters of young females. ... Recruiters were taught by Defendants Epstein, Maxwell and to inform targeted victims that Epstein possessed extraordinary wealth, power, resources and influence; that he was a philanthropist who would help female victims advance their careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact, however, these representations were fraudulent." Id. all 16. +- "The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein's compulsive need for sex with young females by preying on their personal, psychological, financial, and related vulnerabilities. The Defendants' tactics included promising the victims money, shelter, transportation, gifts, employment, admission into educational institutions, educational tuition, protection, and other things of value in exchange for sex. Defendants also took possession of the victims' passports to coerce compliance with their demands." Id. at1 18. +- "Defendants specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females to provide sex for Epstein." Id. at 1 21. +- "Additionally, Defendants always made clear to every young female that they were wealthy, well-connected and could either help or hurt the females depending on their + +degree of cooperation. In fact, Defendants Epstein and Maxwell have been known to threaten young females with physical harm." Id. at 1 22. + +- "Beginning in approximately October 2006 and continuing through April 2007, Defendants recruited Plaintiff into their sexual enterprise by fraudulently promising to use their connections and resources to secure her admission to an institution of higher education at the expense of Defendant Epstein." Id. at 1 34. +- "Defendant Maxwell told Plaintiff she would need to provide Defendant Epstein with body massages in order to reap the benefits of his and Maxwell's connections." Id. at 1 + - 39. +- "All Defendants, including Maxwell, Epstein, Groff and , knew that Plaintiff was actually being recruited for sexual purposes, and each knowingly and deliberately made false representations to ensure that Plaintiff would cooperate in fulfilling Epstein's sexual desires. These false and fraudulent representations included Defendants' telling Plaintiff that Epstein would use his connections to have her admitted into F.I.T. or a similar institute, college, university or school of higher learning and provide her with employment opportunities. Plaintiff reasonably relied on these representations and had a credible basis for such reliance, including the credible representations of Epstein and the other Defendants that they possessed extensive political, business, financial, social, and educational influence and connections." Id. at 140. +- "Maxwell and Epstein also threatened Plaintiff that, while they had the ability to advance her education and career, they also had the ability to make sure that Plaintiff would not obtain formal education or modeling agency contracts if she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein, Groff, and Maxwell." Id. at 1 41. +- "Plaintiff reasonably believed that her compliance with Defendants' demands was crucial to her physical, psychological, financial, and reputational well-being and survival." Id. at 1 42. +- "Plaintiff was instructed dozens of times to provide body massages to Epstein, both at his townhouse in New York and on his private island in the U.S. Virgin Islands.... The Defendants Epstein, Maxwell, and used possession and control of Plaintiff's passport to induce and coerce Plaintiff into performing sexual acts with Epstein and others." Id. at ¶45. + +- "During many sexual encounters, Defendant Epstein gave Plaintiff no option, opportunity, or choice not to participate in the prescribed sexual acts." Id. at 1 46. +- "Defendant Maxwell frequently controlled the assignment, or "rotation," of Plaintiff and the other young females concerning the time, place and manner of the sex acts they were told to provide to Defendant Epstein. Defendant Maxwell also gave instructions on how to perform certain sexual techniques on Epstein. Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with other females." Id. at 1 47. +- "Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaintiff with serious harm, as well as serious psychological, financial, and reputational harm, compelling Plaintiff to perform and continue performing the commercial sexual activity demanded by Defendants." Id. at 1 48. +- "On one occasion, after suffering verbal abuse and threats by Defendants Epstein, Maxwell, and In Plaintiff attempted to escape from Defendant Epstein's private island. A search party led by Defendants Epstein and Maxwell located her and physically returned her to the main house on the island. Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind." Id. at 1 + - 49. +- "As part of their ongoing scheme, Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts with Epstein and others. While Plaintiff was in South Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be permitted to return to the United States to receive her promised education unless she underwent a diet and lowered her body weight from 57 kilograms (approximately 125 pounds) to 52 kilograms (approximately 114 pounds). Epstein and Maxwell promised Plaintiff that, if she complied, she would receive her promised education." Id. at 1 57. +- "In February of 2007, in reliance on promises made by the Defendants, Plaintiff returned to New York City, in the Southern District of New York, and was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants Maxwell, =I, Groff, and Epstein each fraudulently promised Plaintiff again that her sexual compliance would be rewarded with admission to F.I.T. or a comparable college, a promise which they each knew to be false." Id. at 1 61. + +- "In May, 2007, Plaintiff left the United States and did not return. Between returning from South Africa in February 2007 and leaving in May 2007, Defendants , Groff, and Maxwell each continued to repeatedly make false representations to Plaintiff, including false and fraudulent representations that she would be admitted to F.I.T. if she continued to engage in sex with Epstein. Defendant Epstein continued to make similar false and fraudulent promises in order to have sex with Plaintiff." Id. at 1 64. + +This brief snapshot of the facts as alleged in the Amended Complaint undeniably states a claim for relief that is "plausible on its face." + +## D. Has Successfull, Pled Fraud with Particularity + +has pled fraud with the particularity required under the heightened standard under Fed. R. Civ. P. 9(b). A complaint alleging fraud must "(1) specify the statements that the plaintiff contends were fraudulent, (2) identify the speaker, (3) state where and when the statements were made, and (4) explain why the statements were fraudulent." LB. Trading, 2017 WL 5485318, at \*2 (denying motion to dismiss fraud claim) (internal citations omitted); Nagelberg v. Meli, No. 17 CIV. 2524 (LLS), 2017 WL 5201446, at \*3 (S.D.N.Y. 2017) (same). Defendant Maxwell's arguments here, regarding whether has properly pled fraud with particularity, are identical to the arguments raised by the other Defendants and therefore, by reference her response in her Opposition brief at DE 115 at 9 — 13. incorporates + +#### E. Has Specifically Alleged Reasonable Reliance + +has specifically pled that she reasonably relied on Defendants' representations that they would help her get into F.I.T. if she complied with their sex trafficking scheme. Again, Defendant Maxwell's argument is identical to the other Defendants and therefore incorporates by reference her Opposition in DE 115 at 15 -16. + +# F. Has Properly Pled Coercion + +Defendant Maxwell also claims that has failed to plead coercion and thus has not properly pled all of the elements of the sex trafficking statute. Under the sex trafficking + +statute, need only show that Defendants used fraud or coercion in causing to engage in commercial sex acts. See 18 U.S.C. § 1591(aX2) ("... means of force, threats of force, fraud, coercion ... or any combination of such means will be used to cause the person to engage in a commercial sex act ..."); United States v. Paris, No. CR 03:06-CR-64(CFD), 2007 WL 3124724, at \*12 (D. Conn. 2007) (collecting cases) ("Force, fraud and coercion are alternate means to accomplish a single element"); United States v. Marcus, 487 F. Supp. 2d 289, 308 (E.D.N.Y. 2007) (describing "force, fraud, or coercion" as single element of § 1591). + +Nevertheless, has properly pled coercion in her Amended Complaint. The Amended Complaint details how the Defendants coerced her with promises of an education, living quarters, and other benefits "in order to coerce her into sexual compliance" and "as an inducement to provide sex." See McCawley Decl. at Exhibit 1, Am. Compl. at 148, 50. It also details how Defendants "threatened retaliation against her if Plaintiff did not perform as demanded" and "threatened Plaintiff with serious harm, as well as serious psychological, financial, and reputational harm, compelling Plaintiff to perform and continue performing the commercial sexual activity demanded by Defendants." Id. at 11 43, 48, 57. And the Amended Complaint alleges that the Defendants "used possession and control of Plaintiff's passport to induce and coerce Plaintiff into performing sexual acts with Epstein and others." Id. at 1 45, see also id. at 1 51. And the Amended Complaint alleges that "[d]uring many sexual encounters, Defendant Epstein gave Plaintiff no option, opportunity, or choice not to participate in the prescribed sexual acts." Id. at 1 46; see also id. at 1 57. + +Continuing the pattern of launching attacks on the truth of allegation dressed up as legal arguments, Maxwell goes so far as to assert that it was somehow "ridiculous" for to believe Maxwell's threats. Maxwell Mot. to Dismiss at 15. Defendant Maxwell wrongfully reverses the use of Epstein's vast wealth and power to coerce into a scenario of a consensual relationship where wealth and power somehow benefited . Missing from Maxwell's twisted analysis is that Epstein did in fact cause her physical harm and used his power to coerce into compliance. See McCawley Dec. at Exhibit 1, Am. Compl. At yq 40-63. Finally, Defendant Maxwell attempts to attack allegation of the fact that Defendants wrongfully withheld her passport and restricted her travel by falsely stating that was "allowed and did travel on her own accord." But the Amended Complaint alleges that her travel was controlled by the Defendants including controlling the tickets and dictating the acts doubt that needed to perform while traveling. There can be no has properly pled coercion as defined by the sex trafficking statute. + +#### G. Has Properly Pled a Causal Link + +Completely ignoring the allegations in the complaint, Defendant Maxwell next tries to argue that has not established that Defendants' coercive conduct caused her to engage in commercial sex acts. Not so. Defendants' fraudulent and coercive acts and has properly pled a causal link between engaging in commercial sex acts. + +Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind. + +See McCawley Decl. at Exhibit I, Am. Comp!. at 1 49. In order for continue benefitting from Defendants' services and favors, to benefit, and had to keep providing commercial sex acts to Epstein. Contrary to Maxwell's contention, the Amended Complaint makes it more than clear that her sex acts were the direct result of fraudulent statements, coercion, and force. + +Mot. to Dismiss at 16. There was no "free will" being exercised by Maxwell Rather, her activities were being dictated by Defendants — including Maxwell — as alleged in the Complaint. + +## H. Has Successfully Alleged Predicate Acts and Violation of Sections 1592, 1593A, and 1594(a)-(c) + +In addition to pleading violations under Section 1591, has also successfully pled violations of Sections 1592, 1593A, and 1594(a)-(c) of the sex trafficking statute in her Amended Complaint. Defendant Maxwell makes identical arguments as those raised by the other Defendants and therefore, incorporates by reference her Opposition in DE 115 at 16-18. also would note that violations of these statutes are civilly actionable by operation of 18 U.S.C. § 1595. + +## III. MAXWELL'S ARGUMENTS CONCERNING FURTHER AMENDMENT OF THE COMPLAINT ARE UNAVAILING + +Maxwell next pursues a curious effort to impose her own preferred set of facts before any discovery has begun in this case by arguing that, based on her view of the facts, the Court should deny any further amendments to the Complaint. believes that her current complaint amply sets forth a basis for proceeding without any further amendments. But, in any event, Maxwell has presented no support for the proposition that her version of events should in any way control the pleadings or ability to amend those pleadings as may be required by the Court. See Twahir v. Village Care of New York, Inc., 2011 WL 2893466, \*1 (S.D.N.Y 2011) ("Leave to amend should be freely granted when justice requires." ... "[T]he standard for determining futility is comparable to the standard for deciding a motion to dismiss under Fed. R. Civ. P. 12(bX6).") + +In any event, it appears that the basis for Maxwell's argument is the claim that previous testimony in another case would somehow make amendment futile.' But entirely absent from Maxwell's brief is a fair recitation of what was actually shown in that other case. The other case made clear Maxwell's involvement in fraudulent and coercive sex trafficking. For example, provided detailed testimony that Defendant Maxwell was responsible for rotating the girls into Jeffrey Epstein's room for purposes of sexual abuse: + +![](_page_18_Picture_2.jpeg) + +See McCawley Decl. at Exhibit 2, explained that Defendant Maxwell + +Defendant also ludicrously claims that 'll= makes no allegation of physical abuse." First, the entire case is about physical abuse and, while the Complaint does not graphically describe the sexual abuse in detail, it is without question that deposition in that case, was physically abused. In her provided some examples of the abuse she endured: + +2 As explained in Opposition brief to Defendants' Motion to Dismiss (DE 115), the Court should ignore material outside the face of the complaint at the Motion to Dismiss stage. + +[Redacted text block] + +\*\*\* + +[Redacted text block] + +*Id.* at [Redacted]. + +While Defendant Maxwell tries to falsely claim alleged “discrepancies” between the Amended Complaint and [Redacted] testimony, a simple review establishes that her allegations in the Amended Complaint and her statements in the [Redacted] v. *Maxwell* deposition are entirely consistent. In fact, Defendant Maxwell tries to cherry pick five examples of paraphrased testimony in a failed effort to support her discrepancy theory. For example, Defendant Maxwell asserts that [Redacted] testimony does not show any connection between a promised admission to F.I.T. and coercive sexual abuse. Maxwell is incorrect, as a brief review of the deposition immediately established: + +[Redacted text block] + +*See* McCawley Decl. at Exhibit 2, [Redacted]. + +\*\*\* + +[Redacted text block] + +*Id.* at p. [Redacted] + +\*\*\* + +[Redacted text block] + +[Redacted text block] + +*Id. at [Redacted]* + +\*\*\* + +[Redacted text block] + +*Id. at p. [Redacted]* + +\*\*\* + +[Redacted text block] + +*Id. at p. [Redacted]* + +This promise of admission to FIT is just one example from Defendant Maxwell's arsenal of threats and promises she used to abuse [Redacted], threats that also included sabotaging [Redacted] [Redacted] modeling career. In concert with Defendant Maxwell, Defendant Epstein also used this fraud to procure sex: [Redacted] + +[REDACTED] +[REDACTED]. + +Second, Defendant Maxwell incorrectly states that [REDACTED] testimony does not support the fact that Defendant Maxwell instructed her to perform massages for Epstein and that Defendant Maxwell and Defendant Epstein promised her admission to FIT. As set forth above, [REDACTED] testified about Defendant Maxwell's involvement with the FIT process and how she promised to make calls to help her gain admission. [REDACTED] also testified that Defendant Maxwell knew the massages where sexual and Defendant Maxwell was in charge of rotating the girls in for the abuse. + +[REDACTED] + +*See McCawley Decl. at Exhibit 2, pp. [REDACTED]* + +\*\*\* + +[REDACTED] + +[REDACTED] + +*Id.* at p. [REDACTED]. + +Third, Defendant Maxwell wrongly claims that [REDACTED] testimony does not support her allegation that Maxwell “ordered” her to have sex with Epstein. Indeed, [REDACTED] + +[REDACTED] testimony says exactly that, [REDACTED] +[REDACTED] + +Fourth, Defendant Maxwell wrongly claims that [REDACTED] allegations relating to control of her passport differ in some way from her testimony, yet a review of the deposition demonstrates that Maxwell’s counsel never asked [REDACTED] if her passport had been improperly held against her will at any time during the period she was being abused by Defendant Epstein. + +Fifth, Defendant Maxwell claims that [REDACTED] allegation that she was “intimidated, threatened, humiliated and verbally abused” by Ms. Maxwell is not supported by her deposition testimony. Again, that is plainly false because Defendant Maxwell’s counsel never asked [REDACTED] [REDACTED] whether she was verbally abused by Ms. Maxwell. Despite the fact that the question was never asked, [REDACTED] provided direct testimony about how she was intimidated by Ms. Maxwell. For example, [REDACTED] testified: + +[REDACTED] + +*See* + +![](_page_23_Picture_79.jpeg) + +*Id.* at p. [REDACTED]. + +[REDACTED] testimony is entirely consistent with the allegations in her Complaint. And, in any event, "[t]he Court's function on a motion to dismiss is not to weigh the evidence that might be presented at a trial but merely to determine whether the complaint itself is legally sufficient." *See I.B. Trading, Inc. v. Tripoint Glob. Equities, LLC*, 280 F.Supp.3d 524 (S.D.N.Y. 2017) (Koeltl, J.). The complaint itself here is obviously legally sufficient. + +**IV. [REDACTED] CLAIM IS WELL WITHIN THE STATUTE OF LIMITATIONS** + +[REDACTED] claim is unquestionably within the statute of limitations, for all the reasons she has previously articulated in response to similar arguments by the other defendants which she incorporates by reference here as set forth in DE 115 at 22-26. A few words responding to Maxwell may nonetheless be useful here. + +Maxwell begins by conceding a fundamental point: That Congress clearly had the "power" to extend the statute of limitations to permit civil claims by sex trafficking victims, [REDACTED]. Resp. at 21. Curiously, however, Maxwell claims that in adopting a broad remedial statute designed to help sex trafficking victims in the future, Congress somehow choose to keep a narrowly-constructed four-year statute of limitations in place for past victims. This bizarre + +understanding of congressional intent has been persuasively rejected by a neighboring court within this Circuit. See Lama v. Malik, 192 F. Supp. 3d 313, 320-24 (E.D.N.Y. 2016) (court applying ten-year limitations period under 18 U.S.C. § 1595, even though conduct occurred before 2008 amendment, because plaintiff's claim was still "live' in 2008). As Lama persuasively explained, the ten-year statute of limitations (rather than the four-year limit) applies to cases such as this one, and this Court should simply follow the analysis in Lama. + +Maxwell argues that the Court in Lama "misapplied" Landgraf v. USI Film Products, 511 U.S. 244 (1994). To reach this conclusion, Maxwell tries to argue that a simple extension of statute of limitations is somehow a "retroactive" statute under Landgraf. But as Lama very clearly explained, simply extending the time period for a "live" claim to be filed is not a retroactive rule of law. Lama cited cases such as Cruz v. Maypa, 773 F.3d 138, 144-45 (4th Cir. 2014), which have found that TVPA extended the four-year statute of limitations to any unexpired claims. + +A good analysis of the issue issues is found in this Court decision in Oluoch v. Orina, 101 F.Supp.3d 325, 330-31 (S.D.N.Y. 2015), which applied the TVPA's ten-year statute of limitations to claims of involuntary servitude occurring in 2007: + +Just as in the Fourth Circuit, courts in this district recognize that Congress's adoption of a new, longer statute of limitations does not impair a defendant's rights if the effect is merely to extend claims that were still viable at the time of adoption. Goodman v. City of New York, No. 10 CIV. 5236 RJS, 2011 WL 4469513, at \*6 (S.D.N.Y. Sept. 26, 2011). + +Plaintiff claims to have been held by defendant in involuntary servitude from 2006 until September 4, 2007 when she escaped from defendant's home. Compl. 1 23. Thus, her claims accrued in 2007. In 2007, defendant could not expect to face liability for her conduct beyond 2011, when the four-year statute of limitations period expired. However, plaintiffs claims were still valid, still "alive," a year later when Congress expanded the statute of limitations for human trafficking claims to ten years. Holding defendant to this increased limitations period risks no retrospective effect because it does nothing to expand the legal consequences defendant already faced in 2008. Since the claims were still alive in 2008, there is no impermissible retroactivity in applying the extended \*331 statute of limitations Congress adopted that year. + +This Court should also simply follow Oluoch's reasoning here. + +Maxwell also desperately claims that claims fall outside even the ten-year statute of limitations — which she concedes is demarked by the date of January 26, 2007. But the Amended Complaint specifically alleges that "each of the Defendants last verified this information that Epstein was using his connections to ensure was admitted into F.I.T. in exchange for continued sexual cooperation with Epstein in March or April of 2007." See McCawley Decl. at Exhibit 1, Am. Compl. at 1 38. And the Complaint further alleges that, in February 2007, "in reliance on promises made by the Defendants, returned to New York City, in the Southern District of New York, and was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants Maxwell, Groff, and Epstein each fraudulently promised again that her sexual compliance would be rewarded with admission to F.I.T. or a comparable college, a promise which they each knew to be false." Id. at1 61. And finally, the Complaint also alleges an on-going cover-up of the criminal enterprise that occurred "[i]n and after May 2007." Id. at 1 65. + +Of course, to satisfy a statute of limitations, only one act must have been committed inside the relevant period of time. This hardly renders the earlier acts "irrelevant" for purposes of this case, particularly where the case concerns a pattern and conspiracy of sexual trafficking. As explained in her Opposition to Defendants' Motion to Dismiss (DE 115 24-26), has clearly alleged sufficient facts to satisfy her statute of limitations obligations. While Defendant Maxwell desperately tries to cling to deposition testimony to make up a statute of limitation issue, was never asked in detail about what abuse she suffered upon returning from South Africa. The Court should not be deceived by Maxwell's incorrect conclusions. + +### V. THIS COURT HAS JURISDICTION OVER THE DEFENDANT MAXWELL + +After stalling service in this case for almost a year, Defendant Maxwell now attempts to argue that the Court does not have jurisdiction over her. The Amended Complaint very clearly states that "[a]t all times material to this cause of action Defendant Ghislaine Maxwell was residing in . . . New York, New York". See McCawley Decl. at Exhibit 1, Am. Compl. at 1 6. Maxwell advances no argument to defeat this Court's personal jurisdiction other than the conclusory statements that it does not have jurisdiction. Id. + +This Court properly has jurisdiction over all of the Epstein Defendants including Maxwell, and her claims otherwise are unavailing. As pled in the Amended Complaint, Defendant Maxwell had a residence in New York for years before selling it in 2016. At all times material to the present case, Maxwell was living in New York and for the most part residing with Epstein. Id. at 1 12. Plaintiff also pled that the Defendants' trafficking conduct occurred in New York. Id. at 11 20, 28, 45, 52, 55, 60, 61, 63, 76. This trafficking conduct is specifically alleged to have occurred in New York City, within the Southern District of New York, after January 2007. Id. at 1 61. Further, while pleading residence is sufficient by itself to establish jurisdiction, it is also noteworthy that Maxwell's business, the Terra Mar Project, has its address in New York. And it is believed Maxwell still resides in New York. Although she has refused to provide her address. The Court is, of course, familiar with the difficulty in locating the elusive and peripatetic Ms. Maxwell from prior litigation associated with serving her with the Complaint in this case. But, for present purposes, it is enough to note that that the Amended Complaint alleged that "[ajt all times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York." See McCawley Decl. at Exhibit I, Am. Compl. at 16. + +Jurisdiction is plainly proper. + +### VI. VENUE IS PROPERLY LAID IN THE SOUTHERN DISTRICT OF NEW YORK + +Venue is also properly laid in the Southern District of New York because a substantial part of the acts, events, and omissions giving rise to this cause of action occurred in this District. Id. at 1 9. As pled in the Amended Complaint and referenced above, Defendant Maxwell had a residence in the Southern District of New York during the relevant time periods in the complaint. During the relevant time period Defendant Maxwell was "the highest-ranking employee of the Defendants' sex trafficking venture and enterprise. She herself recruited young, including underage, females; oversaw and trained other recruiters on how best to recruit girls for sex; developed and executed schemes designed to recruit young females; and ensured that all participants of the Defendants' sex trafficking scheme acted in certain specific ways in order to advance the purposes of the scheme, including providing young females to Epstein for sexual purposes on a daily basis, and concealing these activities from law enforcement." Id. at 114. • also pled that the Defendants' trafficking conduct occurred in New York City, revolving around Defendant Epstein's residence. See McCawley Decl. at Exhibit I, Am. Compl. at 20, 28, 45, 52, 55, 60, 61, 63, 76. This trafficking conduct is specifically alleged to have occurred in New York City, within the Southern District of New York, after January 2007. Id. at 1 61. Venue is plainly proper — a fact that is underscore by Defendants' notable silence as to which judicial district they believe is a more appropriate venue. + +## CONCLUSION + +For all the foregoing reasons, the Court should deny Defendants' Motions to Dismiss in their entireties. + +Dated: May 7, 2018 + +Respectfully submitted, + +BOLES SCHILLER FLEXNER LLP + +/s/ Sigrid McCawley + +Sigrid S. McCawley (Admitted Pro Hac Vice) + +Meredith (Admitted Pro Hac Vice) + +Boies Schiller Flexner LLP + +401 E. Las Olas Blvd., Suite 1200 + +Ft. Lauderdale, FL 33301 + +(954) 356-0011 + +J. Esq. (Admitted Pro Hac Vice) + +Stanley Pottinger, Esq. + +POTTINGER LLC + +425 North Andrews Avenue, Suite 2 + +Fort Lauderdale, Florida 33301 + +Tel: (954) 524-2820 + +Paul G. Cassell (Admitted Pm Hac Vice) + +S.J. Quinney College of Law + +University of Utah + +383 University St. + +Salt Lake City, UT 84112 + +(801) 585-52023 + +3 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. + +### CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on May 7, 2018, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. + +Kimo S. Peluso Sher Tremonte, LLP 90Broad Street, 23rd Floor New York, NY 10004 k luso@shertremonte.com Counsel for Haddon, & P.C. + +Laura A. Menninger, Esq. Jeffrey Pagliuca Es . HADDON, & 150 East 10th Avenue Denver, Colorado 80203 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com + +John E. Stephenson, Jr. Jonathan D. Parente ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, GA 30309 John.stephenson@alston.com Jonathan.parente@alston.com + +Alexander S. Lorenzo ALSTON & BIRD LLP 90 Park Avenue New York, NY 10016 alexander lorenzo@alston com Counsel for Defendant + +Michael Justin Y.1% Michael A. Keou h , P.C. STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoe.com jchu@steptoe.com Counsel for Defendants, Jeffrey Epstein and Lesley Groff + +/s Sigrid MeCawley Sigrid McCawley \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820235/EFTA02820235.metadata.json b/marker2/court-jane-doe-43/EFTA02820235/EFTA02820235.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..50165bd7b78e95cf45d44f6bc3d44f8cc711a3fe --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820235/EFTA02820235.metadata.json @@ -0,0 +1,1682 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820235.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 30, + "chars": 53734, + "elapsed_seconds": 12.5, + "image_assets": [ + "_page_18_Picture_2.jpeg", + "_page_23_Picture_79.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 72.9 + ], + [ + 293.59381103515625, + 72.9 + ], + [ + 293.59381103515625, + 103.863037109375 + ], + [ + 68.544, + 103.863037109375 + ] + ] + }, + { + "title": "PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO \nDEFENDANT GHISLAINE MAXWELL'S MOTIONS TO DISMISS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 124.23600000000002, + 338.58 + ], + [ + 488.47998046875, + 338.58 + ], + [ + 488.47998046875, + 369.7330322265625 + ], + [ + 124.23600000000002, + 369.7330322265625 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 238.06800000000004, + 72.08999999999999 + ], + [ + 374.5343933105469, + 72.08999999999999 + ], + [ + 374.5343933105469, + 86.2330322265625 + ], + [ + 238.06800000000004, + 86.2330322265625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 228.276, + 71.28 + ], + [ + 383.5578918457031, + 71.28 + ], + [ + 383.5578918457031, + 86.2330322265625 + ], + [ + 228.276, + 86.2330322265625 + ] + ] + }, + { + "title": "United States v. 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1:17-CV-00616 + +JANE DOE 43, + +Plaintiff, + +VS. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +Defendants. + +### FIRST AMENDED COMPLAINT + +Plaintiff JANE DOE 43, by and through her undersigned counsel, for her claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, Lesley Groff, and Natalya , alleges upon personal knowledge with respect to her own acts and status, and upon personal knowledge, information and belief as to all other matters, as follows: + +- 1. This cause of action arises under federal statutes and jurisdiction is proper under 28 U.S.C. section 1331. +- 2. Plaintiff files this Complaint under a pseudonym in order to protect her identity because this Complaint makes allegations of a sensitive sexual nature the disclosure of which, in association with her name, would cause further harm to her. + +3. At all times material to the events alleged in this cause of action the Plaintiff was a citizen of South Africa residing in New York, New York. + +4. At all times material to this cause of action Defendant Jeffrey Epstein had multiple residences, including in New York, New York (within the Southern District of New York) and the United States Virgin Islands. He is currently a citizen of the United States and claims to be a resident of the U.S. Virgin Islands. + +5. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in 1953. + +6. At all times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York and was a citizen of Great Britain and France. + +7. At all times material to this cause of action was a United States citizen, residing in New York, New York (within the Southern District of New York). + +8. At all times material to this cause of action Lesley Groff was a United States citizen, employed by New York based company and regularly conducting business in New York, New York (within the Southern District of New York). + +9. A substantial part of the acts, events, and omissions giving rise to this cause of action occurred in the Southern District of New York; venue is proper in that District. 28 U.S.C. section 1391(b)(2) + +10. At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, and Lesley Groff owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional, criminal, fraudulent, or tortious acts against her, including any acts in violation of 18 U.S.C. §1595. + +## FACTUAL ALLEGATIONS + +11. At all times material to this cause of action, Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is widely recognized as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes and to employ and conspire with a group of numerous others, including each of the named Defendants, to assist in committing those crimes and additional torts as well as to conceal the crimes and torts of the Epstein sex trafficking group from being discovered. + +12. Defendant Epstein displays his enormous wealth, power and influence to his employees; to the victims procured for sexual purposes; and to the public in order to advance and carry out his crimes and torts. At all relevant times, Defendant Epstein owned and continues to own, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats and one or more helicopters. For example, he owned (directly or indirectly) a Boeing aircraft (of make and model B-727-31H with tail number N908JE) and a Gulfstream aircraft (of make and model G-1159B with tail number N909JE). He also owned numerous properties and homes, including a 51,000-square-foot mansion in Manhattan; a \$30 Million, 7,500-acre ranch in New Mexico; a 70-acre private island formerly known as Little St. James in or near St. U.S. Virgin Islands; a home in Paris, France; and a mansion in Palm Beach County, Florida. The allegations herein primarily concern the defendant's conduct while at his townhouse in New York; on one or more of his private airplanes; and on his private island in the United States Virgin Islands. Epstein used all of the real and personal property described in this paragraph to facilitate the illegal sex trafficking venture and enterprise described in this Complaint and in furtherance of that venture and enterprise. + +13. Defendant Epstein has a compulsive sexual preference for young females as young as 13 and as "old" as 25. Through information and belief Defendant Epstein engages in sexual acts with this age range every day and developed, through the employment of and conspiracy with the other Defendants, a sex trafficking venture and enterprise designed to fulfill his sexual desires and conceal the operation of the venture and enterprise and conduct of its participants. As part of the venture and enterprise, Epstein also provided young females for sexual purposes to his friends in order to secure social, business, and other contacts as well as other things of value. + +14. Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise. She herself recruited young, including underage, females; oversaw and trained other recruiters on how best to recruit girls for sex; developed and executed schemes designed to recruit young females; and ensured that all participants of the Defendants' sex trafficking scheme acted in certain specific ways in order to advance the purposes of the scheme, including providing young females to Epstein for sexual purposes on a daily basis, and concealing these activities from law enforcement. + +15. Defendant recruited young females for Epstein for sexual purposes, brought gifts to females in order to entice those females to commit sex acts with Epstein and to assist in concealing the illegal sexual conduct of the venture and enterprise, and maintained Epstein's sex schedule in order to ensure that he was not without young females for any extended period of time. Defendant also handled travel arrangements for various females being exploited for sexual purposes. Defendant was an integral part of the sex trafficking venture and enterprise and reported directly up the enterprise's line of authority to Defendants Maxwell and Epstein. + +16. Defendant Epstein employed many recruiters of young females. The nature of the Defendants' sex trafficking venture and enterprise enabled victims themselves to elevate their status to that of a paid recruiter of other victims. Recruiters were taught by Defendants Epstein, Maxwell and to inform targeted victims that Epstein possessed extraordinary wealth, power, resources and influence; that he was a philanthropist who would help female victims advance their careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact, however, these representations were fraudulent. The young females were actually required to perform intimate sexual acts at the Defendants' direction and the Defendants did not help nor intend to help advance the victims' careers. Victims were also paid to bring Epstein other young females for sex and were told by Defendants Epstein, Maxwell, and that those young females who brought other females would further benefit from bringing other girls. + +17. Defendant Groff was an integral part of the illegal venture and enterprise. Groff coordinated schedules between Defendant Epstein and the various young females used for sex; made travel arrangements for the young females; tended to the living needs of those females; communicated and coordinated with Defendants Epstein, Maxwell and to assist in facilitating young females being available in locations where the other Defendants were traveling; and she carried messages to the young females from the other Defendants including false representations in order to maintain the young females' compliance with the rules of sexual compliance imposed by this structured sex-trafficking group. Groff was aware of the activities of the venture and enterprise, including the fraudulent representations and other coercion that was being applied to secure the females' compliance with demands of sex. + +18. The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein's compulsive need for sex with young females by preying on their personal, psychological, financial, and related vulnerabilities. The Defendants' tactics included promising the victims money, shelter, transportation, gifts, employment, admission into educational institutions, educational tuition, protection, and other things of value in exchange for sex. Defendants also took possession of the victims' passports to coerce compliance with their demands. Defendants also trafficked young females to Epstein's friends and acquaintances in order to secure financial and other benefits as well as social, educational, and business connections. + +19. Defendants' sex trafficking venture and enterprise operated in a hierarchal structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top. Defendants Epstein and Maxwell operated the sex trafficking scheme dating back to at least the mid-nineties, and over the years perfected their roles and the roles of others, both in terms of the ability to increase the volume of young females recruited for sex and in insulating the enterprise from criminal investigation or prosecution. Defendant Groff conspired with Defendant Epstein and Maxwell since at least 2002 and continues to work for Defendant Epstein today. Defendant began working with the Epstein-run sex trafficking venture and enterprise as early as 2001 and her role in their venture and enterprise was well-defined and primarily consisted of conspiring in the commission and cover-up of sex crimes. Underlings included the other named Defendants as well as unnamed coconspirators such as various housekeepers and butlers; an airplane pilot; and various employees, assistants and associates. Wittingly and unwittingly, such underlings performed their respective roles with the purpose and effect of insuring that the enterprise supplied young females to Defendant Epstein and others for sexual purposes. At all times materials to this complaint, the venture and enterprise was a group of two or more individuals associated in fact and deed. + +20. Defendants Epstein and Maxwell, with help from assistants, associates and underlings, recruited and procured hundreds of girls over the decades of the operation of their scheme. Such recruitment and procurement included fraud, coercion, threats, intimidation, fear, the threat of coercion, and a combination of these and similar tactics. Following the Defendants' recruitment and procurement of the young females to join Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent promises, coercion, and threats of coercion in order to entice and coerce the females into sex and, once sexual activities ensued, to cause them to remain in the enterprise. The Defendants also transported females in + +interstate and foreign commerce and in ways that affected interstate and foreign commerce. The sex acts were commercial in nature, because the Defendants promised to provide financial and other compensation to the females in exchange for providing sex acts to Epstein. + +21. Defendants specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females to provide sex for Epstein. + +22. Additionally, Defendants always made clear to every young female that they were wealthy, well-connected and could either help or hurt the females depending on their degree of cooperation. In fact, Defendants Epstein and Maxwell have been known to threaten young females with physical harm. It is unknown exactly how long the Defendants' criminal and illegal venture and enterprise operated, although it was at least continuously and actively in operation from the mid-1990's through and including the calendar year 2007. + +23. Defendant Epstein has continued the venture and enterprise up to the present time in some form or another and with additional co-conspirators and participants. + +24. In 2005, Defendant Epstein and numerous co-conspirators within the venture and enterprise were the subjects of a Palm Beach, Florida Police Department criminal investigation which revealed that Defendant Epstein had engaged in sexual activities with dozens of young teenage school children. Each child identified in that particular investigation was lured into Defendant Epstein's Palm Beach mansion with a promise that she would receive money for providing him with a body massage, although once there, each young female was made to engage in sexual acts in order to receive the promised compensation. Several were also made to engage in sex with another of Defendant Epstein's female traveling sex companions who Epstein referred to as his lesbian sex slave and bragged about purchasing her from her family when she herself was underage. + +25. In 2006, the Palm Beach Police Department investigation was turned over to the FBI and the United States Attorney's Office for the Southern District of Florida. The United States Attorney's Office investigated Defendant Epstein and his co-conspirators for their violations of numerous federal statutes, including 18 U.S.C. Section 1591, one of the statutory bases for this complaint. + +26. The United States Attorney's investigation continued from 2006 through September 2007, at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office deferring federal prosecution of Defendant Epstein and his numerous co-conspirators, including Defendants and Groff, each named by the Federal Government as coconspirators, for identified federal sex crimes against more than 30 minors. + +27. From late 2006 through September 2007, Epstein's team of lawyers negotiated with the federal government in an effort to avoid a fifty-three-page Federal felony indictment from being filed against Epstein. During these negotiations, Defendant Epstein decamped from Palm Beach to New York and the U.S. Virgin Islands in order to convey an image to prosecutors that he and his coconspirators had stopped committing sex crimes. + +28. Remarkably, however—as this case will highlight—Defendant Epstein and his co-Defendants, including the other defendants named herein, did not abandon their sex trafficking venture and enterprise even while they were under state and federal investigation for crimes committed in violation of 18 U.S.C. section 1591, among other laws, and even as Defendants and their attorneys were busy arguing Epstein's innocence and publicly defaming his victims as liars. Rather, Defendants merely changed their location. Instead of targeting local Palm Beach Florida school girls, the Defendants transported young females from other places in the U.S. (including the Southern District of New York) and abroad and brought them to Defendant Epstein's mansion in New York City and his private island in the Virgin Islands. + +29. In June of 2008, Epstein pleaded guilty to Florida state felony sex offenses for procuring a minor for prostitution and soliciting prostitution by minors and registered as a Sex Offender for Life. + +30. Defendants Epstein and Maxwell developed and implemented a sophisticated system designed to insulate them from criminal and civil liability by protecting them from potential testimony of knowledgeable subordinates. Defendants and Groff adapted to the system and also carried it out for years in exchange for significant pay, benefits, and protection from prosecution. The system included requiring subordinates to sign confidentiality agreements barring disclosure of criminal activity; maintaining records of underage females who were abused by Epstein; requiring subordinates and victims to refrain from speaking with law enforcement officials; requiring them to notify Defendant Epstein's lawyers in the event they (subordinates and victims) were contacted by law enforcement officials; requiring them to accept the representation of attorneys paid for by Defendant Epstein; requiring them to invoke the Fifth Amendment in response to questions they might be asked by investigators and prosecutors; requiring them to invoke the Fifth Amendment in order to refuse to turn over incriminating and non-incriminating evidence to law enforcement officers; requiring them to destroy evidence or refuse to reveal knowledge of destroyed evidence; and requiring them generally to refuse all cooperation with law enforcement officials or investigations. + +31. In 2005, Defendant Epstein and other co-conspirators, aware that law enforcement officials were preparing imminently to execute a search warrant for his home, removed computer systems that logged information about Epstein and his co-conspirators' illegal and criminal conduct; the identities of witnesses; nude photographs of young females; scheduling books; message pads; tangible items such as vibrators and toys; and other incriminating matter. + +32. The sex recruiting and trafficking venture and enterprise designed to procure young females for sexual purposes and to conceal those activities was developed and fine-tuned over time, and each of the named Defendants had a well-defined role and improved in his/her role over time, with practice and experience. By the time Plaintiff was recruited into victimization, each Defendant had years of experience perfecting methods of coercion, understanding Epstein's requirements, and becoming more loyal to the continuance and survival of the venture and enterprise. All of the Defendant's knew about the activities of the venture and enterprise and worked in concert for the goals of the venture and knowingly benefitted, financially and by receiving things of value, from their participation in the venture and enterprise. + +33. A typical way the Defendants procured young females for sex with Defendant Epstein was to make false promises of a modeling opportunity, offer a better life, offer payment for a formal education, or offer other money or consideration. + +34. Beginning in approximately October 2006 and continuing through April 2007, Defendants recruited Plaintiff into their sexual enterprise by fraudulently promising to use their connections and resources to secure her admission to an institution of higher education at the expense of Defendant Epstein. + +35. One of the enterprise's many recruiters, Natalya was working to recruit young females for Epstein for sex when she approached and recruited Plaintiff. + +36. informed Plaintiff that she would introduce Plaintiff to Defendant Epstein, whom she described as a wealthy philanthropist who regularly used his wealth, influence and connections to help financially poor females like Plaintiff achieve their personal and professional goals and aspirations. + +37. reported to her superiors, Defendants , Groff and Maxwell, and was paid for her recruitment of young females, including Plaintiff. + +38. introduced Plaintiff to Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology (known as "F.I.T.") in New York City or into a similar institute of higher learning offering a curriculum of fashion industry training. Between October 2006 and May 2007, Defendants Maxwell, , and Groff each also confirmed and reiterated this promise to Plaintiff many times, each telling Plaintiff that Epstein would use his wealth and connections to advance Plaintiffs education. More specifically, each of the Defendants last verified this information that Epstein was using his connections to ensure Plaintiff was admitted into F.I.T. in exchange for Plaintiff's continued sexual cooperation with Epstein in March or April of 2007. + +39. Defendant Maxwell told Plaintiff she would need to provide Defendant Epstein with body massages in order to reap the benefits of his and Maxwell's connections. + +40. All Defendants, including Maxwell, Epstein, Groff and , knew that Plaintiff was actually being recruited for sexual purposes, and each knowingly and deliberately made false representations to ensure that Plaintiff would cooperate in fulfilling Epstein's sexual desires. These false and fraudulent representations included Defendants' telling Plaintiff that Epstein would use his connections to have her admitted into F.I.T. or a similar institute, college, university or school of higher learning and provide her with employment opportunities. Plaintiff reasonably relied on these representations and had a credible basis for such reliance, including the credible representations of Epstein and the other Defendants that they possessed extensive political, business, financial, social, and educational influence and connections. Epstein and the other Defendants represented to Plaintiff in manners that were persuasive, credible, and reasonable to Plaintiff, as they would have been to any other person similarly situated, that they had the political, business, financial, social, educational, and other influence and + +connections sufficient to arrange for and insure her admission into F.I.T. or a similar school of higher learning. + +41. Maxwell and Epstein also threatened Plaintiff that, while they had the ability to advance her education and career, they also had the ability to make sure that Plaintiff would not obtain formal education or modeling agency contracts if she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein, Groff, and Maxwell. + +42. Plaintiff reasonably believed that her compliance with Defendants' demands was crucial to her physical, psychological, financial. and reputational well-being and survival. + +43. Defendant Maxwell instructed Plaintiff how to massage Epstein using the techniques that Maxwell knew that Epstein preferred. During Plaintiff's first massage, Defendant Epstein converted it into a sexual act and made it known to Plaintiff that further sex would be required in order for her to obtain the assistance he promised her and to avoid Defendants' threatened retaliation against her if Plaintiff did not perform as demanded. + +44. Maxwell and Epstein informed Plaintiff that other young females in Epstein's company were there also to perform sexual acts for Epstein and his friends. Groff and helped to secure the presence of the other young females for these purposes. + +45. Plaintiff was instructed dozens of times to provide body massages to Epstein, both at his townhouse in New York and on his private island in the U.S. Virgin Islands. Each time she was so instructed she was also required to perform a sexual act with Epstein. The Defendants all participated in arranging for Plaintiff to be transported in interstate and foreign commerce, and affecting interstate and foreign commerce, for these sexual purposes. The Defendants Epstein, Maxwell, and used possession and control of Plaintiff's passport to induce and coerce Plaintiff into performing sexual acts with Epstein and others. + +46. During many sexual encounters, Defendant Epstein gave Plaintiff no option, opportunity, or choice not to participate in the prescribed sexual acts. + +47. Defendant Maxwell frequently controlled the assignment, or "rotation," of Plaintiff and the other young females concerning the time, place and manner of the sex acts they were told to provide to Defendant Epstein. Defendant Maxwell also gave instructions on how to perform certain sexual techniques on Epstein. Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with other females. + +48. Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaintiff with serious harm, as well as serious psychological, financial, and reputational harm, compelling Plaintiff to perform and continue performing the commercial sexual activity demanded by Defendants. + +49. On one occasion, after suffering verbal abuse and threats by Defendants Epstein, Maxwell, and MI Plaintiff attempted to escape from Defendant Epstein's private island. A search party led by Defendants Epstein and Maxwell located her and physically returned her to the main house on the island. Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind. Defendants further used possession and control of Plaintiff's passport, without lawful consent or authority, to restrict Plaintiff's liberty and thereby force her to provide sex to Epstein. + +50. Defendant Epstein's wealth, influence, power and connections were used by Defendants Maxwell, =, and Groff, both as an inducement to provide sex (in exchange for promises of support to Plaintiff) and as a means of threatening punishment (in the event Plaintiff refused to comply with Defendants' instructions to provide sex to Epstein and others). + +51. In addition to Plaintiffs being trafficked on Epstein's private airplane, Defendants Groff, Maxwell and , with the knowledge of and instruction by Defendant Epstein, arranged Plaintiffs living accommodations, private car travel, and commercial air travel on numerous occasions for the purpose of causing Plaintiff to commit commercial sex acts. These Defendants worked in concert with one another to recruit, procure, entice, and otherwise cause many other females to engage in commercial sex acts, through their use of threats, fraud, and coercion. Among these means of coercion were the Defendant's possession and control of the females' passports and other immigration documents. This coercion was most salient, and especially effective, while the females, including Plaintiff, were on Epstein's island. + +52. In furtherance of their venture and enterprise, Defendants provided living quarters for Plaintiff at 301 East 66th Street, New York, in the Southern District of New York; a car service for Plaintiff to use as needed; a cell phone; and other valuable consideration in order to maintain Plaintiffs sexual compliance. Each of the Defendants told Plaintiff she would obtain the benefits of a place to live and phone and transportation as long as she remained compliant with their demands that she service Epstein sexually. Each of the Defendants also told her that if she was not compliant, these benefits would be taken from Plaintiff. + +53. The relationship between Plaintiff and Defendants Epstein and Maxwell was defined and characterized by Defendant Epstein's and Defendant Maxwell's frequent and persistent fraudulent representations that they would provide Plaintiff with a formal education and career advancement if she provided sex to Defendant Epstein and others in the times, places and manners demanded by Defendants. Defendants Groff and each also told Plaintiff that Defendant Epstein would advance Plaintiffs education and career in order to coerce PI al mi tt into sex. Defendant told Plaintiff that Epstein had done the same for her career. As a result of these and other representations by Defendants, Plaintiff reasonably relied on these representations. In fact, however, these representations were knowingly false, were not acted upon by Defendants, and were made by Defendants Epstein, Groff, , and Maxwell solely for the purpose of maintaining Plaintiffs financial dependence on, emotional vulnerability to, and sexual compliance with Defendant Epstein's demands. The other Defendants intentionally repeated these representations and intentionally made statements designed to convince Plaintiff that the representations were true and could be relied upon. These representations and statements were made to Plaintiff in furtherance of the sex trafficking venture and enterprise for which they were each employed. + +54. As part of the venture and enterprise, Defendants Epstein, Maxwell, and took possession of Plaintiff's passport when she was being trafficked by them, including when she travelled to Epstein's island in the U.S. Virgin Islands. The Defendants took possession of Plaintiff's passport in the course of sexually trafficking Plaintiff and with the intent to violate laws against sex trafficking, including 18 U.S.C. 1591 et. seq. The Defendants used their control of Plaintiff's passport in order to coerce compliance with their demands, including their demands that Plaintiff have sex with Epstein and others. + +55. In January 2007, as part of their illegal venture and enterprise, Defendants sent Plaintiff from New York City, in the Southern District of New York, to South Africa to recruit, for a promised fee, one or more aspiring female models supposedly for Epstein to use as a personal assistant. The Defendants did not care whether the prospective female was qualified to work as a personal assistant because each knew that the female recruit would be immediately placed into the same sexually vulnerable position as Plaintiff (and the dozens of other victims of the sex trafficking enterprise) and would be induced and coerced into being used for sex through fraudulent representations and other means. + +56. Defendants Epstein and Maxwell continuously and frequently demanded that Plaintiff fulfill this task of bringing another female back to the United States and Defendants' control as a condition of Plaintiff's receiving the education, career and related benefits promised by Defendants Epstein and Maxwell. Based upon Plaintiff's experience with Defendants, however, she knew that the requested female model would not be placed in a legitimate position of employment with Defendant Epstein but would, instead, be forced into sexual servitude. Plaintiff also knew that this objective was the only purpose of Defendants , Groff, Maxwell and Epstein's demand for Plaintiff's recruitment efforts. As a result, Plaintiff deliberately refused to perform the recruitment assignment. + +57. As part of their ongoing scheme, Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts with Epstein and others. While Plaintiff was in South Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be permitted to return to the United States to receive her promised education unless she underwent a diet and lowered her body weight from 57 kilograms (approximately 125 pounds) to 52 kilograms (approximately 114 pounds). Epstein and Maxwell promised Plaintiff that, if she complied, she would receive her promised education. Defendant Groff monitored Plaintiffs progress in losing weight and continued to communicate with Plaintiff about Plaintiff's application to be admitted into F.I.T. as part of the Defendants' ruse to coerce Plaintiff to return to the United States for sex. Defendant Groff was aware of the coercion Epstein and Maxwell were applying to Plaintiff and acted to help further that coercion. Believing she had no practical choice in the matter, Plaintiff attempted to comply with the order but, given her physical height and body structure and her already existing body weight, the diet imposed upon her placed her in serious physical jeopardy, including kidney malfunction and extreme emotional and psychological distress. + +58. As part of their scheme, Defendants Epstein and Maxwell called Plaintiff's parents in South Africa to tell them that Defendant Epstein would take good care of Plaintiff when she returned to the United States, and that Defendants Maxwell and Epstein would use their connections and influence to have her admitted to F.I.T. or another well-regarded fashion school or school of higher learning. + +59. As part of their scheme, Epstein and Groff told Plaintiff that she should fill out an application for admission to F.I.T., and supporting essay, and send it to Epstein for his review. Pursuant to these instructions, Plaintiff completed an application, and supporting essay, and sent it to Epstein. As part of his scheme, Epstein told Plaintiff that he had reviewed these materials. His statements were intended to convince Plaintiff, and had the effect of convincing plaintiff (as they would have convinced any reasonable person), that her admission to F.I.T. was a "done deal" if she would comply with his instructions. Groff also made the same representations to plaintiff on Epstein's behalf. Plaintiff reasonably relied on these representations by Epstein and Groff. + +60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had contacts at F.I.T. and at modeling agencies who could ensure her admission to F.I.T. and advance Plaintiff's career. As part of their scheme, Epstein and Maxwell told Plaintiff about Epstein's vast wealth and specifically identified him as a billionaire. Epstein and Maxwell told Plaintiff that they had extensive + +contacts, in addition to those identified above, throughout New York City and elsewhere. + +61. In February of 2007, in reliance on promises made by the Defendants, Plaintiff returned to New York City, in the Southern District of New York, and was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants Maxwell, Groff, and Epstein each fraudulently promised Plaintiff again that her sexual compliance would be rewarded with admission to F.I.T. or a comparable college, a promise which they each knew to be false. In fact all four Defendants had for years worked solely to recruit females for sex and to conceal the operation of the sex scheme, and in 2007 were under Federal investigation for their conspiracy to engage in Federal sexual crimes like those committed against Plaintiff. Plaintiff knew that if she did not comply, Defendants Maxwell and Epstein would use their power, influence and connections in order to ensure that Plaintiff was unable to gain admission to F.I.T. or a comparable school, and that they would destroy her career, just as they had destroyed the careers of others who had failed to comply with their demands. + +62. Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiff's continued compliance with Epstein's sexual demands; however, they failed and refused to perform their promises to help Plaintiff be admitted to F.I.T. or another school, or to provide financial support for college admission or on-going education, false promises they repeatedly made in order to coerce her into commercial sex acts. + +63. Defendants' sexual demands on Plaintiff continued while she was in New York City, in the Southern District of New York, or in other locations in close proximity to the Defendants. In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, each of the Defendants continued to pressure her to lose excessive amounts of body weight and offered her no opportunity to decline or resist their instructions. + +64. In May, 2007, Plaintiff left the United States and did not return. Between returning from South Africa in February 2007 and leaving in May 2007, Defendants =, Groff, and Maxwell each continued to repeatedly make false representations to Plaintiff, including false and fraudulent representations that she would be admitted to F.I.T. if she continued to engage in sex with Epstein. Defendant Epstein continued to make similar false and fraudulent promises in order to have sex with Plaintiff. + +65. In and after May 2007, Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's coverup included efforts to intimidate witnesses who might provide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done. + +66. Unknown to Plaintiff, Defendants' representations and promises to Plaintiff were all false and fraudulent. Plaintiff reasonably relied on the representations and promises of the Defendants. Plaintiff also considered the Defendants' threats against the current and future well-being and safety of Plaintiff to be real and credible. All such representations, promises, and threats were made solely for the purpose of coercing and otherwise inducing Plaintiff into prolonged sexual compliance. Defendants knowingly benefitted financially and received things of value as a result of coercing and inducing Plaintiff into sexual compliance and otherwise participating in their illegal venture and enterprise. + +## COUNT I CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C. 1595 + +67. Plaintiff adopts and realleges paragraphs 1 through 66 above. + +68. Defendants individually and together, within the special maritime and territorial jurisdiction of the United States, in interstate and foreign commerce, and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, maintained, patronized, solicited, threatened, forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by Defendants were undertaken with knowledge and/or reckless disregard of the fact that their threats of force, fraud, coercion, and combinations of such means would be used, and were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In so doing, Defendants violated 18 U.S.C. §1591. + +69. Additionally, Defendants Epstein, Maxwell, and individually and together, knowingly concealed, removed, confiscated, and possessed Plaintiff's passport and associated immigration documents, in the course of violating 18 U.S.C. § 1591, and with the intent of violating 18 U.S.C. § 1591, and to prevent, restrict, attempt to restrict, without lawful authority, Plaintiff's liberty to move or travel, in order to maintain the sexual services of Plaintiff, while Plaintiff was a victim of a severe form of sex trafficking, as defined in section 103 of the Trafficking Victims Protection Act of 2000, enacted in 22 U.S.C. § 7102. In so doing, Defendants violated 18 U.S.C. § 1592. These Defendants also obstructed, and attempted to obstruct and to interfere with the enforcement of 18 U.S.C. § 1592. + +70. Additionally, Defendants knowingly benefitted, financially and by receiving things of value, from participating in a venture (the Epstein sex trafficking venture enterprise) which had engaged in acts in violation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in such violations. In so doing, Defendants violated 18 U.S.C. § 1593A. + +71. Additionally, Defendants attempted to violate 18 U.S.C. § 1591. In so doing, Defendants violated 18 U.S.C. § 1594(a). + +72. Additionally, Defendants conspired with each other, and with other persons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants violated 18 U.S.C. § 1594(6). + +73. Additionally, Defendants conspired with each other, and with other persons known and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendants violated 18 U.S.C. § 1594(c). + +74. By virtue of their violations of 18 U.S.C. §§ 1591, 1592, 1593A, and 1594, Defendants are subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their violations. + +75. Certain property of Defendant Epstein's was essential to the commission of the federal crimes and torts described herein, including the use of multiple private aircraft including a Boeing aircraft (of make and model B-727-31H with tail number N908JE) and a Gulfstream aircraft (of make and model G-1159B with tail number N909JE). Such aircraft, along with other of Defendants' property, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. + +76. Additionally, Defendant Epstein's New York mansion, located at 9 East 71st Street, New York, New York, in the Southern District of New York, and his private island located in the United States Virgin Islands, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. + +77. As a direct and proximate result of Defendants' commission of the aforementioned criminal offenses enumerated in 18 U.S.C. § 1591, 1592, 1593A, and 1594, and the associated civil remedies provided in § 1595, Plaintiff has in the past suffered and will continue to suffer injury and pain; emotional distress; psychological and psychiatric trauma; mental anguish; humiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of enjoyment of life; invasion of privacy; and other damages associated with Defendants' actions. Plaintiff will incur further medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to these losses, Plaintiff has incurred attorneys' fees and will be required do so in the future. + +WHEREFORE, Plaintiff demands judgment against Defendants for compensatory and general damages, attorney's fees, punitive damages and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury. + +Dated: June 5, 2017. + +Respectfully Submitted, + +JAFFE, WEISSING. FISTOS, LEHRMAN, P.L. + +B : J. J. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954)-524-2820 Fax: (954)-524-2822 Email: brad@pathtojustice.com PRO HAC VICE + +BOLES, SCHILLER & FLEXNER LLP David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 (919) 749-8200 Fax: (914) 749-8300 Email: dboies@bsfllp.com + +Sigrid McCac.ile Meredith Boies Schiller & Flexner LLP 401 East Las Olas Blvd., Ste. 1200 Fort Lauderdale, Florida 33301 (954) 356-0011 Fax: Email: smccawley@bsfllp.com Email: mschultz@bsfllp.com PRO HAC VICE + +Paul G Cassell S.J. Quinney College of Law at the University of Utah 383 S. University Street Salt Lake City, UT 84112-0730 (801)-585-5202 Fax: (801)-585-2750 Email: cassellp@law.utah.edu. PRO HAC VICE + +This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation + +#### CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on the 5th day of June, 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. + +STEPTOE & LLP + +Michael C. + +Justin Y.K. + +mmiller@steptoe.com, cjenkins@steptoe.com, pparker@steptoe.com jchu@steptoe.com cienkins@steptoc.com pparker@steptoe.com psafirstein@steptoc.com + +Attorneys for Defendants Jeffrey Epstein & Lesley Groff + +ALSTON & BIRD, LLP + +John E. Stephenson, Jr. + +Alexander S. Lorenzo + +alexander.lorenzo@alston.com autodocket-nyc@alston.com managingclerksoffice-nyc @al ston.com, john.stephenson@alston.com + +Attorneys for Defendant + +By: /s/ J. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820265/EFTA02820265.metadata.json b/marker2/court-jane-doe-43/EFTA02820265/EFTA02820265.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..604f5510d349d2c2d91c28ca50f9affdb567447a --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820265/EFTA02820265.metadata.json @@ -0,0 +1,1279 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820265.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 32, + "chars": 43436, + "elapsed_seconds": 3.67, + "image_assets": [], + 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DECLARATION OF SIGRM MCCAWLEY IN SUPPORT OF PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT CHISLAINE MAXWELL'S MOTION TO DISMISS + +I, Sigrid McCawley, declare that the below is true and correct to the best of my knowledge as follows: + +- I. I am a Partner with the law firm of Boies, Schiller & Flexner LLP and duly licensed to practice in Florida and before this Court pursuant to this Court's Order granting my Application to Appear Pro Hac Vice. +- 2. I respectfully submit this Declaration in Support of Plaintiff's Memorandum of Law in Opposition of Defendant Ghislaine Maxwell's Motion to Dismiss. +- 3. Attached hereto as Exhibit 1 is a true and correct copy of Plaintiff's First Amended Complaint filed on June 05, 2017 (DE 45). + - 4. Attached hereto as Sealed Exhibit 2 is a + +iPlaintiff originally filed this action under the pseudonym "Jane Doe 43," but is now proceeding under her real name. + +I declare under penalty of perjury that the foregoing is true and correct. + +Dated: May 7, 2018. + +Respectfully Submitted, + +BOLES, SCHILLER & FLEXNER LLP + +By: /s/ Sigrid McCawley + +Sigrid McCaS (Pro Hac Vice) + +Meredith (Pro Hac Vice) + +Boies Schiller & Flexner LLP + +401 E. Las Olas Blvd., Suite 1200 + +Ft. Lauderdale, FL 33301 + +(954) 356-0011 + +J. (Pro Hac Vice) + +POTTINGER LLC + +425 North Andrews Avenue, Suite 2 + +Fort Lauderdale, Florida 33301 + +(954) 524-2820 + +Paul G. Cassell (Pro Hac Vice) + +8.3. Quinney College of Law + +University of Utah + +383 University St. + +Salt Lake City, UT 84112 + +(801) 585-52022 + +2 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on the 7th day of May, 2018, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. + +Kimo S. Peluso Sher Tremonte, LLP 90Broad Street, 23rd Floor New York, NY 10004 k luso@shertremonte.com Counsel for Haddon, & P.C. + +Laura A. Menninger, Esq. Jeffrey Pagliuca. E . HADDON, & 150 East 10th Avenue Denver, Colorado 80203 Email: Imenninger@hmflaw.com inagliuca@hmflaw.com + +John E. Stephenson, Jr. Jonathan D. Parente ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, GA 30309 John.stephenson@alston.com Jonathan.parente@alston.com + +Alexander S. Lorenzo ALSTON & BIRD LLP 90 Park Avenue New York, NY 10016 alexander lorenzo@alston com Counsel for Defendant + +Michael Justin Michael A. Keou h , P.C. 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Met i oiner HADDON, AND P.C. 150 East 10 Avenue Denver, CO 80203 303.831.7364 + +### TABLE OF CONTENTS + +| TABLE OF CONTENTS | i | +|-----------------------------------------------------------------------------------|-----------------------------------------------------------------------------------| +| TABLE OF AUTHORITIES | ii | +| INTRODUCTION | 1 | +| ARGUMENT | 2 | +| I. The facts | 2 | +| II. The amended complaint fails to state a claim for relief | 5 | +| A. The Trafficking Victims Protection Act does not apply to the consensual, adult | | +| relationship described in the amended complaint | 5 | +| B. The amended complaint fails to state a claim for relief | 6 | +| i. | The amended complaint impermissibly lumps all Defendants together in violation of | +| Rule 8 | 6 | +| ii. The amended complaint fails to plead fraud | 7 | +| iii. The amended complaint fails to plead coercion | 7 | +| iv. The amended complaint fails to plead a causal link | 9 | +| v. Sections 1592, 1593A, and 1594(a)-(c) do not provide relief | 9 | +| III. The amended complaint is untimely | II | +| CONCLUSION | 13 | +| CERTIFICATE OF SERVICE | 14 | + +### TABLE OF AUTHORITIES + +### Cases + +| Abarca v. Little, 54 | F. Supp. 3d 1064, 1070 (D. Minn. 2014) | 13 | +|-------------------------------------------------|------------------------------------------------------------------|---------------------------------------| +| Bell Atlantic Corp. v. Twombly, | 550 U.S. 544, 553-54 (2007) | 10 | +| FTC v. Silueta Distribs., Inc., | No. C 93-4141 SBA, 1995 WL 215313, at *12 n.5 (N.D. Cal. Feb. | | +| 24, 1995) | | 11 | +| Harris v. Mills, | 572 F.3d 66, 72 (2d Cir. 2009) | 9 | +| v. Women's Div., Gen. Bd. of Global Ministries, | | 284 F.Supp.2d 15, 25 (D.D.C.2003). 11 | +| lqbal v. Ashcroft, | 556 U.S. 662, 678 (2009) | 9 | +| Metawave Commc'ns Corp. Sec. Litig., | 298 F. Supp. 2d 1056, 1090 (W.D. Wash. 2003) | 11 | +| Meyers v. Schriro, | No. CV08-0078-PHX-GMS, 2010 WL 2471914, at •6 (D. Ariz. June 15, | | +| 2010) | | 11 | +| Oluch v. Drina, | 101 F. Supp. 3d 325, 330 (S.D.N.Y. 2015) | I3 | +| United States v. Marcus, | 487 F. Supp. 2d 289 (E.D.N.Y. 2007) | 5 | + +### Statutes + +| 18 U.S.C. § 1591 | 8 | +|-----------------------------------|----------| +| 18 U.S.C. § 1595 | 1, 12 | +| 18 U.S.C. §§ 1592, 1593A, or 1594 | 5, 9, 10 | + +Defendant Ghislaine Maxwell submits this reply memorandum of law in support of her motion to dismiss: + +**INTRODUCTION** + +Try as she might, [REDACTED] cannot salvage the myriad deficiencies in her amended complaint. Nor can she avoid the law and logic of the motions to dismiss, which demonstrate the amended complaint's flaws and the futility of allowing yet another amendment. In particular, [REDACTED] has no persuasive rebuttal to this fundamental fact: The Trafficking Victim's Protection Act (TVPA), 18 U.S.C. § 1595, does not apply to the conduct about which she now complains, conduct she willingly and consensually engaged in more than ten years ago. [REDACTED] have come to regret her consensual relationship with Mr. Epstein, but that does not mean she was the victim of unlawful sex trafficking or that Ms. Maxwell is somehow liable for it. + +To the contrary, [REDACTED], an adult, college-educated women, sophisticated in the ways of relationships and living large, knew exactly what she was doing. [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] Sex trafficking it was not. + +## ARGUMENT + +### I. THE FACTS + +Without the shield of confidentiality,1 the Court can now confirm what was already clear from any fair reading of the amended complaint: [REDACTED] was not the victim of sex trafficking, and the sole claim she now presents is barred by the longest potentially applicable statute of limitations. + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +1 In response to the motions to dismiss filed by Mr. Epstein, Ms. Groff, and [REDACTED] [REDACTED] relied on material outside her deposition transcript and exhibits in the [REDACTED] Matter. (Doc. # 115, p. 24). In response to Ms. Maxwell's motion to dismiss, [REDACTED] incorporates these arguments and authorities by reference. (Doc. # 128, p. 22 (citing Doc. # 115, p. 24-26)). Although Ms. Maxwell is not a party to the Confidentiality Stipulation and Order, that order now permits Defendants to rely on any evidence [REDACTED] produced in the prior matter. (Doc. # 100, ¶ 2). + +[Redacted text block] + +[Redacted text block] + +[Redacted text block] + +[Redacted text block] + +[Redacted text block] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] It is beyond comprehension how Mr. Epstein could be liable for sexually trafficking [REDACTED] based on an alleged promise to secure her admission to F.I.T. when [REDACTED] never even applied. How Ms. Maxwell could be derivatively liable is even more unfathomable. + +In turn, [REDACTED] cannot plausibly allege that her claim, such as it is, accrued after January 26, 2007. [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] Necessarily, then, [REDACTED] + +[REDACTED] claim accrued no later than January 22, 2007 (likely even sooner), more than ten years before she filed her complaint. + +This is not and never will be a sex trafficking case. It is the story of a brief, consensual relationship between two adults occurring more than ten years ago. For these reasons, as elaborated below, this case must be dismissed with prejudice. + +#### II. THE AMENDED COMPLAINT FAILS TO STATE A CLAIM FOR RELIEF + +The TVPA does not apply to the conduct at issue in this case. Even charitably construed, Plaintiff's complaint does not plead fraud with particularity; it fails to plead reasonable reliance, coercion, or causation; it fails to state a claim under 18 U.S.C. §§ 1592, 1593A, or 1594; and it is barred by the statute of limitations. For these reasons, as well as those given in the motions to dismiss and replies in support thereof filed by Mr. Epstein, Ms. Groff, and this Court should dismiss this case with prejudice.2 + +#### A. The Trafficking Victims Protection Act does not apply to the consensual, adult relationship described in the amended complaint + +Mr. Epstein and had a brief, consensual relationship in which sex was exchanged for benefits. Whatever the propriety of that relationship, it's the type of relationship sought out and consented to. It is not sex trafficking. Sex trafficking under the TVPA requires proof of fraud or coercion, something that did not occur here. + +In hoping to convince this Court otherwise, stakes her claim to the decision in United States v. Marcus, 487 F. Supp. 2d 289 (E.D.N.Y. 2007), rev'd in pan and aff'd in part, 628 F.3d 36 (2d Cir. 2010). (Doc. # 128, p. 4-5). But Marcus is nothing like the facts alleged here. Marcus involved physical and emotional torture, violence, abuse, and actual fraud and coercion. It was anything but consensual. In fact, the Second Circuit was careful to note that + +2 Ms. Maxwell adopts and incorporates by reference all of the arguments advanced by Mr. Epstein, Ms. Groff, and M=. (Doc. # 125-1; Doc. # 127). In addition, Ms. Maxwell here reiterates the arguments that this Court should strike paragraphs 11 through 33 of the amended complaint and that dismissal is additionally required because this Court is not the proper forum. (Doc. # 120, p. 4 & n.1; Doc. # 125, p. 4-5, 15). + +“consensual BDSM activities alone could not constitute the basis for a conviction under the sex trafficking charges.” 628 F.3d at 45. + +Promising that she has “not yet had the opportunity to present the extent of sexual abuse she suffered,” Plaintiff avoids the reality that she must adequately *plead* “force, fraud or coercion.” Here, lacking allegations of force, Plaintiff instead asserts conclusory and implausible allegations of fraud and coercion. [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] The TVPA simply does not apply to the adult, consensual relationship at issue here, one that [REDACTED] enjoyed and exploited. + +**B. The amended complaint fails to state a claim for relief** + +**i. The amended complaint impermissibly lumps all Defendants together in violation of Rule 8** + +[REDACTED] denies that she impermissibly lumps all Defendants together. (Doc. # 128, p. 5-7). But in responding to the motions to dismiss, [REDACTED] unwittingly undermines her own argument. + +Take just one example. In defending her claim that some or all of the “Defendants” withheld her passport and restricted her travel, without specifying when her passport was taken from her, (Am. Compl. ¶¶ 45, 49, 51, 54), [REDACTED] says: “Defendants Epstein, Maxwell, and [REDACTED], *both individually and together*, took possession of her passport.” (Doc. # 115, p. 16). This is nothing but another example of impermissible lumping. + +Was her passport taken three times, once by each defendant? Was her passport taken once, by all three Defendants at the same time? Which passport was taken, her U.K. passport or her South African passport? There's no way to know, because the amended complaint doesn't say. + +**ii. The amended complaint fails to plead fraud** + +In addition to all the reasons given in the motion to dismiss, one undisputed fact is enough to dispense with the fraud claim: [REDACTED] never applied to F.I.T. The amended complaint does not allege that she ever applied [REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[REDACTED] has no response to this undisputed fact. (Doc. # 128, p. 11; Doc. # 115, p. 9-11). Her fraud claim fails. + +**iii. The amended complaint fails to plead coercion** + +Ms. Maxwell's motion to dismiss showed why the amended complaint failed to plausibly plead coercion. (Doc. # 115, p. 14-16). In response, [REDACTED] does nothing but quote the conclusory and implausible allegations contained in the amended complaint, including her tried-and-true lump pleading practices. (Doc. # 128, p. 11-13). + +In particular, [REDACTED] claims that she was "coerced" into sexual compliance with promises of "an education, living quarters, and other benefits." (*Id.* at 12). But promises of this sort are not coercive under the law; coercion under the TVPA requires threats of serious harm. + +18 U.S.C. § 1591(e)(2). Here, [REDACTED] could not have been “seriously harmed” if she stopped receiving benefits she had no entitlement to in the first place. + +As a fallback, [REDACTED] points to her allegation that “[d]uring many sexual encounters, Defendant Epstein gave [her] no option, opportunity, or choice not to participate in the prescribed sexual acts.” (*Id.* at 12 (citing Am. Compl. ¶ 46)). She also claims that Mr. Epstein “did in fact cause her physical harm and used his power to coerce [REDACTED] into compliance.” (*Id.* at 13 (citing Am. Compl. ¶¶ 40-63)). How Ms. Maxwell is responsible for this alleged conduct is left entirely unexplained and absent from the amended complaint. + +[REDACTED] + +There was no coercion by Ms. Maxwell. + +**iv. The amended complaint fails to plead a causal link** + +In arguing that she plausibly alleged a causal link, [REDACTED] says only this: + +[REDACTED] has properly pled a causal link between Defendants' fraudulent and coercive acts and [REDACTED] engaging in commercial sex acts: + +Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind. + +(Doc. # 128, p. 13 (quoting Am. Compl. ¶ 49)). ■ + +That is nothing but a conclusory assertion of causation. It is not entitled to any weight before this Court. *See Harris v. Mills*, 572 F.3d 66, 72 (2d Cir. 2009) (“[T]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” (quoting *Iqbal v. Ashcroft*, 556 U.S. 662, 678 (2009))). + +**v. Sections 1592, 1593A, and 1594(a)–(c) do not provide relief** + +Because [REDACTED] has no claim under Section 1591, neither does she have a claim under Section 1592. (Doc. # 120, p. 17). [REDACTED] denies this by asserting that “Defendants Epstein, Maxwell, and [REDACTED], both individually and together, took possession of her passport.” (Doc. # 115, p. 16). This is exactly the type of conclusory assertion that cannot survive a motion to dismiss under *Twombly/Iqbal*. [REDACTED] provides no description of which passport was taken, when, by whom, for how long, or with what effect. + +[REDACTED] + +[REDACTED] + +There is nothing in the amended complaint plausibly showing that anyone took her passport “in the course of violating” Section 1951. + +[REDACTED] does not seriously defend her allegation of liability under Section 1953. The amended complaint is devoid of any allegation as to how Ms. Maxwell supposedly benefitted financially from participating in Mr. Epstein’s “improper” scheme. Nor can [REDACTED] articulate how a 2008 addition to the statute applies to alleged conduct predating its enactment. Like Section 1592, Section 1593 has no application here. + +In addition, this case is not properly brought under Section 1954(a)-(c). Nothing in [REDACTED] opposition changes what Ms. Maxwell said in her motion to dismiss. To the contrary, [REDACTED] response cannot explain how this case involves an alleged attempt; [REDACTED] entire theory is that the Defendants *succeeded* in trafficking her. In turn, just because [REDACTED] has sued multiple people does not mean there was a conspiracy. [REDACTED] must actually and plausibly allege *an agreement*, something she hasn’t done. *See Bell Atlantic Corp. v. Twombly*, 550 U.S. 544, 553-54 (2007). + +Finally, at the time of the events in this case, subsections 1594(b) and 1594(c) were criminal provisions having nothing to do with a civil action. (Doc. # 120, p. 18). [REDACTED] does not address this fact in her opposition. (Doc. # 128, p. 14). This Court should construe this + +failure as a concession that has no claim under either subsection 1594(b) or subsection 1594(c). See v. Women's Div., Gen. Bd. of Global Ministries, 284 F.Supp.2d 15, 25 (D.D.C.2003) ("[W]hen a plaintiff files an opposition to a dispositive motion and addresses only certain arguments raised by the defendant, a court may treat those arguments that the plaintiff failed to address as conceded." (applying local rule)); see also Meyers v. Schriro, No. CV08-0078—PHX—GMS, 2010 WL 2471914, at \*6 (D. Ariz. June 15, 2010) (construing opposition's failure to address one defendant as consent to dismissal of that defendant); In re Metawave Commc 'ns Corp. Sec. Litig., 298 F. Supp. 2d 1056, 1090 (W.D. Wash. 2003) (interpreting failure to address issue in opposition as Plaintiff's concession that motion to dismiss be granted as to that issue); FTC v. Silueta Distribs., Inc., No. C 93-4141 SBA, 1995 WL 215313, at \*12 n.5 (N.D. Cal. Feb. 24, 1995) (viewing failure to oppose portion of motion as concession that motion should be granted). + +## III. THE AMENDED COMPLAINT IS UNTIMELY + +Ms. Maxwell's motion to dismiss explained why the four-year statute of limitations applied and why Congress did not, through the Trafficking Victims Protection Reauthorization Act (TVPRA), intend to enlarge the statute of limitations to ten years. (Doc. # 120, p. 20-23). Whatever power Congress may have had to extend the statute of limitations, no such extension was intended. + +In response, again attempts to misdirect this Court. With no citation to any legal authority, claims that, "[o]f course, to satisfy a statute of limitations, only one act must have been committed inside the relevant time period." (Doc. # 128, p. 22). "Of course," this is not correct. If claim accrued more than ten years before she filed her first complaint on January 26, 2017, then it is time barred under even view of the + +case. See 18 U.S.C. § 1595(c)(1) (“No action may be maintained under [the TVPA] unless it is commenced not later than . . . (1) 10 years after the cause of action arose.”) + +That is precisely what happened here, as [REDACTED] amended complaint makes clear. As alleged in the amended complaint, [REDACTED] “knew” by January 2007, “based upon [her] experience” with Mr. Epstein, that the Defendants were engaged in a fraudulent and coercive scheme to traffick her for sex. (Am. Compl. ¶ 55-56). By this point, as even the amended complaint admits, [REDACTED] knew this scheme was “[il]legitimate.” (*Id.* ¶ 56). Yet she waited more than ten years to file her lawsuit, a delay that bars her from proceeding now. + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +As a matter of law, therefore, her claim under the TVPA accrued no later than January 22, 2007. See, e.g., Oluch v. Orina, 101 F. Supp. 3d 325, 330 (S.D.N.Y. 2015) (Section 1595 claim accrued when plaintiff first left defendant's home); Abarca v. Little, 54 F. Supp. 3d 1064, 1070 (D. Minn. 2014) (Section 1595 claim accrued when plaintiff traveled home to Mexico and had "physical freedom"). Her complaint in this case, first filed more than ten years later, is untimely. + +## CONCLUSION + +For these reasons, as well as those previously provided, Ms. Maxwell respectfully requests that this Court dismiss this case with prejudice. + +Dated: May 21, 2018. + +Respectfully submitted, + +s/ Laura A. Menninger + +Laura A. Or (.115a tal). + +HADDON, AND P.C. + +150 East 10 Avenue + +Denver, CO 80203 + +Phone: 303.831.7364 + +Fax: 303.832.2628 + +Imenninger@hmflaw.com + +Attorneys for Ghislaine Maxwell + +#### CERTIFICATE OF SERVICE + +I certify that on May 21, 2018, I served the accompanying Reply Memorandum of Law in Support of Ghislaine Maxwell's Motion to Dismiss on the following counsel of record: + +Sigrid S. McCawley Meredith Boies, Schiller & Flexner, LLP 401 East Las Olas Boulevard, Ste. 1200 Fort Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com + +r Mi POTTINGER LLC 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com + +John E. Stephenson, Jr. Jonathan D. Parente Alexander S. Lorenzo ALSTON & BIRD, LLP 90 Park Avenue New York, NY 10016 john.stephenson@alston.com jonathan.parente@alston.com alexander.lorenzo@alston.com + +Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu + +Michael C. Justin Y.K. Michael A. Keou h STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoe.com jchu@steptoe.com mkeough@steptoe.com + +s/ Nicole \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820302/EFTA02820302.metadata.json b/marker2/court-jane-doe-43/EFTA02820302/EFTA02820302.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9e3435ce7358f151e334942c615dc453c2c16bd4 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820302/EFTA02820302.metadata.json @@ -0,0 +1,1119 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820302.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 17, + "chars": 22330, + "elapsed_seconds": 137.27, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 71.28 + ], + [ + 418.5074768066406, + 71.28 + ], + [ + 418.5074768066406, + 100.10302734375 + ], + [ + 192.78000000000003, + 100.10302734375 + ] + ] + }, + { + "title": "REPLY MEMORANDUM OF LAW IN SUPPORT OF GHISLAINE \nMAXWELL'S MOTION TO DISMISS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 95.47200000000001, + 387.18 + ], + [ + 516.9287109375, + 387.18 + ], + [ + 516.9287109375, + 420.1209411621094 + ], + [ + 95.47200000000001, + 420.1209411621094 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 238.06800000000004, + 71.28 + ], + [ + 374.5343933105469, + 71.28 + ], + [ + 374.5343933105469, + 86.2330322265625 + ], + [ + 238.06800000000004, + 86.2330322265625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 229.5, + 71.28 + ], + [ + 383.96685791015625, + 71.28 + ], + [ + 383.96685791015625, + 86.2330322265625 + ], + [ + 229.5, + 86.2330322265625 + ] + ] + }, + { + "title": "Cases", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 69.156, + 97.19999999999999 + ], + [ + 105.0146484375, + 97.19999999999999 + ], + [ + 105.0146484375, + 112.4830322265625 + ], + [ + 69.156, + 112.4830322265625 + ] + ] + }, + { + "title": "Statutes", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 69.156, + 428.49 + ], + [ + 117.06278991699219, + 428.49 + ], + [ + 117.06278991699219, + 443.68353271484375 + ], + [ + 69.156, + 443.68353271484375 + ] + ] + }, + { + "title": "INTRODUCTION", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 254.59199999999998, + 127.98000000000002 + ], + [ + 354.96, + 127.98000000000002 + ], + [ + 354.96, + 140.94 + ], + [ + 254.59199999999998, + 140.94 + ] + ] + }, + { + "title": "ARGUMENT", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 268.05600000000004, + 72.08999999999999 + ], + [ + 342.72, + 72.08999999999999 + ], + [ + 342.72, + 84.24 + ], + [ + 268.05600000000004, + 84.24 + ] + ] + }, + { + "title": "I. 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GHISLAINE MAXWELL, LESLEY GROFF, and NATALYA + +Defendants. + +X + +17-cv-00616-JGK + +## Declaration of Laura A. Menninger in Support of Defendant ( ; h Maine Maxwell's Reply Memorandum of Law in Support of the Motion to Dismiss + +I, Laura A. Menninger, declare as follows: + +1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, & la, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell's Reply Memorandum in Support of the Motion to Dismiss. + +2. Attached as Sealed Exhibit C + +I declare under penalty of perjury that the foregoing is true and correct. + +Dated: May 21, 2018. + +s/ Laura A. Menninger Laura A. Menninger + +## CERTIFICATE OF SERVICE + +I certify that on May 21, 2018, I served the accompanying Declaration of Laura A. Menninger in Support of Defendant Ghislaine Maxwell's Reply Memorandum of Law in Support of the Motion to Dismiss on the following counsel of record: + +Sigrid S. McCawley Meredith Boies, Schiller & Flexner, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com + +J. POTTINGER LLC 425 Noah Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com + +John E. Stephenson, Jr. Jonathan D. Parente Alexander S. Lorenzo ALSTON & BIRD, LLP 90 Park Avenue New York, NY 10016 john.stephenson@alston.com jonathan.parente@alston.com alexander.lorenzo@alston.com + +Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu + +Michael C. r Justin Y.K. Michael A. 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Menninger + +150 East 10th Avenue Denver, Colorado 80203 pH 303.831.7364 rx 303.832.2628 www.hmflow.com Imenninger@hmflow.com + +May 21, 2018 + +## Via ECF + +Hon. John G. Koeld United States District Judge United States District Court Daniel Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 + +Re: v. Jeffrey Epstein, et at, 17-cv-00616 (JGK) + +Dear Judge Koeltl: + +This letter motion seeks the Court's permission to file an un-redacted copy of Defendant Ghislaine Maxwell's Reply in Support of Motion to Dismiss, and Exhibit C to the Declaration of Laura A. Menninger in Support of the Reply in Support of Motion to Dismiss, under seal pursuant to paragraph 1(c) of the Court's Confidentiality Stipulation and Order (Doc. #100) dated January 19, 2018. + +Ms. Maxwell has redacted any references to deposition exhibits as provided in the Court's Confidentiality Stipulation and Order (Doc. #100). 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Menninger + +150 East 10th Avenue +Denver, Colorado 80203 +PH: 303 831 7364 FX: 303 832 2628 +www.hmflaw.com +Imenninger@hmflaw.com + +May 21, 2018 + +Via ECF + +Hon. John G. Koeltl +United States District Judge +United States District Court +Daniel [REDACTED] Moynihan Courthouse +Southern District of New York +500 Pearl Street, Room 1940 +New York, New York 10007-1312 + +APPLICATION GRANTED +SO ORDERED + +*John G. Koeltl* +John G. Koeltl, U.S.D.J. +5/22/18 + +Re: [REDACTED] v Jeffrey Epstein, et al , 17-cv-00616 (JGK) + +Dear Judge Koeltl: + +This letter motion seeks the Court's permission to file an un-redacted copy of Defendant Ghislaine Maxwell's Reply in Support of Motion to Dismiss, and Exhibit C to the Declaration of Laura A. Menninger in Support of the Reply in Support of Motion to Dismiss, under seal pursuant to paragraph 1(c) of the Court's Confidentiality Stipulation and Order (Doc. #100) dated January 19, 2018. + +Ms. Maxwell has redacted any references to [REDACTED] deposition exhibits as provided in the Court's Confidentiality Stipulation and Order (Doc. #100). Accordingly, Ms. Maxwell respectfully requests that she may file her unredacted brief and exhibit under seal. + +Respectfully submitted, +HADDON, [REDACTED] AND [REDACTED], P.C. + +*/s/ Laura A. Menninger* +Laura A. Menninger + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC# \_\_\_\_\_ +DATE FILED: 5/23/18 + +Hon. John G. Koeltl +May 21, 2018 +Page 2 + +**CERTIFICATE OF SERVICE** + +I certify that on May 21, 2018, I served the accompanying Letter Motion on the following counsel of record: + +Sigrid S. McCawley +Meredith [REDACTED] +Boies, Schiller & Flexner, LLP +401 East Las Olas Boulevard, Ste. 1200 +Ft. 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Lorenzo +ALSTON & BIRD, LLP +90 Park Avenue +New York, NY 10016 +john.stephenson@alston.com +jonathan.parente@alston.com +alexander.lorenzo@alston.com + +*/s/ Nicole* [REDACTED] +Nicole [REDACTED] \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820324/EFTA02820324.metadata.json b/marker2/court-jane-doe-43/EFTA02820324/EFTA02820324.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..caf63b39a00f0cfea38d7e64f6f21f4ad6320951 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820324/EFTA02820324.metadata.json @@ -0,0 +1,137 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820324.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2551, + "elapsed_seconds": 6.48, + "image_assets": [ + "_page_0_Picture_22.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Via ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 125.46000000000001, + 198.45000000000002 + ], + [ + 170.13600000000002, + 198.45000000000002 + ], + [ + 170.13600000000002, + 210.60000000000002 + ], + [ + 125.46000000000001, + 210.60000000000002 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 240.516, + 102.87 + ], + [ + 387.396, + 102.87 + ], + [ + 387.396, + 115.01999999999998 + ], + [ + 240.516, + 115.01999999999998 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 29 + ], + [ + "SectionHeader", + 3 + ], + [ + "PageHeader", + 2 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 16 + ], + [ + "PageHeader", + 3 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820324" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820324/_page_0_Picture_22.jpeg b/marker2/court-jane-doe-43/EFTA02820324/_page_0_Picture_22.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..da503e5886cc53314ae736e3ed55e7a992243f9b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820324/_page_0_Picture_22.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9aa0d423dfa90480a63677bfb87507da25ef05efa43b5d825af40cadbb0ee812 +size 4438 diff --git a/marker2/court-jane-doe-43/EFTA02820326/EFTA02820326.md b/marker2/court-jane-doe-43/EFTA02820326/EFTA02820326.md new file mode 100644 index 0000000000000000000000000000000000000000..9a11844d0c1387d1bcf1d9d9680ff8c34b913ae4 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820326/EFTA02820326.md @@ -0,0 +1,25 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, Plaintiff(s), + +## NOTICE OF ORAL ARGUMENT + +-against- + +EPSTEIN, 17 civ 616 (JGK) Defendant(s). X + +To All Parties. + +You arc directed to appear for oral argument on the pending motion(s), to be held on Friday, July 27, 2018, at 2:30pm, in Courtroom 14A, before the Honorable John G. Koeltl. + +All requests for adjournments must be made in writing to the Court. + +For any further information, please contact the Court at (212) 805-0107. + +Dated: New York, New York July 23. 2018 + +Court se Manager + +![](_page_0_Picture_14.jpeg) + +Do lets r \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820326/EFTA02820326.metadata.json b/marker2/court-jane-doe-43/EFTA02820326/EFTA02820326.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0a7e70285856fc24374a053597bf4d6fa9eee29b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820326/EFTA02820326.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820326.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 603, + "elapsed_seconds": 0.72, + "image_assets": [ + "_page_0_Picture_14.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "NOTICE OF ORAL ARGUMENT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 353.736, + 144.17999999999998 + ], + [ + 542.5361328125, + 144.17999999999998 + ], + [ + 542.5361328125, + 159.80352783203125 + ], + [ + 353.736, + 159.80352783203125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 27 + ], + [ + "Text", + 12 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820326" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820326/_page_0_Picture_14.jpeg b/marker2/court-jane-doe-43/EFTA02820326/_page_0_Picture_14.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c48b05b2c80c2d34452a793529dca3cc57edafa0 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820326/_page_0_Picture_14.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:edcd5df3b37b252e39a28ba18abaed74446e58897b4775cc608d6e9af5366746 +size 16572 diff --git a/marker2/court-jane-doe-43/EFTA02820327/EFTA02820327.md b/marker2/court-jane-doe-43/EFTA02820327/EFTA02820327.md new file mode 100644 index 0000000000000000000000000000000000000000..2774c8fbf384ec42326406aacf80d7b514b711c5 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820327/EFTA02820327.md @@ -0,0 +1,49 @@ +![](_page_0_Picture_1.jpeg) + +Haddon, and S Pa Laura A. Menninger + +150 East 10th Avenue Denver. Colorado 80203 pm 303.831.7364 rx 303.832.2628 www.hmflow.com Imenninger@hmfIcnv.com + +July 24, 2018 + +## Via ECF + +Hon. John G. Koeld United States District Judge United States District Court Daniel Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 + +Re: v. Jeffrey Epstein, et at, 17-cv-00616 (JGK) + +Dear Judge Koeltl: + +Yesterday, this Court scheduled an oral argument for this Friday, July 27, 2018 at 2:30 p.m. On behalf of defendant Ghislaine Maxwell, this letter requests an adjournment of that Oral Argument. After consultation with the other parties and subject to this Court's approval, Ms. Maxwell requests an adjournment to September 24-26, or August 21-24. Counsel for plaintiff and for defendant Jeffrey Epstein and Lesley Groff do not oppose the adjournment. Counsel for has not responded with a position. + +The grounds for seeking this adjournment are as follows. Counsel for Ms. Maxwell is unavailable this Friday due to pre-existing family travel plans; co-counsel for Ms. Maxwell likewise is out of town this week. Second, counsel for three of the parties will travel from out of state for purposes of the oral argument and a setting further out will allow for more efficient travel arrangements. + +Under these circumstances, and for reasons of efficiency, we request an adjournment of the Oral Argument to September 24-26, or August 21-24. + +Hon. John G. Koeltl July 24, 2018 Page 2 + +Respectfully submitted, + +HADDON, AND P.C. + +Is/ Laura A. Menninger + +Laura A. Menninger + +## CERTIFICATE OF SERVICE + +I certify that on July 24, 2018, I served the accompanying Letter Motion on the following counsel of record: + +Sigrid S. McCawley Meredith Boies, Schiller & Flexner, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com + +J. POTTINGER LLC 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com + +John E. Stephenson, Jr. Jonathan D. Parente Alexander S. Lorenzo ALSTON & BIRD, LLP 90 Park Avenue New York, NY 10016 john.stephenson@alston.com jonathan.parente@alston.com alexander.lorenzo@alston.com + +Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu + +Michael C. r Justin Y.K. Michael A. Keou h STEPTOE & LLP 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoe.com jchu@steptoe.com mkeough@steptoe.com Alexander Seton Lorenzo John E. Stephenson Jr. Alston & Bird, LLP 90 Park Avenue New York, NY 10016 alexander.lorenzo@alston.com john.stephenson@alston.com + +Isl Nicole + +Nicole \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820327/EFTA02820327.metadata.json b/marker2/court-jane-doe-43/EFTA02820327/EFTA02820327.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b2b0de9273500c7554a4f1e0a9d221af34a3f6dc --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820327/EFTA02820327.metadata.json @@ -0,0 +1,153 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820327.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2663, + "elapsed_seconds": 0.87, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Via ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 123.01200000000001, + 212.22000000000003 + ], + [ + 174.42080688476562, + 212.22000000000003 + ], + [ + 174.42080688476562, + 227.60302734375 + ], + [ + 123.01200000000001, + 227.60302734375 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 250.308, + 241.38 + ], + [ + 415.94989013671875, + 241.38 + ], + [ + 415.94989013671875, + 255.7330322265625 + ], + [ + 250.308, + 255.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 37 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 110 + ], + [ + "Line", + 55 + ], + [ + "Text", + 13 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820327" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820327/_page_0_Picture_1.jpeg b/marker2/court-jane-doe-43/EFTA02820327/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3959c4b84b39a5fcaedbf0e76f23852017ab7c0f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820327/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:f72ff030b422d2643086dcf837e0f9cdd8684faa3bf0526a21dc6c1fc0296462 +size 6359 diff --git a/marker2/court-jane-doe-43/EFTA02820329/EFTA02820329.md b/marker2/court-jane-doe-43/EFTA02820329/EFTA02820329.md new file mode 100644 index 0000000000000000000000000000000000000000..6f3cf594032b7cd0df0f631d9496c0fb7b5acf27 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820329/EFTA02820329.md @@ -0,0 +1,95 @@ +![](_page_0_Picture_2.jpeg) + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC# DATE FILED: \_ 1/95/15\_ + +July 24, 2018 + +## Via ECF + +Hon. John G. Koeltl United States District Judge United States District Court Daniel Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 + +Haddon, ancl Laura A. Wessinger + +150 East 101h Avenue Denver. Colorado 80203 P., 303 831 7364 FI 303 832 2628 www hmtlow corn irnenntngerefirnflaw.c orn + +rite Co,n- Ho& 02nt. + +.4/1-(iiit'le#1( 0, ideS0fiy vevir 7 Afg Avast-Wee /1'9,10vA,r, ear. + +So oa-geA-69. S 9 + +Re: v. Jeffrey Epstein, et al, I 7-cv-00616 (JGK) + +Dear Judge Koeltl: + +Yesterday, this Court scheduled an oral argument for this Friday, July 27, 2018 at 2:30 p.m. On behalf of defendant Ghislaine Maxwell, this letter requests an adjournment of that Oral Argument. After consultation with the other parties and subject to this Court's approval, Ms. Maxwell requests an adjournment to September 24-26, or August 21-24. Counsel for plaintiff and for defendant Jeffrey Epstein and Lesley Groff do not oppose the adjournment. Counsel for has not responded with a position. + +The grounds for seeking this adjournment are as follows. Counsel for Ms. Maxwell is unavailable this Friday due to pre-existing family travel plans; co-counsel for Ms. Maxwell likewise is out of town this week. Second, counsel for three of the parties will travel from out of state for purposes of the oral argument and a setting further out will allow for more efficient travel arrangements. + +Under these circumstances, and for reasons of efficiency, we request an adjournment of the Oral Argument to September 24-26, or August 21-24. + +Hon. John G. Koeltl +July 24, 2018 +Page 2 + +Respectfully submitted, + +HADDON, [REDACTED] AND [REDACTED], P.C. + +*/s/ Laura A. Menninger* + +Laura A. Menninger + +### CERTIFICATE OF SERVICE + +I certify that on July 24, 2018, I served the accompanying Letter Motion on the following counsel of record: + +Sigrid S. McCawley +Meredith [REDACTED] +Boies, Schiller & Flexner, LLP +401 East Las Olas Boulevard, Ste. 1200 +Ft. Lauderdale, FL 33301 +smccawley@bsfllp.com +mschultz@bsfllp.com + +Paul G. Cassell +383 S. University Street +Salt Lake City, UT 84112 +cassellp@law.utah.edu + +[REDACTED] J. [REDACTED] +[REDACTED] POTTINGER LLC +425 North Andrews Ave., Ste. 2 +Ft. Lauderdale, FL 33301 +brad@pathtojustice.com + +Michael C. [REDACTED] +Justin Y.K. [REDACTED] +Michael A. Keough +STEPTOE & [REDACTED], LLP +1114 Avenue of the Americas +New York, NY 10036 +mmiller@steptoe.com +jchu@steptoe.com +mkeough@steptoe.com +Alexander Seton Lorenzo +John E. Stephenson Jr. +Alston & Bird, LLP +90 Park Avenue +New York, NY 10016 +alexander.lorenzo@alston.com +john.stephenson@alston.com + +John E. Stephenson, Jr. +Jonathan D. Parente +Alexander S. Lorenzo +ALSTON & BIRD, LLP +90 Park Avenue +New York, NY 10016 +john.stephenson@alston.com +jonathan.parente@alston.com +alexander.lorenzo@alston.com + +*/s/ Nicole* + +Nicole [REDACTED] \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820329/EFTA02820329.metadata.json b/marker2/court-jane-doe-43/EFTA02820329/EFTA02820329.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e4b35ecea44a471f84bcfb9c477bf2c4d376cb14 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820329/EFTA02820329.metadata.json @@ -0,0 +1,145 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820329.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3040, + "elapsed_seconds": 5.85, + "image_assets": [ + "_page_0_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Via ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 127.29599999999999, + 202.29168701171875 + ], + [ + 173.7831268310547, + 202.29168701171875 + ], + [ + 173.7831268310547, + 215.4505615234375 + ], + [ + 127.29599999999999, + 215.4505615234375 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 240.516, + 227.61 + ], + [ + 388.00800000000004, + 227.61 + ], + [ + 388.00800000000004, + 239.76 + ], + [ + 240.516, + 239.76 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 112 + ], + [ + "Line", + 48 + ], + [ + "Text", + 14 + ], + [ + "PageHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 26 + ], + [ + "PageHeader", + 3 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820329" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820329/_page_0_Picture_2.jpeg b/marker2/court-jane-doe-43/EFTA02820329/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..03bae6cf33827b4a183ee43209954a73093b8bac --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820329/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:67a67b796d9cf2f6dd7a2e21921d7e10d2d13cc9dbcc1185d547b8a72a9ca3d8 +size 4522 diff --git a/marker2/court-jane-doe-43/EFTA02820331/EFTA02820331.md b/marker2/court-jane-doe-43/EFTA02820331/EFTA02820331.md new file mode 100644 index 0000000000000000000000000000000000000000..f2e3f6c2c07e7de830c787b369b25a98801281bd --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820331/EFTA02820331.md @@ -0,0 +1,65 @@ +SAO 154 (10/03) Substitution of Attorney + +# UNITED STATES DISTRICT COURT + +SOUTHERN + +District of + +NEW YORK + +JANE DOE 43 + +Plaintiff (s), + +## CONSENT ORDER GRANTING SUBSTITUTION OF ATTORNEY + +V. + +JEFFERY EPSTEIN, GHISALINE MAXWELL, +[REDACTED] LESLEY GROFF, Defendant (s), +AND NATALYA [REDACTED] + +CASE NUMBER: 17-cv-00616-JGK + +Notice is hereby given that, subject to approval by the court, [REDACTED] substitutes [REDACTED] (Party (s) Name) + +Michael C. [REDACTED], State Bar No. 2066256 as counsel of record in (Name of New Attorney) + +place of John E. Stephenson, Jr. (Name of Attorney (s) Withdrawing Appearance) + +Contact information for new counsel is as follows: + +Firm Name: Steptoe & [REDACTED] LLP + +Address: 1114 Avenue of the Americas + +Telephone: (212) 506-3900 Facsimile (212) 506-3950 + +E-Mail (Optional): mmllier@steptoe.com + +I consent to the above substitution. + +Date: 8/6/18 + +[Signature of Party (s)] + +I consent to being substituted. + +Date: 8/3/18 + +[Signature of Party (s)] + +I consent to the above substitution. + +Date: 8/6/18 + +[Signature of New Attorney] + +The substitution of attorney is hereby approved and so ORDERED. + +Date: + +Judge + +[Note: A separate consent order of substitution must be filed by each new attorney wishing to enter an appearance.] \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820331/EFTA02820331.metadata.json b/marker2/court-jane-doe-43/EFTA02820331/EFTA02820331.metadata.json new file mode 100644 index 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b/marker2/court-jane-doe-43/EFTA02820332/EFTA02820332.md @@ -0,0 +1,83 @@ +SAD 154 (\*003) Substitution of Attorney + +# UNITED STATES DISTRICT COURT + +SOUTHERN + +District of + +NEW YORK + +JANE DOE 43 + +Plaintiff (s), + +V. + +CONSENT ORDER GRANTING +SUBSTITUTION OF ATTORNEY + +JEFFERY EPSTEIN, GHISALINE MAXWELL, + +CASE NUMBER: 17-cv-00618-JGK + +[REDACTED] LESLEY GROFF, Defendant (s). + +AND NATALYA MALYSHEV, + +Notice is hereby given that, subject to approval by the court, [REDACTED] substitutes + +(Party (s) Name) + +Michael C Miller , State Bar No 2066256 as counsel of record in +(Name of New Attorney) + +place of John E Stephenson, Jr + +(Name of Attorney (s) Withdrawing Appearance) + +Contact information for new counsel is as follows: + +Firm Name: Steptoe & Johnson LLP + +Address: 1114 Avenue of the Americas + +Telephone: (212) 506-3900 Facsimile: (212) 506-3950 + +E-Mail (Optional): mmiller@steptoe.com + +I consent to the above substitution. + +Date: 8/6/18 + +[Signature] +(Signature of Party (s)) + +I consent to being substituted. + +Date: 8/3/18 + +[Signature] +(Signature of Party (s)) + +I consent to the above substitution. + +Date: 8/6/18 + +[Signature] +(Signature of New Attorney) + +The substitution of attorney is hereby approved and so ORDERED. + +Date: 8/6/18 + +[Signature] +Judge + +[Note: A separate consent order of substitution must be filed by each new attorney wishing to enter an appearance.] + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC# +DATE FILED: 8-7-18 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820332/EFTA02820332.metadata.json b/marker2/court-jane-doe-43/EFTA02820332/EFTA02820332.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4aa51e5cf7c70ec87bd26354510754739264695f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820332/EFTA02820332.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820332.pdf", 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KOELTL, District Judge: + +For the reasons stated on the record at the argument held today, August 7, 2018, the motions to dismiss filed by Jeffrey Epstein, [REDACTED], Lesley Groff, and Ghislaine Maxwell are denied. + +The Clerk of Court is directed to close all pending motions. + +SO ORDERED. + +Dated: New York, New York +August 7, 2018 + +![]()United States District Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820333/EFTA02820333.metadata.json b/marker2/court-jane-doe-43/EFTA02820333/EFTA02820333.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..be6c8f78d852445a3e930a80efa5112178e8b58f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820333/EFTA02820333.metadata.json @@ -0,0 +1,113 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820333.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 643, + "elapsed_seconds": 3.99, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 65.484, + 49.41 + ], + [ + 277.848, + 49.41 + ], + [ + 277.848, + 75.33 + ], + [ + 65.484, + 75.33 + ] + ] + }, + { + "title": "ORDER", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 369.64799999999997, + 132.03000000000003 + ], + [ + 410.65200000000004, + 132.03000000000003 + ], + [ + 410.65200000000004, + 144.17999999999998 + ], + [ + 369.64799999999997, + 144.17999999999998 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 54 + ], + [ + "Text", + 27 + ], + [ + "Line", + 27 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "Caption", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820333" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820334/EFTA02820334.md b/marker2/court-jane-doe-43/EFTA02820334/EFTA02820334.md new file mode 100644 index 0000000000000000000000000000000000000000..270ea6f7bf2008df79bea39c83ef1774d242be31 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820334/EFTA02820334.md @@ -0,0 +1,56 @@ +•• + +- against - + +## • • UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff(s), + +Defendant(s). + +JOHN G. KOELTL, District Judge: + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOCk r).5.-re Fit Fr) ,er/er + +/7 Civ. (JGK) + +## CIVIL SCHEDULING ORDER + +Pursuant to Fed. R. Civ. P. 16(b), after holding a conference in this matter on + +the Court hereby orders that: + +• / 04,4 D i enza — e 4-443,04., tii(3//q. + +Pleadi gs and Parties: Except for good cause shown: + +- I. No additional parties may be joined or cause of action asserted after +- 2. No additional defenses may be asserted after 7/42 7- h g . + +Discovery: Except for good cause shown, all discovery shall be commenced in time to be completed by /AI 57/9 . The Court expects discovery to be completed within 60 days of the first scheduling conference unless, after the expiration of that 60 day period, l lI counsel stipulate that additional time (not to exceed 60 more days) is needed to complete discovery. The expert disclosures required by Fed. R. Civ. P. 26(a)(2) shall be made at least 30 days before the completion of discovery. + +Dispositive Motions:\* Dispositive motions, if any, are to be completed by O2 ;51/ The parties are advised to comply with the Court's Individual Practice 2(B) regarding motions, and to submit one fully briefed set of courtesy copies to the Court. + +Pretrial Order/Motions in Limine:\* A joint pretrial order, together with any motions in limine or motions to bifurcate, shall be submitted by Jhh 9, . In jury cases, parties shall submit requests to charge and voir dire requests. In non-jury cases, parties shall also submit + +&#x27; Note: In the event a dispositive motion is made, the dates for submitting theJoint Pretrial Order (together with Memoranda of Law, Requests to Charge, Proposed Voir Dire, Proposed Findings of Fact and Conclusions of Law, as appropriate) shall be changed from that shown above tothree (3) weeks from the decision on the motion. The ready trial date shall be adjourned to a date four (4) weeks after the decision on the dispositive motion. The final pretrial conference, if any, will be scheduled by the Deputy Clerk. + +At any time after the ready for trial date, counsel must notify the Court and their adversaries in writing of any potential scheduling conflicts, including, but not limited to, trials and vacations, that would prevent a trial at a particular time. Such notice must come before counsel are notified by the Court of an actual trial date, not after. Counsel should notify the Court and all other counsel in writing, at the earliest possible time of any particular scheduling problems involving out-of-town witnesses or other exigencies. + +proposed findings of fact and conclusions of law. The pretrial order shall conform to the Court's Form Joint Pretrial Order, a copy of which may be obtained from the Deputy Clerk. + +Trial:\* The parties shall be ready for trial on 7hours notice on or after The estimated trial time is y days, and this a jury /non jury trial. 3//51) 7. + +## Other: + +1/- + +The case is referred to the Magistrate Judge for purposes of settlement (see attached Reference Order). + +The parties will notify the Court by , 12/ whether-a-Feference-to•the whether they consent to trial before the Magistrate Judge. The parties may communicate with the Court with respect to these matters by joint letter. If the parties consent to trial before the Magistrate Judge, they are directed to do so by stipulation. + +SO ORDERED. + +Dated: New York, New York + +traT7 JO G. 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KOELTL, District Judge: + +X + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC# +DATE FILED: 8/8/18 + +17-cv-616 (JGK) + +ORDER OF REFERENCE +TO A MAGISTRATE JUDGE + +X + +The above entitled action is referred to the designated Magistrate Judge for the following purpose(s): + +\_\_\_ General Pretrial (includes scheduling, discovery, non-dispositive pretrial motions, and settlement) + +\_\_\_ Consent under 28 U.S.C. §636(c) for all purposes (including trial) + +\_\_\_ Specific Non-Dispositive Motion/Dispute:\* + +\_\_\_ Consent under 28 U.S.C.§636(c) for limited purpose (e.g., dispositive motion, preliminary injunction) + +\_\_\_\_\_ +\_\_\_\_\_ + +Purpose: \_\_\_\_\_ + +If referral is for discovery disputes when the District Judge is unavailable, the time period of the referral is: \_\_\_\_\_ + +\_\_\_ Habeas Corpus + +\_\_\_ Social Security + +\_\_\_ X\_\_ Settlement\* + +\_\_\_ Dispositive Motion (i.e., motion requiring a Report and Recommendation) + +\_\_\_ Inquest After Default/Damages Hearing + +Particular Motion: \_\_\_\_\_ + +All such motions: \_\_\_\_\_ + +SO ORDERED. + +DATED: New York, New York +August 7, 2018 + +![]()\* Do not check if already referred for general pretrial. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820336/EFTA02820336.metadata.json b/marker2/court-jane-doe-43/EFTA02820336/EFTA02820336.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a7e2598be6859bd2abd213de3fc027c02f025eae --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820336/EFTA02820336.metadata.json @@ -0,0 +1,119 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820336.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1330, + "elapsed_seconds": 6.64, + "image_assets": [ + "_page_0_Picture_174.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 37.944, + 26.73 + ], + [ + 260.712, + 26.73 + ], + [ + 260.712, + 53.46 + ], + [ + 37.944, + 53.46 + ] + ] + }, + { + "title": "ORDER OF REFERENCE TO A MAGISTRATE JUDGE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 427.176, + 151.47 + ], + [ + 593.64, + 151.47 + ], + [ + 593.64, + 177.39000000000001 + ], + [ + 427.176, + 177.39000000000001 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 92 + ], + [ + "Text", + 57 + ], + [ + "Line", + 46 + ], + [ + "SectionHeader", + 3 + ], + [ + "PageHeader", + 2 + ], + [ + "Footnote", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820336" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820336/_page_0_Picture_174.jpeg b/marker2/court-jane-doe-43/EFTA02820336/_page_0_Picture_174.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..fd8cb97673fcff42bf4bbb11082cb0e00f3cdcb7 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820336/_page_0_Picture_174.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:1d0248f6f7d5e4188c8caa0bd0806a90d846a2ca72ba4f739aa9de9d9c70ac04 +size 1873 diff --git a/marker2/court-jane-doe-43/EFTA02820337/EFTA02820337.md b/marker2/court-jane-doe-43/EFTA02820337/EFTA02820337.md new file mode 100644 index 0000000000000000000000000000000000000000..9de5d98af6edcb06b1444447bd31baeb01c608b2 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820337/EFTA02820337.md @@ -0,0 +1,36 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +-against- + +JEFFREY EPSTEIN, et al., + +Plaintiff, + +Defendants. + +X + +X + +| USDC SDNY | | +|----------------------|-----------| +| DOCUMENT | | +| ELECTRONICALLY FILED | | +| DOC #: | | +| DATE FILED: | 8/14/2018 | + +17-CV-00616 (JGK)(SN) + +ORDER + +## SARAH NETBURN, United States Magistrate Judge: + +On Wednesday, August 8, 2018, the Honorable John G. Koeltl assigned this matter to my docket for settlement. In light of the Court's busy calendar, settlement conferences must generally be scheduled at least six to eight weeks in advance. The Court will likely be unable to accommodate last-minute requests for settlement conferences, and the parties should not anticipate that litigation deadlines will be adjourned in response to late requests for settlement conferences. As soon as practicable, the parties are directed to contact Courtroom Deputy Rachel Slusher with both parties on the line, at (212) 805-0286, to schedule a settlement conference for a time when they believe it would be productive. + +SO ORDERED. + +SAIC INIC TBURN -- United States Magistrate Judge + +DATED: August 14, 2018 New York, New York \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820337/EFTA02820337.metadata.json b/marker2/court-jane-doe-43/EFTA02820337/EFTA02820337.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ac32163da6ffc0ab0a2d9d2a1ce6aa82b0724f02 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820337/EFTA02820337.metadata.json @@ -0,0 +1,113 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820337.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1260, + "elapsed_seconds": 1.2, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 72.08999999999999 + ], + [ + 293.59381103515625, + 72.08999999999999 + ], + [ + 293.59381103515625, + 100.10302734375 + ], + [ + 69.156, + 100.10302734375 + ] + ] + }, + { + "title": "SARAH NETBURN, United States Magistrate Judge:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 298.08 + ], + [ + 349.39788818359375, + 298.08 + ], + [ + 349.39788818359375, + 313.10302734375 + ], + [ + 69.156, + 313.10302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 32 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Form", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820337" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820338/EFTA02820338.md b/marker2/court-jane-doe-43/EFTA02820338/EFTA02820338.md new file mode 100644 index 0000000000000000000000000000000000000000..4423036693ad64d128c34399feccd7cc1a669f6b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820338/EFTA02820338.md @@ -0,0 +1,1183 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Plaintiff, + +v. 17 Civ. 616 (JGK) + +JEFFERY EPSTEIN, GHISLAINE MAXWELL, , LESLEY GROFF and NATALYA + +Defendants. + +Before: + +x + +New York, N.Y. August 7, 2018 2:30 p.m. + +HON. JOHN G. KOELTL + +District Judge + +## APPEARANCES + +BOIES SCHILLER & FLEXNER LLP Attorneys for Plaintiff BY: SIGRID MCCAWLEY + +S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH Attorneys for Plaintiff BY: PAUL CASSELL + +STEPTOE & LLP Attorneys for Defendants Jeffery Epstein, Lesley Groff and BY: MICHAEL JUSTIN III + +DARREN K. INDYKE LLC Attorney for Defendant Jeffery Epstein BY: DARREN K. INDYKE + +APPEARANCES (Continued) + +HADDON & P.C. Attorneys for Defendant Ghislaine Maxwell BY: LAURA MENNINGER + + ALSO PRESENT: ALEXANDER LORENZO + +4 MS. MCCAWLEY: Sigrid McCawley for the plaintiff, along with my co-counsel Paul Cassell. + +5 6 7 8 9 10 11 12 MR. : Good afternoon, your Honor. Michael and Justin III from the law firm of Steptoe & , and Darren Indyke, who is counsel to Mr. Epstein. We represent Jeffery Epstein and Leslie Groff, and yesterday filed a substitution of counsel with respect to , whose previously existing counsel is also here today, and if the Court is comfortable with the substitution of counsel, we will argue for all three defendants. + +13 THE COURT: I signed it already. + +14 MR. : Fine. Thank you, your Honor. + +15 THE COURT: And it should be on the docket, I think. + +16 17 18 MS. MENNINGER: Good afternoon, your Honor. Laura Menninger, on behalf of Ghislaine Maxwell, from Haddon & + +19 20 21 22 23 MR. LORENZO: Good afternoon, your Honor. Alex Lorenzo from Alston & Bird. As Mr. indicated, we are now predecessor counsel. I saw the order pop on the docket. I wanted to come down in case that there was some issue, but I would request permission to be excused. + +24 25 THE COURT: Yes, you can be excused. Thank you. I did sign the substitution, as you saw. + +(Case called) + +(In open court) + +4 5 All right. OK. I know people personally and professionally at Boies Schiller. I knew Mr. Haddon when I was in private practice. I may know people at Steptoe, but I'm not sure. Nothing about any of that affects anything that I do in the case. + +6 7 8 9 10 I also had dealings with Mr. Boise when I was in private practice. Again, nothing about that affects anything that I do in the case. These are motions to dismiss. I'm familiar with the papers, and I'm prepared to listen to argument. + +11 12 MR. : Your Honor, can I address you from the podium there? + +13 THE COURT: Sure. + +14 15 16 MR. Michael from Steptoe & and as I indicated we are here on behalf of and Jeffery Epstein, Lesley Groff and + +17 18 19 20 21 Your Honor, we respectfully submit that the amended complaint before you is legally deficient and should be dismissed for several reasons, the first of which is that it was not filed timely. Our belief is that the statute of limitations has lapsed. + +22 23 24 25 The amended complaint also fails, your Honor, to properly allege fraud, coercion or force, which are three alternative ways of proving a violation of Section 1591. More broadly, your Honor, it's our view that section 1591 does not + +4 And, lastly, at least in terms of points that we will De making, is that we believe that there have been insufficient allegations of personal jurisdiction. + +5 6 7 8 9 10 11 12 13 In an effort to do this efficiently, your Honor, Ms. Menninger and I have divided up these topics, and if it's all right with the Court, I will be addressing the statute of limitations issue, the allegations of fraud, the scope of Section 1591, and the lack of personal jurisdiction; and Ms. Menninger will be addressing the allegations of coercion and force, the lack of a causal link between those allegations and sexual activity, and the specific allegations with respect to her client. + +14 15 16 17 18 19 20 Your Honor, starting with statute of limitations, Section 1591 was enacted in 2000 with a four year statute of limitations. That was the statute of limitations in effect when the events at issue in this case occurred, and those events as alleged were in 2006 and 2007. Clearly, if the four year statute of limitations applies, the lawsuit was not started in a timely fashion. + +21 22 23 24 25 In late 2008, effective early 2009, Section 1591 was amended to permit a ten year statute of limitations. And I think the preliminary, the threshold issue before the Court today, is whether the four year statute of limitations or the ten year statute of limitations should apply to this case. + +apply to the conduct alleged in this case. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +THE COURT: When the statute was amended to increase the statute of limitations to ten years, the claims were still alive under the four year statute of limitations had the case been brought at that time. + +MR. : That is correct, your Honor. And I am aware that there are two cases here -- I believe they are district court cases -- where that analysis has been applied to conclude that the ten year statute of limitations applies. We cited a case out of the District of Minnesota, the Abarca case, that takes a different view, and the thinking in the Abarca case -- which we think is the correct thinking -- + +THE COURT: So far the thinking in this District is against you. + +MR. : I appreciate that, but I think that the analysis in Abarca, which basically is that Congress had the ability to articulate that it wished to apply it retroactively, wished to apply it to any action that was not time barred at the time of amendment and didn't do so. + +THE COURT: But the issue then becomes a definition of retroactivity. The rules against retroactivity are there to prevent -- unless the legislature otherwise provides -- that a cause of action is not revived or that rights are not otherwise cut off. Here there is nothing that was being revived and there was nothing that was being cut off. Congress simply made a determination that the statute of limitations would be + +lengthened. So there was no need for Congress to say we're 4 5 6 7 8 9 reviving a cause of action that is otherwise barred, which would be the core of a problem of retroactivity. So you have to ask in the first instance if there is a claim of retroactivity, did Congress specifically authorize the retroactive application. In this case there was no retroactive application to be applied; Congress simply lengthened the statute of limitations, and that included all causes of action that were alive at that time. That logic seems to be right. + +10 11 12 13 14 15 16 17 18 MR. : Well, if I can, your Honor, I certainly understand, accept and agree with the proposition as you've articulated it as far as it goes, but I think that the case law with respect to retroactive application isn't limited to vested rights like the statute of limitations has already expired and the new statute of limitations would restore an action that has already ceased to be subject to prosecution under the statute of limitations. It's not limited to reviving an affirmative defense that has already run its course. + +19 20 21 22 23 24 25 I respectfully submit that there is a significant impact on defendants. At the time that the alleged activity occurred here, there was a four year statute of limitations. By expanding it to ten years, at the time that they engaged in that conduct -- if they were even aware of the statute -- they would have been operating under the assumption that there was a four year statute of limitations. + +4 5 6 7 8 9 10 THE COURT: Yes, it would have been -- it is a difficult argument that a defendant can rely upon the statute of limitations which has not yet expired so that the defendant can say, you know, you can't sue me; you have a few more years to sue me, but after that you can't sue me because of this statute of limitations. Much more powerful argument would be a defendant who says I rely on the fact that if I did something more years ago than the statute of limitations, I am now safe. A defendant who is still subject to being sued cannot say to himself or herself I am now safe. + +11 12 13 14 15 16 17 18 19 20 MR. That's undeniable, that is true, but in the same breath you could say that by 2011 or thereabouts certain rights that would have existed under the four year statute of limitations would have matured at that point, and from that date forward, from whatever that four date year was forward, there were certain rights that would have existed but for the amendment of the statute of limitations, and that is something of value that is essentially taken away by a retroactive application of the ten year statute of limitations to conduct that predated the date of the amendment. + +21 22 23 24 25 I sense that I'm sledding uphill, and so perhaps I should push my sled in a different direction, but I do believe that the two district court cases here were incorrectly decided on that theory and that the ten year statute of limitations should not apply. + +But even if it does apply, your Honor, according to the amended complaint, in January of 2007 -- and I guess just 4 5 6 7 8 9 10 11 12 by way of a footnote, the original case on January 26th of 2017 -- so according to the amended complaint complaint was in January of in paragraphs filed in this 2007, 55 to 57, the plaintiff went to South Africa to visit with her family. That's where her live. Under the District, a 2015 father and stepmother and other family members Oluch case which we cited from the Southern case, frankly under the Abarca case from the District of Minnesota that we also cited, the cause of action, if any, that the plaintiff had with respect to the defendants under Section 1591 accrued as of that point in time. + +13 14 15 16 17 18 Under Oluch the Southern District held that the claim accrued when the plaintiff first left the defendant's home. In the Abarca case -- which I grant is the District of Minnesota -- they put it slightly different, when the plaintiff traveled home to Mexico and had "physical freedom" the cause of action accrued. + +19 20 21 22 Under the complaint, the amended complaint as drafted, the plaintiff left New York City, left where Mr. Epstein and the defendants were allegedly located, and went home and had the kind of physical freedom that the Abarca case speaks to. + +23 24 25 Now, the complaint is in all candor vague about when in January of 2007 that trip occurred, and the lack of detail is odd because, as you may recall from earlier stages of this + +case, after the original complaint was filed, we worked out a 4 5 6 7 8 9 process with the Court's consent whereby we provided a deficiency letter to the plaintiff, to counsel, outlining the many, many issues that we had with the complaint at that time, and one of those issues was statute of limitations, and one of the points we made is that, to the best of our knowledge, she left, she was already gone and left New York City before January 26 of 2007, more than ten years before the complaint in this action was actually filed. + +10 11 12 13 14 15 16 There is additional evidence that was addressed in the papers, and from a procedural perspective let me pause for a moment. I would like to be able to speak to the evidence that was gathered in the Joffre case, which is the subject of a protective order. It's all before you, but I just don't know if you have any reservations about me speaking about it openly in court about it today. + +17 THE COURT: I don't. Do any of the parties? + +18 19 20 21 22 I should add that it is not clear to me -- in fact I should put it differently. I think the various items that you rely on from the deposition in the other case are not properly considered by me on this motion, which is a motion to dismiss on several grounds. + +23 24 25 The parties go to great lengths to describe the plaintiff in the most uncomplimentary terms based on the deposition in the other case. Those allegations are plainly + +4 5 not in the complaint in this action. The deposition was taken after the complaint in this action. There is no reasonable legal basis that I see for incorporating the allegations or the statements in the deposition in the other case in support of the motions in this case. + +6 7 8 9 10 11 12 13 The deposition in the other case was taken after the complaint in this case, was not incorporated into the complaint in this case, was plainly not relied upon by the plaintiff in drafting the complaint in this case, and appears to me to be admitted or offered by the defendants solely for purposes of influencing me against the plaintiff in this case, contrary to the facts that are pleaded in this case, and that includes the comments about the statute of limitations. + +14 MR. : If I might, just briefly, your Honor. + +15 THE COURT: Yes, sure. + +16 17 18 19 20 21 MR. : Just two quick points. One is chronologically the original complaint was filed in January of 2017. It's my understanding, my recollection, that the depositions at issue occurred after that but before the first amended complaint was drafted and filed, so from a timing perspective, if that matters in your analysis -- + +22 23 24 25 THE COURT: Thank you. It doesn't. It doesn't. Hold on. I appreciate your correcting the chronology, but the deposition was plainly not relied upon by the plaintiff in drafting this complaint, and the plaintiff doesn't rely upon + +any of the allegations in that deposition for purposes of the allegations in this complaint. + +4 5 6 7 8 9 MR. Well, I think we carefully articulated in our motion papers that the reason we cited to the Joffre evidence was to establish that if the Court agreed that the first amended complaint as drafted was legally insufficient, that a dismissal should be with prejudice, because based on the Joffre evidence there is no available theory under which the case -- the complaint could be repled properly. + +10 11 12 13 14 15 16 17 18 19 20 21 22 THE COURT: That really is not the way in which the deposition was used. It was not used for purposes of saying don't let the plaintiff amend because look at what was said in the deposition. It was used, for example, to say on the statute of limitations that while the complaint alleges activities that continued into February of 2007, you can't believe those allegations because at that time the plaintiff was in fact a willing and knowledgeable person who was doing other things, other things which are not alleged in the complaint. And they were used for purposes of saying you really can't credit the allegations in the complaint of force or fraud, coercion, because look at all of the other things that the plaintiff was doing. + +23 24 25 MR. : Your Honor, I must say, I take ownership of the drafting of that motion. It was our intention, if inartfully framed, to really speak to the ability of the + +4 5 6 7 8 THE COURT: Well, trust me we will not sit down and go over the motion papers. Trust me also that I carefully read all of the motion papers, and I was more than surprised that lawyers of the distinction defense side would do what of the lawyers in this case on the you did. + +9 10 11 12 13 14 15 16 Now, you may say, II, Judge, even though our papers were larded with an explicit discussion of each of the plaintiff's relations with other people, right down to the most recent allegations of the plaintiff's alleged other occupation, all of that, we're not relying on that for our motion to dismiss; we're relying on that for our argument that once having dismissed this complaint you shouldn't let the plaintiff replead. + +17 18 19 20 21 22 23 24 25 You can say that, but I don't think that any reasonable person reading these briefs would come away with that as a conclusion. And also one wonders how that would even make any sense. If I were to grant the motion to dismiss because there are insufficient allegations in the complaint, I should then rely upon the deposition to say that the plaintiff could not replead because I now can read the deposition and rely upon the statements in the deposition, and conclude that any new complaint would not survive a new motion to dismiss, + +plaintiff to replead a legally sufficient complaint. And I would be happy to sit down with you and go over the motion papers as drafted, but -- + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +when the new complaint would plainly not rely upon the specific allegations that the defendants are relying on in the deposition? That would be a difficult argument. Moreover, it is contrary to what you said in the briefs. + +In the briefs you attempted to come up with other reasons for putting all of this in, reasons like the plaintiff started it; we were able to rely upon the deposition because the plaintiff relied on the deposition. Well, that's not quite right, is it? + +You made the motions to dismiss, and then the plaintiff responded to the motions to dismiss. And the plaintiff said, you know, the deposition doesn't really say what you're saying it says. But it was in the motions to dismiss, so -- but go ahead. + +MR. : Your Honor, I will just say I apologize for any unintended confusion on our part about how we intended to use the evidence from the Joffre matter, and -- + +THE COURT: I should add, the amount of the briefs that are devoted to the allegations from the deposition, I haven't counted up words or pages, but there is an awful lot of these briefs that rely upon what was said at the deposition, and under the law that's just not right. Just as a matter of law it's not correct, which is what brought me to my comment of surprise at the defense counsel doing that. + +MR. : Thank you, your Honor. Understood. I + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +will proceed without any further reference to that body of information. + +In addition to the fact that the complaint itself, the amended complaint itself, acknowledges that the plaintiff left New York in January of 2007, the complaint also states that at the time that the plaintiff left in January of 2007 and went to South Africa, that when she went to South Africa she was asked to look for somebody to work as a personal assistant to Mr. Epstein, and she decided not to do that, having concluded that the individual, rather than being treated as an assistant, might be treated in another, you know, less reputable way. And I believe it is fair to conclude from that language in the amended complaint that by the time the plaintiff left New York to go to South Africa in January of 2007, she had already come to a place where in her mind she didn't believe she could trust the defendants or the representations that they were making to her about what they were actually seeking to accomplish with -- + +THE COURT: What do I do, for example, with the allegation in the amended complaint in paragraph 61? "In February of 2007, in reliance on promises made by the defendants, plaintiff returned to New York City, in the Southern District of New York, and was promptly ordered by the defendant Maxwell to have sex with defendant Epstein. Defendants Maxwell, Groff and Epstein each fraudulently promised plaintiff again that her sexual compliance would be + +rewarded with admission to the Fashion Institute of Technology or a comparable college, a promise which they knew to be false." + +4 5 6 7 8 9 10 11 12 MR. : I think in short strokes you have an individual who claims that before she left, or at the time she left New York, she no longer believed the representations made by the defendants to her. That is difficult to reconcile with the notion that she left her family in South Africa to come back to New York based on additional promises and representations made by the defendants. So, we have a fundamental conflict within the four corners of the complaint as drafted. + +13 14 15 16 17 THE COURT: It wouldn't be the first time for a fraud case in which an alleged victim of a fraud came to believe that the victim was defrauded, and the perpetrator goes to the victim and convinces the victim to invest yet again. Those cases are in fact not uncommon. + +18 19 20 21 22 23 24 So, you say there are conflicting allegations in the complaint. That means that they're not really susceptible to a motion to dismiss. They may be susceptible to a motion for summary judgment. But the only way to grant the motion on statute of limitations grounds is to say that paragraph 61 is simply false, it's a false allegation, you can't take it, Judge. + +25 And in order to support that, of course, in your + +4 papers you describe what you say the plaintiff was doing after she returned to New York. But you say, well, we're not relying on that for the motion to dismiss; we're relying on it solely that she can't file an amended complaint. + +5 MR. : That is correct. + +6 7 THE COURT: But then I'm left with the unrebutted paragraph 61. + +8 9 10 11 12 13 14 MR. : The way we read that paragraph is that the allegations were broad, they were conclusory, they don't satisfy Rule 9(b) particularization, and there is no way to read those additional allegations in light of the other allegations in the amended complaint to demonstrate that the plaintiff reasonably relied on whatever new representations were made to her. + +15 16 17 18 So, given the unique definition of Section 1591, it is our view that those allegations about the conduct that occurred between February and May of 2007 don't establish a violation of Section 1591. + +19 20 21 22 23 24 Whatever conduct occurred before January of 2007 - and obviously on the merits, you know, we have a different view of the underlying allegations, but whatever happened before January of 2007, that cause of action accrued at the time the plaintiff left New York and went to South Africa, under the cases that we discussed earlier. + +25 So, our view is that the ten year statute of + +4 5 6 7 Your Honor, Section 1591 requires that the defendants know and, indeed, in some manner of conduct, know that an individual is going to be subject to amongst other things force, coercion or fraud. + +8 9 10 11 12 13 14 15 16 We respectfully submit that the amended complaint as drafted does not satisfy Rule 9(b) pleading standards. The amended complaint fails to allege with particularity when any representations -- specifically when any representations were made to plaintiff about getting her into FIT -- which seems to have been the principal factual allegation in the amended complaint -- or any other particular school, particularly whether any of those representations were made before or after the alleged sexual relationship began. + +17 18 19 20 21 22 23 24 25 In addition, the amended complaint fails to allege with particularity what any particular defendant said to her about her prospects of getting into FIT or any other particular school. There is a heavy reliance throughout the amended complaint on group pleading, which is not embraced in this Circuit, when you're talking about oral statements and representations. And the allegations with respect to defendants Groff and are particularly threadbare and conclusory. + +limitations ran on the activity that occurred before January of 2007 and that the new allegations that were raised don't satisfy the elements of Section 1591. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +The amended complaint also fails to allege with particularity whether anyone promised that the plaintiff would get into FIT or any other similar school in any particular semester. + +The amended complaint fails to allege facts demonstrating that at the time whatever statements were made about FIT, that they were false when made. The law is clear in this jurisdiction that the question is were the statements false at the time they were made. And the fact that there has been inaction in connection with the promises isn't sufficient to show that the statements were false when made. + +The amended complaint contains allegations, your Honor, that strongly suggest to the contrary. The allegations in the complaint are that Mr. Epstein promised to take care of this individual and that he in fact gave her access to an apartment, a car, telephone, and that with respect to the school, that the complaint acknowledges that Epstein reminded the plaintiff about completing her application and reviewing it for her. None of those facts contained in the amended complaint are consistent with the notion that at the time whatever statements were made those statements were false. + +THE COURT: One of the arguments made in the papers is that it was incredible for the plaintiff to believe that defendant Epstein could impact, derail her application to FIT and derail her modeling career, that is simply incredible, or + +the papers say. + +4 MR. : Well, we do make the argument that the plaintiff's reliance on those representations was not reasonable. + +5 6 7 8 THE COURT: Not reasonable because it was incredible to believe that a person of the alleged wealth and prestige of defendant Epstein could in fact derail the plaintiff's education and career. That's the argument. + +9 10 11 12 13 14 MR. : I think the allegations in the amended complaint, your Honor, are that the threat was you'll never go to college anywhere, you'll never get a modeling career going anywhere, and I think that is a pretty broad statement for somebody to reasonably rely upon, regardless of the wealth and power of the individual who is making the statement. + +15 16 17 18 19 20 21 22 23 24 THE COURT: So, it is incredible as a matter of law that a person of alleged wealth and prestige sufficient to own an island could in fact blackball someone from education and a career presumably in New York? I am expected to rule as a matter of law that that's incredible as a matter of law, that that is not reasonable reliance, it just couldn't happen, and no reasonable person could believe that it could happen. Right? I mean your argument is asking me to rule as a matter of law that such a conclusion is incredible as a matter of law, and that, therefore, there is no reasonable reliance. + +25 MR. : Yes. The argument is specifically that + +4 5 THE COURT: What comparable case do you think stands for that proposition? + +6 7 8 9 10 11 12 MR. : Well, I think the threat is just so broad as to be as a practical matter -- regardless of the wealth or prestige of the individual -- an impossible threat to carry through on. The notion that an individual could prevent another individual from going to school anywhere, from pursuing a modeling career anywhere, it stretches the boundaries of what is reasonable reliance. That's the point we were making. + +13 14 15 16 17 18 THE COURT: And my question is what case do you rely on for that proposition with any similar set of circumstances: An alleged -- for purposes of the complaint -- young person versus a person of wealth and prestige, that the kind of promises and alleged threats that were being made were unreasonable as a matter of law? + +19 20 21 22 23 24 25 I mean I understand the reasonable reliance cases in terms of investors and in terms of what should and shouldn't be done in terms of reasonably pursuing an investigation of a company. But is there any comparable case that has said that in a situation such as this, such as alleged in the amended complaint, it should be dismissed as a matter of law on a motion to dismiss? + +relying on the affirmative promises, relying on the alleged very broad allegations of threat, was not reasonable under the circumstances. + +4 5 6 MR. : Your Honor, most of the cases that we looked at did deal with reasonable reliance in the context of investment scenarios with relatively sophisticated parties on both sides. I can't say that we found a case that is specifically on point, so we're really arguing more from the facts than a specific case. + +7 THE COURT: OK. + +8 9 MR. : Your Honor, the last point that I'd like to address is the issue of lack of personal jurisdiction. + +10 11 12 13 14 15 16 I think it's fair to say, based on some of the dialog we've had so far, that it's your view that there are sufficient allegations of conduct in the February to May 2007 time period. But, you know, as we have noted in the papers, virtually all of the conduct that's at issue in this case predated January of 2007, predated the plaintiff's departure from New York to go to South Africa. + +17 18 19 20 21 22 23 The only allegations in the complaint as to the defendants and their current ties to New York relate to Mr. Epstein and a particular piece of real estate. We respectfully submit that the absence of concrete evidence of violations of Section 1591 in 2007 -- as opposed to before the defendant left -- should lead to the conclusion that there is no personal jurisdiction over the defendants. + +24 THE COURT: OK, thank you. + +25 MR. : Thank you. + +4 5 6 MS. MENNINGER: Thank you, your Honor. On behalf of defendant Ghislaine Maxwell, I would ask the Court to dismiss the first amended complaint filed on June 5, 2017. In some ways I want to start in the same place that Mr. did, and that is with the statute itself and its passage. + +7 8 9 10 11 12 Your Honor, in 2007 -- 2006 and 2007 -- when the allegations in the complaint purportedly took place, there was no civil cause of action at all under this chapter other than a violation of 1591. The same amendment which added these ten year statute of limitations also broadened who could be sued and for what. + +13 14 15 16 17 The statute that existed in 2006 and 2007 read, "An individual who is a victim of violation of Section 1589, 1590 or 1591 of this chapter, may bring a civil action against the perpetrator in an appropriate district of the U.S. and may recover damages and reasonable attorney fees." + +18 19 20 21 22 23 24 25 The persons who could be sued under that chapter were perpetrators of the crimes specified in 1589, 1590 and 1591, and the person who could sue was an individual who was a victim under those three statutes. Notably absent is any reference to lawsuits, civil causes of action brought pursuant to other sections of that chapter. Those would include 1592, 1593 and 1594, as well as 1593(a), which was added in December of 2008 and did not previously exist. + +THE COURT: Ms. Menninger. + +4 5 6 THE COURT: The same arguments that I was raising with your colleague would apply to all of these arguments also. At the time that the statute was amended to include the ten year statute of limitations, there was no bar, if you will, to a claim against all of the defendants. + +7 8 9 10 11 12 13 14 MS. MENNINGER: Your Honor, I respectfully would contend that there is a fundamental difference between a statute of limitations that is extended as to conduct that has already occurred versus creating a new cause of action or a new civil remedy. The support for that, your Honor, is the U.S. Supreme Court in Landgraf v. USI Film Products, which I cited in my papers for a different proposition, but it's found at 511 U.S. 244. + +15 16 17 18 19 20 In that case, your Honor, the U.S. Supreme Court was considering a very similar situation with respect to a sexual harassment claim under Title VII. In that case, Title VII, prior to the defendant at issue's conduct, only provided for back pay or equitable remedies, and then in 1991 Congress added a compensatory damage provision. + +21 22 23 24 25 The U.S. Supreme Court spent a great deal of time in Landgraf, explaining that adding a cause of action for damages -- as was done in this statute -- did not retroactively apply unless there was an express finding by Congress to do so. And they distinguished things like extending statutes of + +Paragraphs -- you look like you had a question. + +4 THE COURT: OK. + +5 6 7 8 9 10 MS. MENNINGER: Paragraphs 69 through 77 of the first amended complaint purport to state causes of action under each of those other chapters -- excuse me -- sections of the same chapter, your Honor, and I would ask at the outset that those particular requests be stricken from the first amended complaint. + +11 12 THE COURT: But there would still be the action under 1591. + +13 14 15 16 17 18 MS. MENNINGER: Yes, your Honor. I'm starting from the ones that are really easy, in my opinion, and then moving to 1591, which would be the other one. But it does, your Honor, significantly affect some of the allegations within the first amended complaint. For example, 1592 is the provision that criminalized the taking of the passport, for example. + +19 20 21 22 23 THE COURT: Right. But, in a way, each of the other provisions is subsidiary to 1591. The plaintiff doesn't break out the four separate subsidiary statutes, 1591 and the other three; the plaintiff has only one cause of action for a violation of 1595. + +24 25 MS. MENNINGER: She requests specific damages under some of those statutes, your Honor, for example, forfeiture and + +limitations and, rather, relied on the fact that a new action for damages was being created. And that is what happened in this case with respect to this statute as well, your Honor. + +4 restitution. She relies on a conspiracy theory that is articulated in one of those statutes. She relies on the attempt provision that's included in one of those statutes and, as I mentioned, the passport. + +5 6 7 8 9 10 11 THE COURT: But she one claim, one cause of action for a violation of 1595. What the argument that you have been making so far comes down to is I should give the complaint a haircut by striking some of the allegations in the complaint, even though the case goes forward, and even though allegations like holding the passport could be used in support of a violation of 1591. + +12 13 14 MS. MENNINGER: Your Honor, I was not about to just sit down after that particular argument; I was going to move on to the next one. + +15 THE COURT: OK. + +16 17 18 19 20 21 MS. MENNINGER: So, I guess it would be the first chop in the haircut that I propose that this Court make a complete shaving of the head by the time that we're done. But, in any event, I think those particular statutes clearly do not grant a cause of action to the plaintiff for conduct that occurred prior to Congress authorizing the civil action. + +22 23 24 25 With respect to 1591, your Honor, moving there, the statute as it read at the time permitted a cause of action against the perpetrator, not against someone who was alleged to have been a person who benefited from a venture, which is + +4 5 6 7 something else that is seen replete through the first amended complaint. And it requires, your Honor, the statute 1591 as it existed in 2016, that an individual either recruit, entice, harbor, transport, provide, or obtain by any means a person or benefit financially. Those are what I would -- drawing upon criminal law -- call the actus reus of this particular offense that has been granted a civil cause of action. + +8 9 10 11 12 13 14 15 Your Honor asked earlier with respect to the statute of limitations question why does paragraph 61 of the first amended complaint -- which talks about reliance on promises that occurred after January of 2007 -- how can we just read those out of the first amended complaint. Your Honor, I believe that the way 1591 is read, the act is accomplished - the offense accrues when the recruiting, enticing, harboring, etc. occurs. + +16 17 18 19 20 21 This is not a general fraud statute. Although fraud rears its head in the mens III element, fundamentally the act that is sought to be covered here occurs at the time of the recruitment, the enticement, the harboring, etc., or at the time of benefiting financially. Those are the two provisions of 1591. + +22 23 24 25 So, your Honor, the allegations contained in paragraph 61 of the first amended complaint are not allegations of a recruitment, or an enticement, or a harboring; they are allegations that go to the mens III. Therefore, I would submit + +4 5 6 7 8 Your Honor, moving on to the sections not already covered by Mr. I would point your Honor to the requirement that one of those two acts has to occur knowing that fraud, force or coercion will be used to cause that person to engage in a commercial sex act. + +9 10 With respect to knowing that force will be used, there is no allegation of force in the first amended complaint. + +11 12 13 14 15 16 With respect to fraud, Mr. has already addressed the absence of particular allegations with respect to fraud: The dates, times and circumstances that any particular statement was made. And, your Honor, I will move to the last of those three permitted means of stating a claim, and that is with respect to coercion. + +17 18 19 20 21 22 23 24 25 In their response, plaintiff has pointed to two particular paragraphs that they claim adequately state a claim for coercion -- although they plead it in the alternative, noting as the statute does, that there are three ways that could accomplish the final goal. And they point to paragraph 48, which just says simply that there were threats of serious harm, without stating what any such threats were; and they point to paragraph 49, which is that she was physically returned to the main island on house by a search party at some + +to your Honor that the act has accrued once the recruitment or the enticement happened, not because further acts of purported fraud occurred later. + +4 point in time. And, again, without any dates, it's difficult for the Court or the parties to understand any particular sequence of events, but it is up to the plaintiff to allege sufficient facts that would state a claim, if they were there. + +5 6 7 8 9 10 And, your Honor, there are no facts that show -- I think it's important to look at the statute again, which defines what coercion means in this context, and coercion means under 1591 in existence at the time, threats of serious harm to, or physical restraint against any person, is the primary definition. + +11 12 13 14 15 16 There are not facts other than bald allegations with respect to that definition of coercion. In their response papers they point to a threat that she would no longer be given the same financial benefits that she had been receiving in the past, but that is clearly not what coercion is defined to include in the statute itself under 1591. + +17 18 19 20 Finally, your Honor, with respect to what we will call the causal connection, 1591 states that the person must have known that fraud, force or coercion would occur, would be used to cause the commission of the commercial sex act. + +21 22 23 24 25 Again, your Honor, other than using these several months at a time pleading windows, the complaints have not specified the time when any such thing occurred. And I think that was a conscious choice, because they, I believe -- and we will not talk about other things outside of the four corners of + +the complaint -- it was a choice they made not to include 4 specific dates. Without nothing more than a bald fraud, or coercion would those dates, your Honor, there is assertion that the knowing, the force, cause a commercial sex act. + +5 6 7 8 9 10 11 12 THE COURT: In your papers -- I say it for the first time, unlike other defendants -- you also rely on the fact that the plaintiff was engaged, you say, in another occupation which is inconsistent with the allegations in the complaint. And I could not understand how that allegation could be made in your papers. It's certainly not in the complaint. And I couldn't understand the reason for putting that in or what the effort was in terms of having me rely on that for a decision. + +13 14 15 16 17 18 MS. MENNINGER: Your Honor, I heard you very loud and clear when you were speaking with Mr. , and I too had intended to use evidence from the other deposition in support of an argument that any further amendment of this complaint would be futile, but I'm trying to carefully not mention any of those items during my oral argument. + +19 20 21 THE COURT: OK. If you believe that that's the true reason why that was included in your papers, so be it. Go ahead. + +22 23 MS. MENNINGER: As with the argument regarding fraud and I think there are a number of cases -- + +24 25 THE COURT: II, before we leave that, part of the argument that there was no fraud is there is no -- the + +4 5 plaintiff hasn't pleaded the reasonable basis for concluding that the defendants didn't believe the alleged promises at the time that they were made and, therefore, there is no pleading of fraud, because a promise isn't fraud unless it is knowingly false when made. + +6 7 8 9 10 11 12 13 14 At the same time the defendants ask me to strike all the allegations in the complaint about what happened previously, which would appear to go to the issue of intent under 404(b). Promises were made in the past, they weren't kept, the defendants knew that when they were making promises in this case they weren't going to be kept, and the defendants urge me to simply strike paragraphs in the early part of the complaint as irrelevant. Why don't those paragraphs go to intent on the subject of fraud? + +15 16 17 18 19 20 21 MS. MENNINGER: Your Honor, the intent for purposes of this statute would require knowledge that force, coercion or fraud would be used to induce a commercial setback. Those earlier allegations do not allege force; they do not allege except in very bare terms coercion; they do not allege, except in very bare terms anything with respect to the fraud. + +22 23 24 25 So, for the same reasons that in this District fraud requires particularity, those are very broad, unspecified allegations, divorced from dates, times, places, people's statements, and so it appears for perhaps some of the same + +reasons that your Honor questioned why some of these other things were in our papers, that that is in fact the same reason 4 5 that these other allegations were contained in the first amended complaint, more to make it read as a press release than it was to actually try to make a cause of action. + +6 7 8 THE COURT: There are differences, right, between allegations in a complaint and a legal basis for a motion to dismiss. So, OK. + +9 10 11 12 13 14 15 16 MS. MENNINGER: Your Honor, I would really urge your Honor to look through the complaint with a careful eye towards any places in which an actual time, place, event were specified. We asked for that in our motion to dismiss; we said that there was nothing more than a bald assertion that there was a causal connection; and we were told here is where it says in the amended complaint where it says there is a causal link, but without any reason to show the causal link. + +17 18 19 20 There are ways that your Honor could imagine that a complaint could contain allegations. They could say this happened first and then this happened next, but that's not how any of this read. + +21 22 23 24 25 And the same way that your Honor earlier pointed out how am I supposed to just say because he's have controlled all of higher institutions modeling contracts in this world, if there like he sat on the board of FIT, or he had wealthy he could not of learning and all were allegations a special connection + +4 5 6 7 8 9 10 11 with all of these higher institutions of learning -- like an investor who is defrauded where there have been promises made that an individual has the ability to get a particular return -- there are no facts in here other than the mere mention of wealth and status to suggest under the terms of the amended complaint that this individual, Mr. Epstein, could control all higher institutions of learning or all modeling contracts. But there is even less with respect to my client, your Honor. There are no allegations that she controlled the world of modeling and the world of higher institutions of learning. + +12 13 14 15 So, I would ask your Honor to enforce what is the common rule in this District, that allegations of fraud need to be pled with particularity, and no such particularity exists in this amended complaint. + +16 THE COURT: OK. Thank you. + +17 18 MS. MCCAWLEY: Is it all right if I'm here, or would you prefer if I am at the podium? + +19 20 THE COURT: It's probably better if you are at the podium. + +21 22 MS. MCCAWLEY: If I could just approach the bench; I have come books. + +23 24 THE COURT: All right. It's not so clear why you're offering up a bench book. + +25 MS. MCCAWLEY: Sorry, your Honor. I thought it might + +4 5 6 7 be helpful for you to have in front of you some of the key cases we cited, along with a copy of our amended complaint, and then I have just a couple -- just to make it easy for you to follow -- the bullet points that show where the paragraphs are in the motion to dismiss. They've obviously claimed that we have not properly alleged certain things including fraud and coercion, so I've set this forth. + +8 THE COURT: Go ahead. + +9 10 11 12 13 14 15 MS. MCCAWLEY: So, your Honor, I submit to you that Congress had in mind this exact situation when it enacted 18 U.S.C. 1591, and that was to stop repeat offenders, or repeat traffickers like the defendant in this case, from using fraud and coercion to force females in commercial sex. That's what happened to my client here, and that's what happened to other females, as alleged in our complaint. + +16 17 18 19 So what we have alleged in the complaint -- you've heard a lot from the defendant about various deficiencies. We believe the complaint is fulsome. It includes the allegations that are necessary under the statute. + +20 21 22 23 24 25 The statute makes clear that with respect to the definition of commercial sex, that it is broad and it means any sex act on account of which anything of value is given or received by any person. We believe we have alleged that in our complaint with respect to being used and induced into commercial sex with respect to the defendants, and we + +4 5 6 7 8 9 I want to talk a little bit about the fact that the defendants have claimed that the tightened pleading standard, we haven't met it. First, I believe we have met it. But setting that aside, in the sea of the over 50 cases that they cite in their briefs, there is not one that addresses a sexual trafficking case where this heightened 9(b) issue is discussed. So, they have RICO cases, they have other securities cases, things of that nature, but nothing in this context. + +10 11 12 13 14 15 16 17 18 19 20 21 22 And I submit to you that when Congress enacted this statute, it intended it to be very broad; the language is very broad. It covers not only fraud but also, as we've said, coercion. And while Ms. Menninger was reading to you from the old statute, the statute as it sits today and as it was at the time that our client filed her complaint, defines the term coercion in a much broader manner. It defines it -- and this is in Section 4 of 1591 and (e)(4) -- it says, "The term 'serious harm'" -- so serious harm is one of the pieces of coercion -- "The term 'serious harm' means any harm, whether physical or nonphysical, including psychological, financial, reputational harm that is sufficiently serious under all the surrounding circumstances" -- + +23 24 25 THE COURT: Should I look at the statute at the time that the events occurred? You're not suggesting that if the defendants did something when the statute was somewhat + +believe we have pled that with specificity. + +4 different, and the statute was then amended thereafter, I should look at the amended statute to determine whether what the defendants did at the time that they did it was in violation of the statute? + +5 6 7 8 9 10 11 12 MS. MCCAWLEY: Well, your Honor, first I believe we need we meet both, so let me be clear on that. I believe the complaint as pled meets both standards. I was reading to you the coercion as it stands now with respect to serious harm under the statutory language -- which I believe we've met - and as we talked about with respect to the statute of limitations, that's the Lama v. Malik case and the Oluch case that they referenced. + +13 14 15 16 THE COURT: I mean I understand your argument with respect to the statute of limitations with respect to the length of the statute of limitations and the fact that when the statute was amended the claim was still alive. + +17 18 19 20 21 It's a somewhat different argument to say that at the time the statute was amended the statute made unlawful something that was lawful at the time that the defendants did it. That would seem to run counter to the normal retroactivity practice. + +22 23 24 25 MS. MCCAWLEY: Right, your Honor, I understand. So, I can just move on from that. I believe we've met the fraud and coercion under both the old version and the new version, and I believe we sufficiently articulate that in our complaint, so I + +4 5 6 I did just want to highlight for you very briefly with respect to the claims of fraud and coercion, that we have pled those. I put them in the binder, but they are a number of paragraphs, 38, 40, 41, 52, 53 and 66; and with respect to coercion, 43, 45, 46, 48, 50 and 57. + +7 8 9 10 11 12 13 With respect to the allegation that there was a group pleading or an insufficient pleading with respect to certain of the defendants, we submit to your Honor -- and I put the paragraphs in there -- but we have both allegations particular to the individual defendants, as well as allegations when they pertain to all defendants, we've set that forth in the complaint as well. + +14 15 16 17 18 With respect to reasonable reliance, your Honor touched on this a little bit in the beginning, but we have a number of paragraphs that address that reliance, including 11, 12, 16, 22, 36, 38, 40, and the causal link as well in those and in 49. + +19 20 21 22 23 I will just touch briefly on the jurisdictional argument that was made. We obviously believe we've submitted appropriately that your Honor has jurisdiction in this matter, and if there was any question with respect to jurisdiction we did request in our papers to have a jurisdictional deposition. + +24 25 With respect to the timing on the statute of limitations, you pointed out paragraph 61. We believe that in + +will move forward with respect to that. + +that paragraph we have set forth very sufficiently that while 4 5 6 7 there was an episode where my client, , was sent by the defendants to South Africa for the purposes of recruiting another female and bringing her back to the United States for the purposes of sex, we believe that that allegation is part and parcel of the fraud and coercion that she was susceptible to during that time period, that it carried on, it didn't stop. + +8 9 10 11 There is no magical moment in that time period. She was still under that fraud and coercion at that point, and it continued when she got back to the United States, as alleged in the complaint, up until May of 2007, your Honor. + +12 13 14 15 So, we believe that the complaint sets forth very sufficient allegations in detail about the harm that she was subjected to and the time period within which that harm occurred. + +16 17 And, your Honor, if you have any other questions, I would be happy to answer them. + +18 THE COURT: No, thank you. + +19 All right. I will take a ten minute break. + +20 II, I'm sorry. I should have asked, any response? + +21 MR. : No, your Honor. + +22 THE COURT: Ms. Menninger? + +23 24 MS. MENNINGER: Your Honor, may I be very briefly heard? + +25 THE COURT: Of course. Of course. + +4 5 6 7 8 9 10 11 12 13 14 15 16 MS. MENNINGER: With respect to the statute of limitations question, your Honor, you heard plaintiff say that they rely on the allegations contained in paragraph 61 of their first amended complaint. And, your Honor, in that particular paragraph they do not set forth any activity that could be described as recruiting, enticing, harboring, transporting or obtaining by any means a person, nor do they set forth anybody who has gained a financial benefit. Those are the two requirements of 1591 as it existed in 2006. And without any allegations that any of those activities happened, you know, after January of 2007 when the plaintiff left the country, they have not set forth I think -- and I would submit to your Honor -- any allegations that would restart the accrual period that set off the ten year statute of limitations at best, the four year statute of limitations of course having expired four years earlier. Thank you. + +17 18 THE COURT: OK. Thank you all. I will take ten minutes. + +19 (Recess) + +20 THE COURT: I am prepared to decide the motions. + +21 22 23 24 25 The plaintiff, , brings this action under the Trafficking Victims Protection Reauthorization Act (the "TVPRA"), 18 U.S.C. Section 1595, against the defendants Jeffery Epstein, Ghislaine Maxwell, Lesley Groff and Natalya . The plaintiff alleges that between + +4 5 6 October 2006 and May 2007, the defendants knowingly, coercively, and fraudulently recruited and enticed the plaintiff to engage in commercial sex acts with Jeffery Epstein in violation of 18 U.S.C. Section 1591, and that the defendant engaged in conduct that violated 18 U.S.C. Sections 1592, 1593A and 1594. + +7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Epstein, Groff, Maxwell and to dismiss the plaintiff's amended 12(b)(2), 12(b)(3) and 12(b)(6) of Procedure, and they move to strike 12(f) of the Federal Rules of Civil the Court should strike the portion detailing prior proceedings related have filed motions complaint pursuant to Rules the Federal allegations Procedure. Rules of Civil pursuant to Rule They argue that of the amended complaint to Epstein as impertinent or immaterial to the allegations set forth in the amended complaint and that the amended complaint fails to state a claim for relief under 18 U.S.C. Section 1591 because, first, Section 1591 does not apply to the alleged relationship between the plaintiff and Epstein; second, the amended complaint fails to allege fraud or coercion against any of the defendants; third, the amended complaint impermissibly lumps the defendants together in violation of Rule 8 of the Federal Rules of Civil Procedure; and, fourth, the amended complaint fails to demonstrate that the alleged fraudulent or coercive conduct caused the plaintiff to engage in a commercial sex act. Additionally, with respect to the Section 1591 claim, Groff and + +4 5 6 7 8 argue that the plaintiff fails to allege that either Groff or had sufficient knowledge that the plaintiff was engaged in commercial sex caused by fraud or coercion. With respect to the plaintiff's Section 1592 claim, the defendants argue that the claim should be dismissed because it lacks specific factual support. The defendants also argue that the plaintiff does not allege violations of Sections 1593A and 1594. + +9 10 11 12 13 The defendants also argue that the plaintiff's claims are barred by the statute of limitations set forth in 18 U.S.C. Section 1595(c), that the Court lacks personal jurisdiction over the defendants, and that venue is improper in this District. + +14 15 16 17 18 19 20 21 22 23 24 25 In deciding a motion to dismiss pursuant to Rule 12(b)(6), the allegations in the complaint are accepted as true, and all reasonable inferences must be drawn in the plaintiff's favor. McCarthy v. Dun & Bradstreet Corp., 482 F.3d 184, 191 (2d Cir. 2007). The Court's function on a motion to dismiss is "not to weigh the evidence that might be presented at trial but merely to determine whether the complaint itself is legally sufficient. v. Belden, 754 F.2d 1059, 1067 (2d Cir. 1985). The Court should not dismiss the complaint if the plaintiff has stated "enough facts to state a claim to relief that is plausible on its face." Bell Atl. Corp. v. Twombly, 550 U.S. 554, 570 (2007). "A claim has + +4 5 6 7 8 facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 667 (2009). While the Court should construe the factual allegations in the light most favorable to the plaintiff, "the tenet that a court must accept as true all the allegations contained in the complaint is applicable to legal conclusions." Id. + +9 10 11 12 13 14 15 16 17 When presented with a motion to dismiss pursuant to Rule 12(b)(6), the Court may consider documents that are referenced in the complaint, documents that the plaintiff relied on in bringing suit and that are either in the plaintiff's possession or that the plaintiff knew of when bringing suit, or matters of which judicial notice may be taken. See v. Time Warner, Inc., 282 F.3d 147, 153 (2d Cir. 2002); Millennium Health LLC v. Emblemhealth, Inc., 240 F.Supp. 3d 276, 279-80 (S.D.N.Y. 2017). + +18 19 20 The following facts are taken from the plaintiff's amended complaint and are accepted as true for the purposes of this motion to dismiss. + +21 22 23 24 25 Jeffery Espstein is a wealthy individual who, along with and Lesley Groff, has previously been investigated by Florida state law enforcement and the United States Attorney's office for the Southern District of Florida for various offenses relating to sex trafficking, including 18 + +U.S.C. Section 1591. Amended Complaint paragraphs 11 to 29. + +4 5 6 7 8 9 10 11 12 13 14 15 16 17 The plaintiff alleges that her association with the defendants began in approximately October 2006, when the plaintiff was approached by Natalya the enterprise's recruiters. , allegedly one of informed the plaintiff that she would introduce the plaintiff to Epstein, whom described as a wealthy philanthropist who regularly used his wealth, influence and connections to help financially poor women like the plaintiff achieve their personal and professional goals and aspirations. Amended complaint paragraphs 35 to 36. introduced the plaintiff to Epstein, and Epstein confirmed to the plaintiff that he would use his wealth and influence to have the plaintiff admitted to the Fashion Institute of Technology, ("F.I.T.") in New York City. Between October 2006, and May 2007, each defendant confirmed and reiterated this promise to the plaintiff many times. Amended complaint paragraph 38. + +18 19 20 21 22 23 24 25 Ghislaine Maxwell, who allegedly oversaw the entire sexual enterprise with Epstein, told the plaintiff that in order to reap the benefits of Epstein's and Maxwell's connections, the plaintiff would need to provide Epstein with body massages. Amended complaint paragraph 39. Maxwell allegedly instructed the plaintiff on how to massage Epstein. During the plaintiff's first massage of Epstein, Epstein allegedly converted the massage into a sexual act and made it + +4 5 6 7 8 9 10 11 12 13 known order her. to the plaintiff that further sex would be required in for the plaintiff to obtain the assistance he promised Epstein allegedly told the plaintiff that if she did not perform the sexual act as demanded, Epstein had the ability to make sure that the plaintiff would not obtain either a formal education or any modeling agency contracts. Amended complaint paragraph 43. Maxwell allegedly reiterated to the plaintiff that if the plaintiff did not perform the sexual favors desired by Epstein or abide by the instructions given to her by Epstein, Groff, , and Maxwell, the defendants had the ability to make sure the plaintiff would not obtain formal education or modeling agency contracts. Amended complaint paragraph 41. + +14 15 16 17 18 19 20 21 22 23 24 25 Thereafter, the plaintiff was allegedly instructed dozens of times to provide body massages to Epstein, both at his alleged townhouse in New York City and on his alleged private island in the U.S. Virgin Islands, and on each occasion the plaintiff was required to perform a sexual act with Epstein. Amended complaint paragraph 45. Each defendant participated in arranging these meetings between Epstein and the plaintiff, and each defendant allegedly made representations mainly promises to advance the plaintiff's education cooperate complaint and career - in fulfilling paragraphs 40 to ensure that the plaintiff would Epstein's sexual requests. Amended and 45. The plaintiff alleges that + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +these representations were knowing and deliberately false, were not acted upon by the defendants, and were made by Epstein, Groff, , and Maxwell solely for the purpose of maintaining the plaintiff's financial dependence on, and sexual compliance with, Epstein's demands. Amended complaint paragraph 53. The plaintiff was also allegedly provided with living quarters in New York, a car service and a cell phone, so long as she serviced Epstein sexually. Amended complaint paragraph 52. + +Epstein, Maxwell, , and Groff allegedly intimidated, threatened, humiliated and verbally abused the plaintiff in order to coerce the plaintiff into compliance. Amended complaint paragraph 48 and 50. For example, while being transported to Epstein's island in the U.S. Virgin Islands, Epstein, Maxwell, and took possession of the plaintiff's passport in order to coerce her to comply with their demands, including their demands that the plaintiff have sex with Epstein and others. Epstein and Maxwell also forced the plaintiff into losing weight in order to be allowed to return to the United States from the trip to South Africa. Amended complaint paragraph 54. + +The plaintiff complied with the defendants' instructions, including Maxwell's sexual demands. In May 2007, after still not being granted admission into F.I.T., the plaintiff left the United States and did not return. Amended + +4 5 6 7 8 9 The defendants argue that the portion of the amended complaint related to the prior state and federal investigations of Epstein and others should be stricken from the amended complaint. The defendants argue that these allegations are immaterial because the prior investigations did not involve the plaintiff. The plaintiff argues that the allegations of prior state and federal investigations into Epstein's conduct could be used to show a modus operandi. + +10 11 12 13 14 15 16 17 18 19 20 21 A "court may strike from a pleading an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter." Federal Rule of Civil Procedure 12(f). "Motions to strike are not to be freely granted, and no deletions will be made unless it is clear that the allegations are without [basis]." Laub v. Genway Corp., 60 F.R.D. 462, 465-66 (S.D.N.Y. 1973) (citations and quotations omitted). Moreover, the movants should show that they will be prejudiced if the attacked allegations are left in the pleadings. Allsate Ins. Co. v. Home Ins. Co., No. 97 Civ. 4332, 1997 WL 639254, at \*1 (S.D.N.Y. Oct 15, 1997). As another court in this district noted: + +22 23 24 25 "there has arisen since the adoption of Rule 12(f) general judicial agreement, as reflected in the extensive case law on the subject, that motions to strike under Rule 12(f) should be denied unless the challenged allegations have no + +complaint paragraph 64 to 66. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +possible relation or logical connection to of the controversy and may cause some form prejudice to one or more of the parties to the subject matter of significant the action." + +VNB Realty, Inc. v. Bank of America Corp., No. 11 CV. 6805, 2013 WL 5179197, at \*3 (S.D.N.Y. Sept. 16, 2013) (internal quotation marks, brackets and citations omitted); see also I.B. Trading, Inc. v. Tripoint Global Equities, LLC, 280 F. Supp. 3d 524, 546 (S.D.N.Y. 2017). + +There is no issue in this case with respect to an unknown identity that may have to be proved by a pattern of similar alleged crimes. Cf. Federal Rule of Evidence 404(b); United States v. Carlton, 534 F.3d 97, 101-02 (2d Cir. 2008) (holding that the defendant's three prior convictions for bank robbery were admissible to prove identity for the bank robbery at issue through a common modus operandi). However, the portion of the amended complaint that the defendants move to strike is not relevant to an issue of identity. The plaintiff has no doubt as to who allegedly committed sex acts with her. However, the portion of the amended complaint that the defendants move to strike is not so irrelevant to the case that they should be stricken. Groff, Maxwell and deny that the alleged promises of financial assistance to the plaintiff were knowingly false when made. The portion of the amended complaint subject to the motion to strike provides specific facts in support of the plaintiff's allegations that she was + +4 recruited an enticed into performing sex acts with Epstein as part of a larger enterprise to provide Epstein with young females for sex, in which each defendant allegedly played a specific role. + +5 6 7 8 9 10 11 12 The defendants contend that the plaintiff was a younger woman who willingly accepted the blandishments of a wealthy older man. The knowledge and intent of the defendants will plainly be an issue. The paragraphs of the amended complaint that the defendants seek to strike may be evidence of the defendants' knowledge and intent in their dealings with the plaintiff. See Federal Rule of Evidence 404(b). Accordingly, the motion to strike is denied. + +13 14 15 16 17 18 The defendants move to dismiss the amended complaint on the basis that 18 U.S.C. Section 1591 does not cover the alleged conduct. The defendants argue that the plaintiff and Epstein were engaged in a consensual relationship and that the amended complaint does not allege that the plaintiff was the victim of sex trafficking within the meaning of Section 1591. + +19 20 21 22 23 24 25 As support for their argument, the defendants rely on the plaintiff's deposition in a proceeding before a different judge. According to the defendants, in this deposition the plaintiff describes her relationship with Epstein as consensual. The defendants argue that this testimony from the plaintiff contradicts the amended complaint. But it is well established that it is improper for the Court to consider + +4 5 6 7 8 9 10 11 12 13 14 15 matters outside of the pleadings on a motion to dismiss. Millennium Health, 240 F. Supp. 3d at 280. The defendants argue that the Court can consider the plaintiff's testimony because it was relied on by the plaintiff in response to the defendants motions. But the plaintiff referenced her prior deposition only in response to the defendants' improper use of the deposition. The defendants also argue that the plaintiff relied on her prior deposition to draft the amended complaint, but that is plainly not true. The plaintiff's deposition is not referred to, relied on, or incorporated by reference in the amended complaint, and indeed the defendants argue that the specific testimony in the deposition is actually inconsistent with the allegations in the amended complaint. Therefore, the Court will not consider either parties' improper use of materials outside of the amended complaint. + +16 17 18 19 20 21 22 23 24 25 The defendants also argue that the amended complaint itself should be read as describing a consensual relationship between two adults, but the amended complaint describes with sufficient detail the manner in which the plaintiff was deceived, threatened, and coerced into following the defendants' instructions to comply with Epstein's sexual requests. Accepting the defendants' description of the relationship between the plaintiff and Epstein would require the Court to accept the defendants' view of the facts rather than the allegations in the amended complaint. That would be + +4 5 6 7 8 9 The defendants further argue that Section 1591 was intended only to reach victim's trafficked for sex and held against their will, and that the amended complaint does not allege that the plaintiff falls within that definition. The defendants again rely on materials outside the amended complaint to support this proposition. The Court will not consider evidence extrinsic to the amended complaint at this stage of the litigation. + +10 11 12 Moreover, Section 1591 is not as limited as the defendants suggest. Rather, Section 1591(a) imposes liability on: + +13 14 15 16 17 18 19 20 21 22 "whoever knowingly in or affecting interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States, recruits, entices, harbors, transports, provides, obtains ... or solicits by any means a person, or benefits financially or by receiving anything of value from participation in a venture ... knowing, in reckless disregard of the fact, that means of force, threats of force, fraud, coercion ... or any combination of such means will be used to cause the person to engage in a commercial sex act." + +23 24 25 18 U.S.C. Section 1591. The statute imposes liability for the use of force but does not require that force be used in order for conduct to fall within the statute's reach. + +improper on a motion to dismiss. + +4 5 6 7 8 9 10 11 12 13 14 15 16 17 Here, the amended complaint alleges that the plaintiff performed sex acts on Epstein in return for numerous financial inducements and fraudulent misrepresentations made and reiterated by each of the defendants to the plaintiff. The plaintiff was allegedly recruited and enticed by the defendants who knew that she would be fraudulently induced to engage in commercial sex acts with Epstein. A commercial sex act is defined in Section 1591(e)(3) as "any sex act, on account of which anything of value is given to or received by any person ." The plaintiff was given financial incentives to engage in sex acts with Epstein. She was allegedly fraudulently induced to do so by false promises of help in her education and career, and threatened with retaliation if she did not continue. The promises were allegedly knowingly false when made. She was recruited and solicited to do so. While the defendants seek to limit the statute to sex slavery, the statute is not so limited. + +18 19 20 Accordingly, the defendants' argument that the amended complaint's allegations do not fall within Section 1591 is without merit. + +21 22 23 24 25 The defendants move to dismiss the amended complaint on the ground that it fails to satisfy the pleading requirements under Iqbal, Twombly, and Rule 8 of the Federal Rules of Civil Procedure. The defendants argue that the amended complaint does not state a plausible claim with + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +sufficient specific allegations that the plaintiff was a victim of sex trafficking in violation of Section 1591 or any other related statute entitling the plaintiff to civil relief pursuant to Section 1595. + +While the plaintiff has partly relied on group pleading in her allegations against the defendant, the amended complaint contains several specific factual allegations sufficient to survive a motion to dismiss against each of the defendants. For example, the amended complaint alleges that in March or April of 2007, Maxwell, , and Groff reiterated to the plaintiff Epstein's alleged promise that in exchange for the plaintiff's continued sexual cooperation with Epstein, Epstein would use his wealth and influence to have the plaintiff admitted into F.I.T. Amended complaint paragraph 38. The amended complaint alleges that Maxwell and Epstein threatened the plaintiff that if she did not comply with Epstein's sexual requests, they had the ability to make sure she did not obtain a formal education or modeling agency contracts. Amended complaint paragraph 41. The amended complaint also alleges that Epstein's wealth and connections were similarly used by and Groff both to induce the plaintiff to provide sex to Epstein and as a means of threatening punishment to the plaintiff if she refused to comply with their instructions. Amended complaint paragraph 50. + +Accordingly, the defendants' motion to dismiss on the basis that the plaintiff does not state a plausible claim based on specific factual allegations is without merit. + +4 5 6 7 The defendants argue that the amended complaint fails to state a claim under Section 1591 because it fails to allege either fraud under Rule 9(b) or coercion as defined by Section 1591. Section 1591 defines coercion as: + +8 9 "(A) Threats of serious harm to or physical restraint against any person; + +10 11 12 "(B) Any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person; or + +13 14 "(C) The abuse or threatened abuse of law or the legal process." 18 U.S.C. Section 1591(e)(2). + +15 Section 1591 defines serious harm as: + +16 17 18 19 20 21 22 "any harm, whether physical or nonphysical, including psychological, financial, or reputational harm, that is sufficiently serious under all of the surrounding circumstances, to compel a reasonable person of the same background and in the same circumstances to perform or to continue to performing commercial sexual activity in order to avoid incurring that harm." 18 U.S.C. Section 1591(e)(5). + +23 24 25 Based on the definitions of coercion provided by Sections 1591(e)(2) and 1591(e)(5), the plaintiff has stated a claim for coercion,. As explained above, the plaintiff alleges 4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +that the threats made to her by Epstein, Maxwell, Groff, and coerced the plaintiff into performing and continuing to perform the sexual acts requested by Epstein. + +Maxwell, Groff, and Epstein argue that the threats allegedly made by Maxwell and Epstein would not cause a reasonable person to believe that they were in danger of suffering serious harm, and therefore the plaintiff's allegations fail to state a claim for coercion. But whether a reasonable person would perceive the alleged statements as a threat of serious harm is necessarily a factual inquiry which cannot be decided on a motion to dismiss. + +Moreover, it is certainly not implausible that a young person could believe that a person of apparent enormous wealth would have the power to open educational and career doors for her, or to slam those doors if she did not acquiesce in requests for sexual activity. + +argues that nowhere in the amended complaint is alleged to have participated in or to have been aware of Maxwell's and Epstein's threats, but the amended complaint alleges that played a role in inducing the plaintiff into performing commercial sex acts for Epstein and that used Epstein's wealth, influence, power and connections as a means of threatening punishment in the event that the plaintiff refused to comply with the instructions to provide sex to Epstein. That conduct meets the definition of coercion and + +4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 The defendants also argue that the plaintiff has failed to satisfy the heightened pleading standards provided by Rule 9(b) for fraud claims because the amended complaint fails to specify when and where any fraudulent statements were made or explain why these statements were made with scienter. Rule 9(b) provides that "in alleging fraud or mistake, a party must state with particularity the circumstances constituting fraud or mistake. Malice, intent, knowledge, and other conditions ever a person's mind may be alleged generally." Federal Rules of Civil Procedure 9(b). To satisfy Rule 9(b), a complaint must "(1) specify the statements that the plaintiff contends were fraudulent, (2) identify the speaker, (3) state where and when the statements were made, and (4) explain why the statements were fraudulent." Mills v. Polar Molecular Corp., 12 F.3d 1170, 1175 (2d Cir. 1993). Although Rule 9(b) allows a plaintiff to allege fraudulent intent generally, a plaintiff must allege facts that give rise to a strong inference of fraudulent intent. Shields v. Citytrust Bancorp, Inc., 25 F.3d 1124, 1128 (2d Cir. 1994). This strong inference can be established either "(a) by alleging facts to show that defendants had both motive and opportunity to commit fraud, or (b) by alleging facts that constitute strong circumstantial evidence of conscious misbehavior or recklessness." Id. See also U.S. Bank National Association v. BFPRU 1, LLC, 230 + +under Section 1591(e)(2). + +4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 The amended complaint satisfies Rule 9(b). The plaintiff alleges that told the plaintiff in October of 2006 that Epstein would use his wealth and influence to have the plaintiff admitted into F.I.T. and that when introduced the plaintiff to Epstein, Epstein reiterated this promise to her. Amended complaint paragraphs 34 to 36. The plaintiff also alleges that between October 2006 and May 2007, Maxwell, , and Groff each confirmed and reiterated to the plaintiff many times that Epstein would use his wealth and connections to advance the plaintiff's career. Amended complaint paragraph 38. These allegations sufficiently specify the statements that the plaintiff contends are fraudulent, as well as the identity of the speakers. See Lehman Brothers Commercial Corp. v. Minmetals International Non-Ferrous Metals Trading Co., No. 94 Civ. 8301 (JFK), 1995 WL 608323A2, at \*2 (S.D.N.Y. Oct. 16, 1995) (noting that where allegedly fraudulent statements occurred over a period of time, a plaintiff is not required to provide the date and time of every statement). + +21 22 23 24 25 While the plaintiff does not describe the specific locations where each of the alleged misstatements took place, the plaintiff does allege that a substantial portion of her interaction with Epstein occurred at his townhouse in New York and on his private island in the U.S. Virgin Islands and that + +F.Supp. 3rd 253, 262 (S.D.N.Y. 2017). + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +each defendant participated in arranging the plaintiff's transportation to these locations. Amended complaint paragraph 45. Moreover, the plaintiff provides the exact address where the plaintiff was provided living quarters and that she was provided a cell phone so that the defendant could communicate with and maintain control over the plaintiff. Amended complaint paragraph 52. These allegations satisfy the requirement under Rule 9(b) that the plaintiff provide the location at which the fraudulent statements were made. + +As to scienter, the defendants argue that the fact that they did not ultimately act upon the alleged promises to have the plaintiff admitted into F.I.T. fails to show that they made the alleged misrepresentations with the intent to defraud. But while "the failure to fulfill a promise to perform future acts is not ground for a fraud action," it can provide a basis for fraud if "there existed an intent not to perform at the time the promise was made." v. Koenig, 25 F.3d 1168, 1172 (2d Cir. 1994). Here, the plaintiff alleges that the defendants reiterated and confirmed Epstein's promise solely for the purpose of maintaining the plaintiff's relationship with Epstein. Amended complaint paragraph 53. The plaintiff also alleges that these statements were reiterated by the defendants with the intention of convincing her to rely on the defendants' representations in furtherance of a sex trafficking enterprise. Amended complaint paragraph 53. That is + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +sufficient to allege that when the defendants made the statements at issue, the defendants did not intend to perform their promises to further the plaintiff's education and career. Indeed, the allegations that the defendants seek to strike may provide further evidence of the defendants' knowledge and intent. Accordingly, the defendants' argument that the plaintiff has failed to plead fraud is without merit. + +and Groff also argue that the plaintiff's allegations against them do not establish that either had knowledge that force, fraud, or coercion would be used to cause the plaintiff to engage in a commercial sex act with Epstein. This argument is without merit. As explained above, the amended complaint provides several specific allegations that, if accepted as true, would establish that both and Groff knew that Epstein's wealth, influence, power and connections were being used fraudulently to induce the plaintiff into complying with Epstein's demands and as a means of coercing the plaintiff. + +Accordingly, the defendants' argument that the amended complaint fails to state a claim because it does not allege coercion or fraud fails. + +The defendants argue that the amended complaint fails to plead a causal link under Section 1591 because the amended complaint should be read as describing a consensual sexual relationship between the plaintiff and Epstein. See 18 U.S.C. + +4 5 6 7 8 9 10 Section 1591(a) (requiring that "force, threats of force, fraud, coercion ... or any combination of such means ... be used to cause the person to engage in a commercial sex act"). This argument is without merit. Again, this argument asks the Court to accept the defendants' version of the facts rather than accept the well pleaded allegations in the plaintiff's amended complaint as true, which is impermissible on a motion to dismiss. Accordingly, the defendants' argument that the amended complaint fails to plead a causal link is without merit. + +11 12 13 14 15 16 Epstein, Maxwell, and move to dismiss the plaintiff's claim that they violated Section 1592. Epstein Maxwell, and argue that plaintiff's Section 1592 claim lacks factual support and argue that there is no factual allegation that the plaintiff's passport was confiscated and held in order to force the plaintiff into commercial sex. + +17 18 19 20 21 22 23 24 25 Section 1592 imposes liability on "whoever knowingly ... confiscates, or possesses any ... passport of another person in the course of a violation of section 1591." 18 U.S.C. Section 1592(a). As an initial matter, the plaintiff's allegation of a violation of Section 1591 alones provides a sufficient basis to proceed on a claim under Section 1595. See 18 U.S.C. Section 1595(a) (providing a civil remedy to anyone "who is a victim of a violation of" Chapter 77 of Title 18 of the United States Code). Moreover, the plaintiff has pleaded + +sufficiently a violation of Section 1592. The amended 4 5 6 7 8 9 10 complaint alleges that the plaintiff's passport was confiscated and controlled by Groff, Maxwell, and while the plaintiff was on Epstein's private island in order to coerce the plaintiff into providing sex to Epstein. Of course, the defendants tell a completely different story by relying on upon statements in the plaintiff's deposition, but the Court cannot rely upon those statements for purposes of this motion to dismiss. Accordingly, the amended complaint states a cause of action under Section 1592. + +11 12 13 14 15 16 The defendants also argue that the plaintiff fails to state violations of Sections 1593A and 1594. As noted above, the plaintiff's allegations of violations of Sections 1591 and 1592 are each sufficient on their own to sustain a Section 1595 claim. It is therefore unnecessary to reach the defendants' arguments with respect to Sections 1593A and 1594. + +17 18 The defendants argue that the plaintiff's claim is barred by the statute of limitations in Section 1595(c)(1). + +19 20 21 22 23 24 25 At the time when the plaintiff alleges the violation in this case occurred -- in 2006 and 2007 -- Section 1595 contained a four-year statute of limitations. See Trafficking Victims Protection Reauthorization Act of 2003, Public Law No. 108-193, Section 4(a)(4), 117 Statutes 2875, 2878; 28 U.S.C. Section 1658(a); see also Cruz v. Maypa, 773 F.3d 138, 143-44 (4th Cir. 2014). In December 2008, Section 1595 was amended to 4 provide a ten year statute of limitations. See William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008, Public Law No. 110-457, Section 221, 122 Statutes 5044, 5067. + +5 6 7 8 9 10 11 12 The defendants argue that the ten year statute of limitations should not be read to apply to this case under the anti-retroactivity doctrine and that the four-year statute of limitations applies to the plaintiff's claims in this case. See Weingarten v. United States, 865 F.3d 48, 54-55 (2d Cir. 2017) (citing Landgraf v. USI Film Products, 511 U.S. 244, (1994)). Therefore, the defendants conclude that the plaintiff's claims are plainly time-barred. + +13 14 15 16 17 18 19 20 21 22 23 24 25 The defendants rely on Abarca v. Little, 54 F. Supp. 3d 1064 (District of Minnesota 2014), in which the district court held that the four-year statute of limitations applied to Section 1595 claims, where the conduct was alleged to have occurred prior to the 2008 amendment. Id. at 1068-69. However, courts within this Circuit have held consistently that the ten-year statute of limitations applies to TVPRA claims that were not time-barred under the four-year statute of limitations when Congress extended the Section 1595 statute of limitations in December 2008, even if those claims accrued before 2008. See Lama v. Malik, 192 F. Supp. 3d 313, 321-323 (E.D.N.Y. 2016); Oluoch, v. Orina, 101 F. Supp. 3d 325, 329-31 (S.D.N.Y. 2015); accord Cruz, 773 F.3d at 143-44. In that + +4 5 6 7 8 9 10 11 12 situation, applying this ten year statute to claims that were alive in December of 2008 has no retroactive effect because it does not impair any rights or revive any stale or expired claims. The defendants have not explained why this Court should reject the conclusions reached by all of the other courts of this Circuit that have addressed this question, which have held uniformly that the ten-year statute of limitations applies to claims that were viable when the ten-year statute of limitations period was enacted. See Lama, 192 F. Supp. 3d at 321-22 (collecting cases). Accordingly, the ten-year statute of limitations applies to the plaintiff's claims in this action. + +13 14 15 16 17 18 19 20 21 22 23 24 25 The defendants argue that even if the ten-year period applies, the plaintiff's claims would still be time barred because they accrued no later than January 2007. But the amended complaint alleges that the plaintiff returned to New York in February 2007, each of the defendants promised the plaintiff again that her sexual compliance would be rewarded with admission into F.I.T. and that each defendant required the plaintiff to provide Epstein with sex acts thereafter. Amended complaint paragraphs 61-63. The defendants argue further that after January 2007 it was unreasonable for the plaintiff to rely on any alleged promises made by the defendants, but this is a factual question that cannot be decided on a motion to dismiss. A statute of limitations defense that involves a + +4 5 6 7 fact-specific analysis is inappropriate to resolve on a motion to dismiss unless it is clearly meritorious from the face of the complaint. See Bigsby v. Barclays Capital Real Estate, Inc., 298 F. Supp. 3d 708, 725-26 (S.D.N.Y. 2018). That is plainly not the case here. Accordingly the defendants' motions to dismiss based on the argument that the plaintiff's claim is time-barred are not yet ripe for litigation. + +8 9 defense Accordingly, the defendants' is not a basis to dismiss the statute of limitations plaintiff's claims. + +10 11 12 13 14 15 16 17 18 Finally, the defendants move to dismiss the amended complaint for lack of personal jurisdiction. Groff, and Maxwell argue that the amended complaint fails to allege any present connection between the defendants and New York. However, there is plainly specific personal jurisdiction over all of the defendants on the basis that the alleged violations of Section 1595 occurred in New York. See N.Y. C.P.L.R. Section 302(a)(2) (providing personal jurisdiction over any person who "commits a tortious act within the state"). + +19 20 21 22 23 24 25 The defendants contend that the alleged tortious conduct in this case ended prior to the period covered by the statute of limitations and that therefore the amended complaint fails to show that the suit-related conduct occurred in New York. This argument depends upon accepting the defendants' arguments on the statute of limitations that the Court has already rejected. In any event, to survive a motion to dismiss + +4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 where no evidentiary hearing is held, the plaintiff need only make a prima facie case that the defendants are subject to the Court's personal jurisdiction. See In re Magnetic Audiotape Antitrust Litigation, 334 F.3d 204, 206 (2d Cir. 2003) (per curium) ("Prior to discovery, a plaintiff may defeat a motion to dismiss based on legally sufficient allegations of jurisdiction;") PDX Labs, Inc. v. Friedlander, 103 F.3d 1105, 1108 (2d Cir. 1997); Rubinbaum LLP v. Related corporate Partners V, L.P., 154 F. Supp. 2d 481, 486 (S.D.N.Y. 2001). The Court must construe the pleadings and supporting affidavits in the light most favorable to the plaintiff. See PDK Labs, 103 F.3d at 1108. The plaintiff eventually will have to establish jurisdiction by a preponderance of the evidence, either at trial or at a pretrial evidentiary hearing. See CutCo Industries, Inc. v. Naughton, 806 F.2d 361, 365 (2d Cir. 1986); Marine Midland Bank, N.A. v. , 664 F.2d 889, 904 (2d Cir. 1981). But at this stage, prior to discovery, the Court must "credit a plaintiff's averments of jurisdictional facts as true." In re Magnetic Audiotape, 334 F.3d at 206; see also Landau v. New Horizon, No. 02 Civ. 6802, 2003 WL 22097989, at \*3, (S.D.N.Y., Sept. 8, 2003). The plaintiff has done all she needs to do to plead personal jurisdiction at this stage of the litigation. See United States v. Machet, No. 08 Civ. 7936, 2009 WL 3029303, at \*8 (S.D.N.Y. Sept. 21, 2009) ("Where, as here, the facts of the case itself are so intertwined with the + +4 5 6 7 8 9 10 11 12 13 14 Similarly, the defendants' assertion that venue is improper in this District is without merit. Again, the defendants argue that the alleged conduct occurred outside of the statute of limitations period and therefore cannot establish that a substantial part of the events giving rise to the claim occurred within this District. The defendants' argument is yet another variant of their statute of limitations argument, which has already been rejected as grounds to dismiss the amended complaint. The amended complaint alleges that a substantial amount of the actionable conduct occurred here in the Southern District of New York. + +15 16 Accordingly, the defendants' arguments to dismiss for lack of personal jurisdiction and improper are without merit. + +17 18 19 20 21 The Court has considered all of the arguments raised by the parties. To the extent not specifically addressed, the arguments are either moot or without merit. As explained above, the defendants' motions to dismiss are denied. The clerk is directed to close all pending motions. So ordered. + +22 23 All right. That brings us then to the scheduling order. How much time for discovery? + +24 25 It would seem to me that discovery in the case is fairly straightforward. There are about six potential + +jurisdictional issue, the Court is well within its discretion to deny the motion to dismiss for lack of personal jurisdiction."). + +witnesses. The parties allege that each of the other parties is not telling the truth. Whether those issues can be resolved 4 5 6 7 8 9 10 11 on summary judgment, I don't know. I don't decide anything until it's briefed on the facts and the law; and there is no such motion before me, except the parties attempted to rely on lots of material outside the complaint. But there are about six witnesses, except perhaps some additional witnesses with respect to the allegations in the complaint that were the subject of the motion to strike. But I would think that you all ought to be able to complete discovery by the end of the year, end of December. OK? + +12 13 MR. : Your Honor, respectfully, could we request a close of discovery at the end of February of 2019? + +14 THE COURT: On what basis? + +15 16 17 18 19 MR. : Just as I'm starting to discuss the issue of timing with my colleagues here, there is some concern that between document production and scheduling depositions, the end of the year may not be realistic, and we're just trying to set a date that gives us some flexibility there. + +20 THE COURT: OK. Yes, plaintiff? + +21 22 23 MS. MCCAWLEY: On behalf of the plaintiff, we would like to proceed as swiftly as possible, so we would appreciate the December date. + +24 25 THE COURT: I think February is a little long. On the other hand, I think asking the parties to complete discovery at + +4 5 6 the end of the holiday season, December the 28th, may not be quite fair to both sides, so I think the end of January is not unreasonable -- that's six months -- but that should be a firm deadline. There is no reason why you can't get the discovery done by then. So, the last Friday in January is actually January 25. So, complete discovery by January 25, 2019. + +7 8 There aren't going to be anymore parties, causes of action, amendments to the complaint; is that right? + +9 MS. MCCAWLEY: Not from the plaintiff, no. + +10 THE COURT: OK. + +11 12 MR. : Your Honor, obviously we have not filed an answer yet. + +13 THE COURT: Right. + +14 15 16 MR. : And we haven't fully evaluated whether there are any counterclaims or the like, so I just want to note that for the record. + +17 18 19 THE COURT: OK. I think the rules say, what, how much time after a decision on the motion to dismiss to file an answer? 14 days? + +20 21 MR. : The wiser heads at this table are telling me 20 days. + +22 23 24 MS. MENNINGER: I think it's 21 just off the top of my head, but I apologize, your Honor, I may be confusing another rule. + +25 THE COURT: It doesn't really make a difference, + +4 5 6 7 For what it's worth, my recollection was correct, it's 14 days. "Unless the court sets a different time, serving a motion under this rule alters these periods as follows: If the court denies the motion or postpones its disposition until trial, the responsive pleading must be served within 14 days after notice of the court's action." + +8 MR. : Your Honor, can we request -- + +9 10 11 THE COURT: You can have some more time. So end of August, August 31. So, time for defendants to answer is August 31, 2018. + +12 13 No additional parties or causes of action after September 14, 2018. + +14 No additional defenses after September 28, 2018. + +15 16 Except for good cause shown, all discovery is to be completed by January 25, 2019. + +17 Dispositive motions, if any, February 15, 2019. + +18 Joint pretrial order, March 1, 2019. + +19 20 21 And the date for the pretrial order gets put over automatically for three weeks if there is a dispositive motion, and the ready trial date gets put over also for four weeks. + +22 23 24 So, if there is a dispositive motion, the parties should be ready for trial 48 hours notice on and after March 15. + +25 This is a jury trial, yes? Jury trial. + +because I can set it. + +4 THE COURT: Do the parties want to talk to the magistrate judge about the possibility of settlement? + +5 6 MS. MCCAWLEY: We have no objection to that, your Honor. + +7 8 9 10 MR. : We haven't discussed that with the clients yet. As a general proposition, we are always open to that, but I would like to discuss it with the clients if I could. + +11 12 13 14 15 16 17 18 19 20 21 22 THE COURT: Well, it seems to me if there is willingness on one side to talk, I should at least send it to the magistrate judge, even if one side says that there will never be a settlement in this case. So long as there is some flexibility on one side, that at least is a step forward. Which leads then to the next question: Would the parties agree to try this case before the magistrate judge? I don't know if another magistrate judge has been appointed. It was originally Magistrate Judge Francis, who has now left the bench, but the docket sheet will reflect a new magistrate judge when I assign it to the magistrate judge for purposes of settlement, so you can follow that. + +23 24 25 I imagine that without even knowing who the magistrate judge is, you're not going to tell me that you're prepared to agree to try the case before the magistrate judge, but maybe + +Estimated trial time? Eight days? + +MS. MCCAWLEY: That would be fine, your Honor. + +4 5 6 THE COURT: OK. So, I'm going to refer it to the magistrate judge for purposes of settlement. Follow the docket sheet, and you will see who the magistrate judge is. + +7 8 9 10 11 12 And you can let me know by September 14 -- just write me a letter -- whether the parties consent to trial before the magistrate judge. And you can just write me a joint letter. You don't have to tell me who wants to go to the magistrate judge and who doesn't; all I need to know is whether all agree to go to the magistrate judge. + +13 14 Which leads me then to one other request. I really urge all of you to be cooperative and civil with each other. + +15 16 17 Whatever the relations are between your clients should not infect the way you deal with each other, or the papers that you file before me, because that's really not helpful. + +18 19 20 So, OK, I'll enter the civil scheduling order. I will do an order disposing of the motions, and the full rationale for the motions is in the transcript. + +21 All right. Anything further? + +22 MS. MCCAWLEY: Thank you, your Honor. + +23 MR. : No. Thank you, your Honor. + +24 THE COURT: Good afternoon, all. + +25 (Adjourned) + +I'm wrong. + +MS. 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SOUTHERN DISTRICT OF NEW YORK + +[REDACTED] + +USA / Plaintiff(s) + +v. + +JEFFREY EPSTEIN ET AL., + +Defendant(s) + +) +) +) +) +) +) +) +) +) +) +) + +Case No.: 17CV616 + +NOTICE OF FILING OF OFFICIAL TRANSCRIPT + +Notice is hereby given that an official transcript of a CONFERENCE held on 8/7/18 has been filed by the court reporter/transcriber in the above-captioned matter. + +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting the transcript is a judge or a member of the public or media. + +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days. + +This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion. + +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the above-entitled matter. + +/S STEVEN GRIFFING + +Court Reporter/Transcriber + +Date \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820408/EFTA02820408.metadata.json b/marker2/court-jane-doe-43/EFTA02820408/EFTA02820408.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0465406b1e22362aba71a78aed0af370d53d7db2 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820408/EFTA02820408.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820408.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1483, + "elapsed_seconds": 6.12, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 153.612, + 66.42 + ], + [ + 416.77200000000005, + 66.42 + ], + [ + 416.77200000000005, + 93.96000000000001 + ], + [ + 153.612, + 93.96000000000001 + ] + ] + }, + { + "title": "NOTICE OF FILING OF OFFICIAL TRANSCRIPT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 168.3, + 307.79999999999995 + ], + [ + 446.76, + 307.79999999999995 + ], + [ + 446.76, + 322.38 + ], + [ + 168.3, + 322.38 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Text", + 30 + ], + [ + "Line", + 27 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820408" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820409/EFTA02820409.md b/marker2/court-jane-doe-43/EFTA02820409/EFTA02820409.md new file mode 100644 index 0000000000000000000000000000000000000000..199cc012e77234c785444465e34b8b913c07fb35 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820409/EFTA02820409.md @@ -0,0 +1,252 @@ +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +CASE NO. 17 Civ 616 (JGK) + +JANE DOE 43, + +Plaintiff, vs. + +JEFFREY EPSTEIN GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +Defendants. + +# ANSWER OF JEFFREY EPSTEIN + +Defendant Jeffrey Epstein ("Epstein"), by and through his counsel, answers and responds to Plaintiff "Complaint"). ("Plaintiff" or First Amended Complaint (the + +#### PRELIMINARY STATEMENT' + +Epstein enjoys the same protections of the self-incrimination clause of the Fifth Amendment to the United States Constitution (the "Fifth Amendment") as do all other persons who are potentially subject to criminal prosecution in a jurisdiction in which the Fifth Amendment applies. It is Epstein's express intent in this Answer to claim the fullest possible protection of the United States Constitution in responding to the Complaint. Epstein does not intend by any of his responses to waive such protection and requests that, in cases of any doubt or ambiguity, his response be construed as an assertion rather than a waiver of such privilege. Epstein also reserves his right to amend his responses without compromising his rights under the Fifth Amendment. + +3 Epstein is not required to respond to the headings set forth in the Complaint since they arc not factual allegations. + +#### RESPONSE TO SPECIFIC ALLEGATIONS + +I. Epstein admits that the Plaintiff purports to bring this lawsuit pursuant to the statutes described in Paragraph 1. + +2. In response to the allegations in Paragraph 2, Epstein admits that the Plaintiff filed this lawsuit under a pseudonym purportedly for the reasons stated therein. + +3. It appears that the allegations in Paragraph 3 are directed to an individual other than Epstein, to which no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +4. Epstein admits that he is a citizen of the United States and a resident of the U.S. Virgin Islands. In response to the other allegations in Paragraph 4, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +5. Epstein admits that he is an adult male born in 1953. In response to the other allegations in Paragraph 5, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +6. It appears that the allegations in Paragraph 6 are directed to an individual other than Epstein, to which no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +7. It appears that the allegations in Paragraph 7 are directed to an individual other than Epstein, to which no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +8. It appears that the allegations in Paragraph 8 are directed to an individual other than Epstein, to which no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +9. It appears that the allegations in Paragraph 9 state conclusions of law, to which no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +10. It appears that the allegations in Paragraph 10 state conclusions of law, as to which no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +II. To the extent the allegations in Paragraph 11 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +12. In response to the allegations in Paragraph 12, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +13. In response to the allegations in Paragraph 13, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +14. To the extent the allegations in Paragraph 14 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +IS. To the extent the allegations in Paragraph 15 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive + +16. To the extent the allegations in Paragraph 16 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +17. To the extent the allegations in Paragraph 17 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +18. To the extent the allegations in Paragraph 18 concern Epstein, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +19. To the extent the allegations in Paragraph 19 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +20. To the extent the allegations in Paragraph 20 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +21. To the extent the allegations in Paragraph 21 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +22. To the extent the allegations in Paragraph 22 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +23. To the extent the allegations in Paragraph 23 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +24. To the extent the allegations in Paragraph 24 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive + +25. To the extent the allegations in Paragraph 25 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +26. To the extent the allegations in Paragraph 26 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer, except admits that he entered into a non-prosecution agreement with the United States Attorney's Office for the Southern District of Florida and refers to the document for its true and complete contents. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +27. To the extent the allegations in Paragraph 27 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +28. To the extent the allegations in Paragraph 28 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive + +29. In response to the allegations in Paragraph 29, Epstein admits that he pled guilty in Florida state court and refers to the guilty plea for its true and complete contents. Epstein otherwise asserts his rights under the Fifth Amendment and declines to answer. + +30. To the extent the allegations in Paragraph 30 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +31. To the extent the allegations in Paragraph 31 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +32. To the extent the allegations in Paragraph 32 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +33. To the extent the allegations in Paragraph 33 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive + +34. To the extent the allegations in Paragraph 34 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +35. It appears that the allegations in Paragraph 35 are directed to an individual other than Epstein, to which no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +36. It appears that the allegations in Paragraph 36 are directed to individuals other than Epstein, to which no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +37. To the extent the allegations in Paragraph 37 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +38. To the extent the allegations in Paragraph 38 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +39. To the extent the allegations in Paragraph 39 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +40. To the extent the allegations in Paragraph 40 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +41. To the extent the allegations in Paragraph 41 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +42. To the extent the allegations in Paragraph 42 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +43. To the extent the allegations in Paragraph 43 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive + +44. To the extent the allegations in Paragraph 44 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights tinder the Fifth Amendment and declines to answer. + +45. To the extent the allegations in Paragraph 45 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +46. To the extent the allegations in Paragraph 46 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +47. To the extent the allegations in Paragraph 47 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +48. To the extent the allegations in Paragraph 48 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +49. To the extent the allegations in Paragraph 49 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +50. To the extent the allegations in Paragraph 50 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +51. To the extent the allegations in Paragraph 51 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +52. To the extent the allegations in Paragraph 52 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive + +53. To the extent the allegations in Paragraph 53 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +54. To the extent the allegations in Paragraph 54 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +55. To the extent the allegations in Paragraph 55 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +56. To the extent the allegations in Paragraph 56 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +57. To the extent the allegations in Paragraph 57 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +58. To the extent the allegations in Paragraph 58 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +59. To the extent the allegations in Paragraph 59 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +60. To the extent the allegations in paragraph 60 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +61. To the extent the allegations in Paragraph 61 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive + +62. To the extent the allegations in Paragraph 62 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +63. To the extent the allegations in Paragraph 63 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +64. To the extent the allegations in Paragraph 64 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +65. To the extent the allegations in Paragraph 65 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +66. To the extent the allegations in Paragraph 66 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +67. In response to Paragraph 67, Epstein repeats and incorporates his responses to Paragraphs 1 through 66 of the Complaint. + +68. To the extent the allegations in Paragraph 68 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +69. To the extent the allegations in Paragraph 69 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +70. To the extent the allegations in Paragraph 70 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +71. To the extent the allegations in Paragraph 71 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +72. To the extent the allegations in Paragraph 72 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +73. To the extent the allegations in Paragraph 73 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +74. It appears the allegations in Paragraph 74 state conclusion of law, as to which no response is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +75. To the extent the allegations in Paragraph 75 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +76. To the extent the allegations in Paragraph 76 concern Epstein's conduct, Epstein asserts his rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Epstein and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +77. It appears the allegations in Paragraph 77 state conclusion of law, as to which no response is required. To the extent a response is required, Epstein asserts his rights under the Fifth Amendment and declines to answer. + +## DEFENSES + +By alleging the following defenses, Epstein does not assume any burden of proof, persuasion, or production not otherwise legally assigned to him. Epstein reserves all rights to assert other defenses as appropriate. + +## First Defense + +The Complaint fails to state a claim upon which relief can he granted against Epstein. + +## Second Defense + +Plaintiffs claim is barred, in whole or in part, by the applicable statute of limitations and/or !aches. + +## Third Defense + +Plaintiff failed to mitigate damages in whole or in part. + +## Fourth Defense + +Plaintiff's claim is barred, in whole or in part, by the doctrines of assumption of risk, estoppel, unclean hands, waiver, consent and/or ratification. + +### Filth Defense + +Plaintiff's damages, if any, resulted from the acts or omissions of Plaintiff or third parties other than Epstein. + +## Sixth Defense + +The damages, if any, alleged in the Complaint were directly and proximately caused, in whole or in part, by superseding or intervening conduct for which Epstein cannot be held liable. + +## Seventh Defense + +The conduct alleged does not constitute a violation, and is beyond the scope, of the federal criminal anti-sex trafficking statutes upon which this suit is based, none of which are meant to regulate voluntary private relationships. + +## Eighth Defense + +Plaintiff's claim is barred because Plaintiff was an educated, experienced and sophisticated individual who was free to associate and form relationships with anyone and free to terminate her association and relationships with anyone. + +### Ninth Defense + +Plaintiff's claim is barred because Plaintiff did not actually rely and did not detrimentally and/or reasonably rely upon any misrepresentations or omissions alleged in the Complaint. + +## Tenth Defense + +This Court lacks personal jurisdiction over Epstein. + +### Eleventh Defense + +Epstein reserves the right to supplement this Answer and to assert other defenses, when and if they become appropriate in this action. + +## PRAYER FOR RELIEF + +WHEREFORE, Epstein respectfully requests: + +- A. judgment dismissing the First Amended Complaint with prejudice; and +- B. such other and further relief as this Court may deem just and proper. + +Dated: August 31, 2018 New York, New York + +> STEPTOE & LLP + +By: is/Michael C + +Michael C. + +Justin Y.K. + +1114 Avenue of the Americas + +New York, NY 10036 + +Telephone: 212-506-3900 + +Facsimile: 202-506-3950 + +Attorneys for Defendant Jeffrey Epstein \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820409/EFTA02820409.metadata.json b/marker2/court-jane-doe-43/EFTA02820409/EFTA02820409.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..76a024368efad411ed4de2beab886314f0d9d218 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820409/EFTA02820409.metadata.json @@ -0,0 +1,1094 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820409.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": 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b/marker2/court-jane-doe-43/EFTA02820428/EFTA02820428.md @@ -0,0 +1,248 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +CASE NO. 17 Civ 616 (JGK) + +JANE DOE 43, + +Plaintiff, vs. + +JEFFREY EPSTEIN GHISLAINE MAXWELL, LESLEY GROFF, AND NATALYA + +Defendants. + +# ANSWER OF LESLEY GROFF + +Defendant Lesley Groff ("Groff"), by and through her counsel, answers and responds to Plaintiff "Complaint"). ("Plaintiff" or ` ") First Amended Complaint (the + +#### PRELIMINARY STATEMENT' + +Groff enjoys the same protections of the self-incrimination clause of the Fifth Amendment to the United States Constitution (the "Fifth Amendment") as do all other persons who are potentially subject to criminal prosecution in a jurisdiction in which the Fifth Amendment applies. It is Groff's express intent in this Answer to claim the fullest possible protection of the United States Constitution in responding to the Complaint. Groff does not intend by any of her responses to waive such protection and requests that, in cases of any doubt or ambiguity, her response be construed as an assertion rather than a waiver of such privilege. Groff also reserves her right to amend her responses without compromising her rights under the Fifth Amendment. + +Groff is not required to respond to the headings set forth in the Complaint since they arc not factual allegations. + +## RESPONSE TO SPECIFIC ALLEGATIONS + +I. Groff admits that the Plaintiff purports to bring this lawsuit pursuant to the statutes described in Paragraph 1. + +2. In response to the allegations in Paragraph 2, Groff admits that the Plaintiff filed this lawsuit under a pseudonym purportedly for the reasons stated therein. + +3. It appears that the allegations in Paragraph 3 are directed to an individual other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +4. It appears that the allegations in Paragraph 4 are directed to an individual other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +5. It appears that the allegations in Paragraph 5 are directed to an individual other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +6. It appears that the allegations in Paragraph 6 are directed to an individual other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +7. It appears that the allegations in Paragraph 7 are directed to an individual other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +8. Groff admits that she is a citizen of the United States. In response to the other allegations in Paragraph 8, Groff asserts her rights under the Fifth Amendment and declines to answer. + +9. It appears that the allegations in Paragraph 9 state conclusions of law, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +10. It appears that the allegations in Paragraph 10 state conclusions of law, as to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +II. To the extent the allegations in Paragraph 11 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +12. It appears that the allegations in Paragraph 12 are directed to an individual other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +13. It appears that the allegations in Paragraph 13 are directed to an individual other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +14. To the extent the allegations in Paragraph 14 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +15. It appears that the allegations in Paragraph 15 are directed to individuals other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +16. It appears that the allegations in Paragraph 16 are directed to individuals other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +17. In response to the allegations in Paragraph 17, Groff asserts her rights under the Fifth Amendment and declines to answer. + +18. To the extent the allegations in Paragraph 18 concern Groff, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +19. To the extent the allegations in Paragraph 19 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +20. To the extent the allegations in Paragraph 20 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +21. To the extent the allegations in Paragraph 21 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +22. To the extent the allegations in Paragraph 22 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +23. It appears that the allegations in Paragraph 23 are directed to individuals other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +24. To the extent the allegations in Paragraph 24 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +25. To the extent the allegations in Paragraph 25 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +26. To the extent the allegations in Paragraph 26 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +27. It appears that the allegations in Paragraph 27 are directed to individuals other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +28. To the extent the allegations in Paragraph 28 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +29. It appears that the allegations in Paragraph 29 are directed to an individual other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +30. To the extent the allegations in Paragraph 30 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +31. To the extent the allegations in Paragraph 31 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +32. To the extent the allegations in Paragraph 32 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +33. To the extent the allegations in Paragraph 33 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +34. To the extent the allegations in Paragraph 34 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +35. It appears that the allegations in Paragraph 35 are directed to an individual other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +36. It appears that the allegations in Paragraph 36 are directed to individuals other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +37. To the extent the allegations in Paragraph 37 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +38. To the extent the allegations in Paragraph 38 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +39. It appears that the allegations in Paragraph 39 are directed to individuals other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +40. To the extent the allegations in Paragraph 40 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +41. To the extent the allegations in Paragraph 41 concern Groff s conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations + +are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +42. To the extent the allegations in Paragraph 42 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +43. To the extent the allegations in Paragraph 43 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +44. To the extent the allegations in Paragraph 44 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +45. To the extent the allegations in Paragraph 45 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +46. It appears that the allegations in Paragraph 46 are directed to individuals other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +47. It appears that the allegations in Paragraph 47 are directed to individuals other than Groff, to which no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +48. To the extent the allegations in Paragraph 48 concern Groff s conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +49. To the extent the allegations in Paragraph 49 concern Groff s conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +50. To the extent the allegations in Paragraph 50 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +51. To the extent the allegations in Paragraph 51 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations + +are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +52. To the extent the allegations in Paragraph 52 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +53. To the extent the allegations in Paragraph 53 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +54. To the extent the allegations in Paragraph 54 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +55. To the extent the allegations in Paragraph 55 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +56. To the extent the allegations in Paragraph 56 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +57. To the extent the allegations in Paragraph 57 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +58. To the extent the allegations in Paragraph 58 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +59. To the extent the allegations in Paragraph 59 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +60. To the extent the allegations in paragraph 60 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive + +pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +61. To the extent the allegations in Paragraph 61 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +62. To the extent the allegations in Paragraph 62 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +63. To the extent the allegations in Paragraph 63 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +64. To the extent the allegations in Paragraph 64 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +65. To the extent the allegations in Paragraph 65 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +66. To the extent the allegations in Paragraph 66 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +67. In response to Paragraph 67, Groff repeats and incorporates her responses to Paragraphs I through 66 of the Complaint. + +68. To the extent the allegations in Paragraph 68 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +69. To the extent the allegations in Paragraph 69 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +70. To the extent the allegations in Paragraph 70 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +71. To the extent the allegations in Paragraph 71 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +72. To the extent the allegations in Paragraph 72 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +73. To the extent the allegations in Paragraph 73 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +74. It appears the allegations in Paragraph 74 state conclusion of law, as to which no response is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +75. To the extent the allegations in Paragraph 75 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +76. To the extent the allegations in Paragraph 76 concern Groff's conduct, Groff asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than Groff and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +77. It appears the allegations in Paragraph 77 state conclusion of law, as to which no response is required. To the extent a response is required, Groff asserts her rights under the Fifth Amendment and declines to answer. + +# DEFENSES + +By alleging the following defenses, Groff does not assume any burden of proof, persuasion, or production not otherwise legally assigned to him. Groff reserves all rights to assert other defenses as appropriate. + +# First Defense + +The Complaint fails to state a claim upon which relief can be granted against Groff. + +# Second Defense + +Plaintiff's claim is barred, in whole or in part, by the applicable statute of limitations and/or laches. + +# Third Defense + +Plaintiff failed to mitigate damages in whole or in part. + +## Fourth Defense + +Plaintiff's claim is barred, in whole or in part, by the doctrines of assumption of risk, estoppel, unclean hands, waiver, consent and/or ratification. + +## Fifth Defense + +Plaintiff's damages, if any, resulted from the acts or omissions of Plaintiff or third parties other than Groff. + +# Sixth Defense + +The damages, if any, alleged in the Complaint were directly and proximately caused, in whole or in part, by superseding or intervening conduct for which Groff cannot be held liable. + +## Seventh Defense + +The conduct alleged does not constitute a violation, and is beyond the scope, of the federal criminal anti-sex trafficking statutes upon which this suit is based, none of which are meant to regulate voluntary private relationships. + +# Eiehth Defense + +Plaintiff's claim is barred because Plaintiff was an educated, experienced and sophisticated individual who was free to associate and form relationships with anyone and free to terminate her association and relationships with anyone. + +## Ninth Defense + +Plaintiff's claim is barred because Plaintiff did not actually rely and did not detrimentally and/or reasonably rely upon any misrepresentations or omissions alleged in the Complaint. + +## Tenth Defense + +This Court lacks personal jurisdiction over Groff. + +## Eleventh Defense + +Groff presently has insufficient knowledge or information upon which to form a belief as to whether he may have other, unstated, defenses. Groff reserves the right to supplement this Answer and to assert other defenses, when and if they become appropriate in this action. + +## PRAYER FOR RELIEF + +WHEREFORE, Groff respectfully requests: + +- A. judgment dismissing the First Amended Complaint with prejudice; and +- B. such other and further relief as this Court may deem just and proper. + +Dated: August 31, 2018 New York, New York + +> STEPTOE & LLP + +By: /s/ Michael C. + +Michael C. 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(a), by and through her counsel, answers and responds to ("Plaintiff" or a First Amended Complaint (the + +CASE NO. 17 Civ 616 (JGK) + +# ANSWER OF + +#### PRELIMINARY STATEMENT' + +enjoys the same protections of the self-incrimination clause of the Fifth Amendment to the United States Constitution (the "Fifth Amendment") as do all other persons who are potentially subject to criminal prosecution in a jurisdiction in which the Fifth Amendment applies. It is express intent in this Answer to claim the fullest possible protection of the United States Constitution in responding to the Complaint. does not intend by any of her responses to waive such protection and requests that, in cases of any doubt or ambiguity, her response be construed as an assertion rather than a waiver of such privilege. also reserves her right to amend her responses without compromising her rights under the Fifth Amendment. + +is not required to respond to the headings set forth in the Complaint since they are not factual allegations. + +## RESPONSE TO SPECIFIC ALLEGATIONS + +admits that the Plaintiff purports to bring this lawsuit pursuant to the statutes described in Paragraph I . + +2. In response to the allegations in Paragraph 2, admits that the Plaintiff filed this lawsuit under a pseudonym purportedly for the reasons stated therein. + +3. It appears that the allegations in Paragraph 3 are directed to an individual other than =, to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +4. It appears that the allegations in Paragraph 4 are directed to an individual other than =, to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +5. It appears that the allegations in Paragraph 5 are directed to an individual other than M, to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +6. It appears that the allegations in Paragraph 6 are directed to an individual other than to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +7. admits that she is a citizen of the United States. In response to the other allegations in Paragraph 7, asserts her rights under the Fifth Amendment and declines to answer. + +8. It appears that the allegations in Paragraph 8 are directed to an individual other than =, to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +9. It appears that the allegations in Paragraph 9 state conclusions of law, to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +10. It appears that the allegations in Paragraph 10 state conclusions of law, as to which no responsive pleading is required. To the extent a response is required, rights under the Fifth Amendment and declines to answer. asserts her + +I I. To the extent the allegations in Paragraph 11 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +12. It appears that the allegations in Paragraph 12 are directed to an individual other than =, to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +13. It appears that the allegations in Paragraph 13 are directed to an individual other than =, to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +14. To the extent the allegations in Paragraph 14 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +IS. In response to the allegations in Paragraph 15, asserts her rights under the Fifth Amendment and declines to answer. + +16. To the extent the allegations in Paragraph 16 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations arc directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +17. To the extent the allegations in Paragraph 17 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +18. To the extent the allegations in Paragraph 18 concern =, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +19. To the extent the allegations in Paragraph 19 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +20. To the extent the allegations in Paragraph 20 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +21. To the extent the allegations in Paragraph 21 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +22. To the extent the allegations in Paragraph 22 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +23. It appears that the allegations in Paragraph 23 are directed to individuals other than =, to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +24. To the extent the allegations in Paragraph 24 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +25. To the extent the allegations in Paragraph 25 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +26. To the extent the allegations in Paragraph 26 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +27. To the extent the allegations in Paragraph 27 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +28. To the extent the allegations in Paragraph 28 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +29. It appears that the allegations in Paragraph 29 are directed to an individual other than =, to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +30. To the extent the allegations in Paragraph 30 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +31. To the extent the allegations in Paragraph 31 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +32. To the extent the allegations in Paragraph 32 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +33. To the extent the allegations in Paragraph 33 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +34. To the extent the allegations in Paragraph 34 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive + +pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +35. It appears that the allegations in Paragraph 35 are directed to an individual other than I= to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +36. It appears that the allegations in Paragraph 36 are directed to individuals other than =, to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +37. To the extent the allegations in Paragraph 37 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +38. To the extent the allegations in Paragraph 38 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +39. It appears that the allegations in Paragraph 39 are directed to individuals other than to which no responsive pleading is required. To the extent a response is required. asserts her rights under the Fifth Amendment and declines to answer. + +40. To the extent the allegations in Paragraph 40 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +41. To the extent the allegations in Paragraph 41 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +42. To the extent the allegations in Paragraph 42 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +43. To the extent the allegations in Paragraph 43 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +44. To the extent the allegations in Paragraph 44 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +45. To the extent the allegations in Paragraph 45 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +46. It appears that the allegations in Paragraph 46 are directed to individuals other than to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +47. It appears that the allegations in Paragraph 47 are directed to individuals other than =, to which no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +48. To the extent the allegations in Paragraph 48 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +49. To the extent the allegations in Paragraph 49 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +50. To the extent the allegations in Paragraph 50 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +51. To the extent the allegations in Paragraph 51 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +52. To the extent the allegations in Paragraph 52 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +53. To the extent the allegations in Paragraph 53 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +54. To the extent the allegations in Paragraph 54 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +55. To the extent the allegations in Paragraph 55 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +56. To the extent the allegations in Paragraph 56 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +57. To the extent the allegations in Paragraph 57 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +58. To the extent the allegations in Paragraph 58 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +59. To the extent the allegations in Paragraph 59 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive + +pleading is required. To the extent a response is required, Fifth Amendment and declines to answer. asserts her rights under the + +60. To the extent the allegations in paragraph 60 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Fifth Amendment and declines to answer. asserts her rights under the + +61. To the extent the allegations in Paragraph 61 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Fifth Amendment and declines to answer. asserts her rights under the + +62. To the extent the allegations in Paragraph 62 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, Fifth Amendment and declines to answer. asserts her rights under the + +63. To the extent the allegations in Paragraph 63 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +64. To the extent the allegations in Paragraph 64 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +65. To the extent the allegations in Paragraph 65 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +66. To the extent the allegations in Paragraph 66 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +67. In response to Paragraph 67, repeats and incorporates her responses to Paragraphs 1 through 66 of the Complaint. + +68. To the extent the allegations in Paragraph 68 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +69. To the extent the allegations in Paragraph 69 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +70. To the extent the allegations in Paragraph 70 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +71. To the extent the allegations in Paragraph 71 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +72. To the extent the allegations in Paragraph 72 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +73. To the extent the allegations in Paragraph 73 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive + +pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +74. It appears the allegations in Paragraph 74 state conclusion of law, as to which no response is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +75. To the extent the allegations in Paragraph 75 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +76. To the extent the allegations in Paragraph 76 concern conduct, asserts her rights under the Fifth Amendment and declines to answer. In so far as the allegations are directed to individuals other than and/or state conclusions of law, no responsive pleading is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +77. It appears the allegations in Paragraph 77 state conclusion of law, as to which no response is required. To the extent a response is required, asserts her rights under the Fifth Amendment and declines to answer. + +# DEFENSES + +By alleging the following defense, does not assume any burden of proof, persuasion, or production not otherwise legally assigned to him. reserves all rights to assert other defenses as appropriate. + +## First Defense + +The Complaint fails to state a claim upon which relief can be granted against + +#### Second Defense + +Plaintiff's claim is barred, in whole or in part, by the applicable statute of limitations and/or laches. + +## Third Defense + +Plaintiff failed to mitigate damages in whole or in part. + +### Fourth Defense + +Plaintiff's claim is barred, in whole or in part, by the doctrines of assumption of risk, estoppel, unclean hands, waiver, consent and/or ratification. + +### Fifth Defense + +Plaintiff's damages, if any, resulted from the acts or omissions of Plaintiff or third parties other than + +# Sixth Defense + +The damages, if any, alleged in the Complaint were directly and proximately caused, in whole or in part, by superseding or intervening conduct for which cannot be held liable. + +# Seventh Defense + +The conduct alleged does not constitute a violation, and is beyond the scope of the federal criminal anti-sex trafficking statutes upon which this suit is based, none of which are meant to regulate voluntary private relationships. + +## Eiehth Defense + +Plaintiff's claim is barred because Plaintiff was an educated, experienced and sophisticated individual who was free to associate and form relationships with anyone and free to terminate her association and relationships with anyone. + +# Ninth Defense + +Plaintiff's claim is barred because Plaintiff did not actually rely and did not detrimentally and/or reasonably rely upon any misrepresentations or omissions alleged in the Complaint. + +# Tenth Defense + +This Court lacks personal jurisdiction over + +#### Eleventh Defense + +reserves the right to supplement this Answer and to assert other defenses, when and if they become appropriate in this action. + +# PRAYER FOR RELIEF + +WHEREFORE, respectfully requests: + +- A. judgment dismissing the First Amended Complaint with prejudice; and +- B. such other and further relief as this Court may deem just and proper. + +Dated: August 31, 2018 New York, New York + +STEPTOE & LLP + +By: Is/ Michael C. + +Michael C. 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file diff --git a/marker2/court-jane-doe-43/EFTA02820464/EFTA02820464.md b/marker2/court-jane-doe-43/EFTA02820464/EFTA02820464.md new file mode 100644 index 0000000000000000000000000000000000000000..76675cb4f6c0a17c5f706a9ae9906948bbda715d --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820464/EFTA02820464.md @@ -0,0 +1,231 @@ +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +X + +Plaintiff, v. + +17-cv-00616-J6K + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF, and NATALYA + +Defendants. + +X + +#### ANSWER + +Defendant Ghislaine Maxwell, through her attorneys Haddon, P.C., answers the First Amended Complaint as follows: + +- 1. Ms. Maxwell denies the legal conclusions contained in Paragraph 1. +- 2. Ms. Maxwell admits that Plaintiff filed this action under a pseudonym but later moved to change the case-caption to include her name. Ms. Maxwell denies all other factual allegations contained in Paragraph 2. +- 3. Ms. Maxwell is without knowledge or information sufficient to fomi a belief as to the allegations contained in Paragraph 3. +- 4. Ms. Maxwell is without knowledge or information sufficient to form a belief as to the allegations contained in Paragraph 4. + +5. Ms. Maxwell admits that Defendant Jeffrey Epstein is an adult male and otherwise is without knowledge or information sufficient to form a belief as to the allegations contained in Paragraph 5. + +6. Ms. Maxwell admits that she is a citizen of the United Kingdom and the United States but otherwise denies the allegations contained in Paragraph 6. + +7. Ms. Maxwell is without knowledge or information sufficient to firm a helief as to the allegations contained in Paragraph 7. + +8. Ms. Maxwell is without knowledge or information sufficient to form a belief as to the allegations contained in Paragraph 8. + +9. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 9. + +10. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 10. + +# FACTUAL ALLEGATIONS + +11. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph II. + +12. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 12. + +13. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 13 that reference her and otherwise is without knowledge or information sufficient to form a belief as to the remaining allegations. + +14. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 14. + +15. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 15 that reference her and otherwise lacks knowledge or information sufficient to form a belief as to the remaining allegations. + +16. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 16. + +17. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 17. + +18. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 18. + +19. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 19. + +20. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 20. + +21. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 21. + +22. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 22. + +23. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 23. + +24. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 24. + +25. Ms. Maxwell lacks knowledge or information sufficient to form a belief as to the allegations contained in Paragraph 25 and denies any such allegations as pertain to her. + +26. Ms. Maxwell lacks knowledge or information sufficient to form a belief as to the allegations contained in Paragraph 26 and denies any such allegations as pertain to her. + +27. Ms. Maxwell lacks knowledge or information sufficient to form a belief as to the allegations contained in Paragraph 27. + +28. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 28 that reference her and otherwise lacks knowledge or information sufficient to form a belief as to the remaining allegations. + +29. Ms. Maxwell lacks knowledge or information sufficient to form a belief as to the allegations contained in Paragraph 29. + +30. Ms. Maxwell denies the allegations contained in Paragraph 30. + +31. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 31 that reference her and otherwise lacks knowledge or information sufficient to form a belief as to the remaining allegations. + +32. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 32 that reference her and otherwise lacks knowledge or information sufficient to form a belief as to the remaining allegations. + +33. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 33 that reference her and otherwise lacks knowledge or information sufficient to form a belief as to the remaining allegations. + +34. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 34 that reference her and otherwise lacks knowledge or information sufficient to form a belief as to the remaining allegations. + +35. Ms. Maxwell lacks knowledge or information sufficient to form a belief as to the allegations contained in Paragraph 35. + +36. Ms. Maxwell lacks knowledge or information sufficient to form a belief as to the allegations contained in Paragraph 36. + +37. Ms. Maxwell denies the allegations contained in Paragraph 37. + +38. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 38 that reference her and otherwise lacks knowledge or information sufficient to form a belief as to the remaining allegations. + +39. Ms. Maxwell denies the allegations contained in Paragraph 39. + +40. Ms. Maxwell denies the allegations contained in Paragraph 40. + +41. Ms. Maxwell denies the allegations contained in Paragraph 41. + +42. Ms. Maxwell denies the allegations contained in Paragraph 42. + +43. Ms. Maxwell denies the allegations contained in Paragraph 43. + +44. Ms. Maxwell denies the allegations contained in Paragraph 44. + +45. Ms. Maxwell denies the allegations contained in Paragraph 45. + +46. Ms. Maxwell lacks knowledge or information sufficient to form a belief as to the allegations contained in Paragraph 46. + +47. Ms. Maxwell denies the allegations contained in Paragraph 47. + +48. Ms. Maxwell denies the allegations contained in Paragraph 48. + +49. Ms. Maxwell denies the allegations contained in Paragraph 49. + +50. Ms. Maxwell denies the allegations contained in Paragraph 50. + +51. Ms. Maxwell denies the allegations contained in Paragraph 51. + +52. Ms. Maxwell denies the allegations contained in Paragraph 52. + +- 53. Ms. Maxwell denies the allegations contained in Paragraph 53. +- 54. Ms. Maxwell denies the allegations contained in Paragraph 54. +- 55. Ms. Maxwell denies the allegations contained in Paragraph 55. +- 56. Ms. Maxwell denies the allegations contained in Paragraph 56. +- 57. Ms. Maxwell denies the allegations contained in Paragraph 57. +- 58. Ms. Maxwell denies the allegations contained in Paragraph 58. +- 59. Ms. Maxwell denies the allegations contained in Paragraph 59. +- 60. Ms. Maxwell denies the allegations contained in Paragraph 60. +- 61. Ms. Maxwell denies the allegations contained in Paragraph 61. +- 62. Ms. Maxwell denies the allegations contained in Paragraph 62. +- 63. Ms. Maxwell denies the allegations contained in Paragraph 63. +- 64. Ms. Maxwell denies the allegations contained in Paragraph 64. +- 65. Ms. Maxwell denies the allegations contained in Paragraph 65. +- 66. Ms. Maxwell denies the allegations contained in Paragraph 66. + +## COUNT 1: CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C. # 1595 + +67. Ms. Maxwell restates and incorporates all of the foregoing answers contained in paragraphs 1-66 above. + +- 68. Ms. Maxwell denies the allegations contained in Paragraph 68. +- 69. Ms. Maxwell denies the allegations contained in Paragraph 69. +- 70. Ms. Maxwell denies the allegations contained in Paragraph 70. +- 71. Ms. Maxwell denies the allegations contained in Paragraph 71. +- 72. Ms. Maxwell denies the allegations contained in Paragraph 72. + +73. Ms. Maxwell denies the allegations contained in Paragraph 73. + +74. Ms. Maxwell denies the allegations contained in Paragraph 74. + +75. Ms. Maxwell denies the allegations contained in Paragraph 75. + +76. Ms. Maxwell denies the allegations contained in Paragraph 76 to the extent they pertain to her. + +77. Ms. Maxwell denies the allegations contained in Paragraph 77. + +## AFFIRMATIVE DEFENSES + +78. The Court lacks personal jurisdiction over Ms. Maxwell. + +79. The case is improperly venued in the Southern District of New York. + +80. Insufficient process has been afforded to Ms. Maxwell. + +81. Insufficient service of process has been afforded to Ms. Maxwell. + +82. The First Amended Complaint fails to state a claim upon which relief could be granted. + +83. Plaintiff's claims are barred by the statute of limitations. + +84. Plaintiff failed to take reasonable, necessary, appropriate and feasible steps to mitigate her alleged damages, and to the extent of such failure to mitigate, she should be barred from recovering some or all of the alleged damages she seeks. + +85. Plaintiff's damages, if any, are the proximate result of intervening causes, preexisting medical and mental conditions of Plaintiff, and/or causes that occurred without the knowledge or participation of Ms. Maxwell and for which Ms. Maxwell is not responsible. + +86. Plaintiff's damages, if any, were the result of her own conduct or the conduct of others and were not proximately caused by any action of Ms. Maxwell. + +87. Plaintiff voluntarily or negligently assumed a known risk. + +88. Plaintiff consented to the alleged conduct. + +89. Sections 1591, 1592, I593A, 1594 and 1595 of Title 18 of the United States Code are unconstitutional as applied to Ms. Maxwell. + +90. Plaintiff's claims are barred, in whole or in part, by the affirmative defenses of waiver, estoppel, lathes, and unclean hands. + +### JURY DEMAND + +Ghislaine Maxwell demands a jury trial. + +WHEREFORE, Defendant Ghislaine Maxwell demands judgment as follows: + +- A. That Plaintiff take nothing by way of her First Amended Complaint; +- B. That the First Amended Complaint be dismissed with prejudice; +- C. That Judgment be entered in favor of Defendant Ghislaine Maxwell and against Plaintiff +- D. That Defendant Ghislaine Maxwell be awarded her costs and fees in this action, including reasonable attorneys' fees and pre- and post-judgment interest; and +- E. All other such relief as this Court deems just and proper. + +Dated: August 31, 2018. + +Respectfully submitted, + +s/ Laura A. Menninger + +Laura A. Met i oir + +HADDON, AND P.C. + +150 East 10 Avenue + +Denver, CO 80203 + +Phone: 303.831.7364 + +Fax: 303.832.2628 + +Imenninger@hmflaw.com + +Attorney for Ghislaine Maxwell + +### CERTIFICATE OF SERVICE + +I certify that on August 31, 2018, I served the accompanying Answer on the following counsel of record: + +Sigrid S. McCawley Meredith Boies, Schiller & Flexner, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com + +r Mi POTTINGER LLC 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com + +John E. Stephenson, Jr. Jonathan D. Parente Alexander S. Lorenzo ALSTON & BIRD, LLP 90 Park Avenue New York, NY 10016 john.stephenson@alston.com jonathan.parente@alston.com alexander.lorenzo@alston.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu + +Michael C. Justin Y.K. Michael A. 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LINK IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE + +I, Scott J. Link, hereby declare as follows: + +- 1. I make this Affidavit in connection with my Motion for Admission Pro Hac Vice in the above-captioned matter as co-counsel for Defendant Jeffrey Epstein. + - 2. I am a partner with the law firm of Link & Rockenbach, PA. + - 3. I am a member of good standing of the bar of the state of Florida. (Exhibit A.) + - 4. I have never been convicted of a felony. +- 5. I have never been censured, suspended, disbarred or denied admission or readmission by any court. +- 6. There are no pending disciplinary proceedings against me in any state or federal court. + +I declare under penalty of perjury under the laws of theeinit§d States of America that the foregoing is true and correct.. + +Dated: September J32018 + +Scott J. Li Link & Rocken 1555 Palm Beach Lakes Blvd., Suite 930 West Palm Beach, FL 33401 (561) 847-4408; (561) 855-2891 [fax] scott@linkrocklaw.com + +STATE OF FLORIDA COUNTY OF PALM BEACH + +BEFORE ME, the undersigned authority, personally appeared SCOTT J. LINK who is + +/personally known to me, or provided proper identification [Type: + +and who, upon being first duly sworn according to law, deposes and says that he executed the foregoing Affidavit and it is true and correct to the best of his knowledge and belief. + +IN WITNESS WHEREOF, I have hereunto set my hand and affix the seal of my office in the County and State last aforementioned this day of September, 2018. + +C Ann-eA. G34/1 NOTARY PUBLIC tmA + +MY COMMISSION EXPIRES: + +(Print Name as Commissioned) + +![](_page_1_Picture_12.jpeg) + +# Supreme Court of Florida Certificate of Good Standing + +*I JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that* + +**SCOTT JEFFREY LINK** + +*was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida on October 17, 1986, is presently in good standing, and that the private and professional character of the attorney appear to be good.* + +*WITNESS my hand and the Seal of the Supreme Court of Florida at Tallahassee, the Capital, this September 11, 2018.* + +![](_page_2_Picture_63.jpeg) + +![]()*Clerk of the Supreme Court of Florida.* \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820473/EFTA02820473.metadata.json b/marker2/court-jane-doe-43/EFTA02820473/EFTA02820473.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..be52ab7c33bc7ec92946716d2f0b4347be167776 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820473/EFTA02820473.metadata.json @@ -0,0 +1,223 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820473.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2432, + "elapsed_seconds": 3.73, + "image_assets": [ + "_page_1_Picture_12.jpeg", + "_page_2_Picture_63.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 66.096, + 76.94999999999999 + ], + [ + 290.63665771484375, + 76.94999999999999 + ], + [ + 290.63665771484375, + 105.49249267578125 + ], + [ + 66.096, + 105.49249267578125 + ] + ] + }, + { + "title": "AFFIDAVIT OF SCOTT J. 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GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +No. 17-Civ-00616 (JGK) + +## ORDER FOR ADMISSION PRO HAC VICE + +The motion of Scott J. Link for admission to appear Pro Hac Vice in the above-captioned action is granted. + +Applicant has declared that he is a member in good standing of the bar of the state of Florida and that his contact information is as follows: + +Applicant Name: Scott J. Link Firm Name: Link & Rockenbach, PA Address: 1555 Palm Beach Lakes Boulevard, Suite 930 City/State/Zip: West Palm Beach, Florida 33401 Telephone/Fax: (561) 847-4408; (561) 855-2891 [fax] Email: scott@linkrocklaw.com + +Applicant, having requested admission Pro Hac Vice to appear for all purposes as cocounsel for Defendant Jeffrey Epstein in the above-entitled action. + +IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above-captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. + +Dated: , 2018 + +United States District/Magistrate Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820476/EFTA02820476.metadata.json b/marker2/court-jane-doe-43/EFTA02820476/EFTA02820476.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5a5b835e87b31e970b243167575ea5b76d91c69f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820476/EFTA02820476.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820476.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1251, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 72.08999999999999 + ], + [ + 293.59381103515625, + 72.08999999999999 + ], + [ + 293.59381103515625, + 100.10302734375 + ], + [ + 68.544, + 100.10302734375 + ] + ] + }, + { + "title": "ORDER FOR ADMISSION \nPRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 355.57199999999995, + 196.02 + ], + [ + 506.55810546875, + 196.02 + ], + [ + 506.55810546875, + 224.9830322265625 + ], + [ + 355.57199999999995, + 224.9830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 32 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820476" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820477/EFTA02820477.md b/marker2/court-jane-doe-43/EFTA02820477/EFTA02820477.md new file mode 100644 index 0000000000000000000000000000000000000000..cdfa2e900b757e27d8cc8303bba37e7d8457b7d8 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820477/EFTA02820477.md @@ -0,0 +1,27 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +Plaintiff, + +v. + +JEFFREY EPSTEIN GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +No. 17-Civ-00616 (JGK) + +## MOTION FOR ADMISSION PRO HAC VICE + +Pursuant to Rule 1.3 of the Local Rules of the United State Courts for the Southern and Eastern Districts of New York, I, Scott J. Link, hereby move this Court for an Order for admission to practice Pro Hac Vice as co-counsel for Defendant Jeffrey Epstein in the above-captioned action. + +I am in good standing of the bar of the State of Florida and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony, and I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the Affidavit pursuant to Local Rule 1.3. + +Dated: September 14, 2018 Respectfully Submitted, West Palm Beach, FL + +LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 930 West Palm Beach, Florida 33401 (561) 847-4408; (561) 855-2891 [fax] scott@linkrocklaw.com + +By: Is/ Scott J. Link + +Scott J. Link (FBN 602991) \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820477/EFTA02820477.metadata.json b/marker2/court-jane-doe-43/EFTA02820477/EFTA02820477.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b93ef317c3d0c089a9f62da800e69899933930df --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820477/EFTA02820477.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820477.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1144, + "elapsed_seconds": 0.77, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 293.59381103515625, + 71.28 + ], + [ + 293.59381103515625, + 100.10302734375 + ], + [ + 68.544, + 100.10302734375 + ] + ] + }, + { + "title": "MOTION FOR ADMISSION PRO \nHAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 338.43600000000004, + 209.79000000000002 + ], + [ + 524.5205078125, + 209.79000000000002 + ], + [ + 524.5205078125, + 238.4830322265625 + ], + [ + 338.43600000000004, + 238.4830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 31 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820477" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820478/EFTA02820478.md b/marker2/court-jane-doe-43/EFTA02820478/EFTA02820478.md new file mode 100644 index 0000000000000000000000000000000000000000..12a33704514ace77a06c0cfff51f16d2f62dccd8 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820478/EFTA02820478.md @@ -0,0 +1,35 @@ +October 4, 2018 + +## VIA CM/ECF + +Honorable John G. Koeltl United States District Court United States Courthouse 500 Pearl Street New York, NY 10007 + +Re: Jane Doe 43 v. Jeffrey Epstein, et aL, Case No.: 17-cv-00616 (JGK) — Letter Motion Seeking Pre-Motion Conference + +Dear Judge Koeltl, + +We write today to request a pre-motion conference, pursuant to Local Civil Rule 37.2 to seek the Court's guidance as to the location and timing of Defendant Maxwell's deposition. + +The Court issued its Order denying Defendants' Motions to Dismiss on August 8, 2018. On August 10, 2018 Plaintiff noticed Defendant Maxwell's deposition for August 28, 2018 in New York City, where we believed the depositions should take place. (Plaintiff also noticed the depositions of all other defendants for dates in August and early September.) Ms. Maxwell's counsel informed us she was not available on August 28, 2018. (Each of the other defendant's counsel also stated our noticed dates were unacceptable.) We asked defendants' counsel to confer and propose dates that were acceptable to all of them since we were concerned that the defendants would use each others' asserted unavailability to unduly delay our depositions. It was also important that we have the opportunity to depose the defendants, who we were diligently trying to depose, before they took the deposition of our client, who they had not yet requested to depose. + +Thereafter, we reached agreement on the dates for de sing certain of the defendants other than Ms. Maxwell. We also agreed to make available for deposition in New York on November 5 assuming we had completed our depositions of defendants by then. Plaintiff offered the following dates as options for the de sition of Ms. Maxwell to ensure we were able to complete her deposition before : September 17, 18, 19, 20, 24, 25, 26, 28, October 11, 12, IS, 16, 17, IS, 19, 22, 25 and 26 . Because we could not get agreement on any of those dates, and because time was passing, Plaintiff noticed the deposition of Defendant Maxwell for October 15, 2018 in New York. + +![](_page_1_Picture_1.jpeg) + +Honorable Judge Koeld October 4, 2018 Page 2 + +Thereafter, Defendant Maxwell's counsel said she was unavailable on October 15, 2018. When asked about her availability for the numerous other dates Plaintiff offered in September and October, Defendant's counsel said she was only available on October 25th but insisted that the deposition be taken in London, rather than in New York. Plaintiff explained that the case is pending in the Southern District of New York and Plaintiff should not be required to travel to London to get the Defendant's deposition. We agreed to accommodate counsel for Mr. Epstein by having his deposition in Florida; however, we believe requiring counsel to go to London for Ms. Maxwell's deposition, particularly given how many alternative dates we offered and the fact that Ms. Maxwell resided in New York at the time of the events in question, was unreasonable. (We also note that defendants are requesting that deposition be in New York, rather than in Spain where she resides.) If the Court determines it is appropriate for Ms. Maxwell to be deposed in New York, we are prepared to do so on October 25 or any other day in October other than October 29 and 30. + +If the Court were to determine that it is appropriate for Ms. Maxwell to be deposed in London, we request that she be required to appear October 26, 27, 28, or 29. Mr. Boies, who is planning to depose Ms. Maxwell, has a longstanding mediation commitment in the United States on October 24, which would make it very difficult for him to take Ms. Maxwell's deposition in London on October 25. + +We believe at least part of the defendants' motivation in making it difficult to depose Ms. Maxwell is to manipulate her deposition after deposition. Accordingly, if it is not ssible to depose Ms. Maxwell in either London or New York in October, we request that ■ **deposition be delayed from November 5.** + +**The parties conducted a meet and confer conference call on October 1, 2018, and have subsequently exchanged emails with respect to their relative positions. Unfortunately, we have been unable to resolve the issue without the Court's guidance.** + +**Accordingly, Plaintiff respectfully requests a pre-motion discovery conference pursuant to Local Rule 37.2 and Your Honor's Individual Practice Rules.** + +**Sincerely,** + +**Sigrid S. McCawley Sigrid S. McCawley** + +cc: All Counsel of Record \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820478/EFTA02820478.metadata.json b/marker2/court-jane-doe-43/EFTA02820478/EFTA02820478.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b2c7b1fa46c02f65f16eb14b5dd087535155b105 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820478/EFTA02820478.metadata.json @@ -0,0 +1,126 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820478.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 4477, + "elapsed_seconds": 0.81, + "image_assets": [ + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA CM/ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 160.38 + ], + [ + 147.3926544189453, + 160.38 + ], + [ + 147.3926544189453, + 176.2330322265625 + ], + [ + 68.544, + 176.2330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 86 + ], + [ + "Line", + 42 + ], + [ + "Text", + 7 + ], + [ + "PageHeader", + 3 + ], + [ + "PageFooter", + 3 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 37 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820478" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820478/_page_1_Picture_1.jpeg b/marker2/court-jane-doe-43/EFTA02820478/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..8a6b2b52939fecbe499b1a652702c1adf7c2632f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820478/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:c279fc233b515694cbcb2f6c5d772d9a1cc420fd0270c99f47b90799d4f3c0d9 +size 3549 diff --git a/marker2/court-jane-doe-43/EFTA02820480/EFTA02820480.md b/marker2/court-jane-doe-43/EFTA02820480/EFTA02820480.md new file mode 100644 index 0000000000000000000000000000000000000000..f2d34db1a9670f9e3c308cbac19f120616e43451 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820480/EFTA02820480.md @@ -0,0 +1,39 @@ +Sent: Tuesday, October 2, 2018 10:29 PM + +To: Michael + +Cc: Laura Menninger; Sigrid McCawley; Justin; Scott Link (scott@linkrocklaw.com); Stan Pottinger; Meredith + +inla Paul Cassell (cassellp@law.utah.edu); brad@epllc.com; Jeff Pagliuca + +Subject: Re: Defendant Maxwell's Deposition + +Not necessarily. We are trying to accommodate Ms. Maxwell's counsel. My understanding is that we can do so if deposition is moved to November 8. I had expected that all Defendants' counsel were coordinating. If November 8 works for your deposition of the Plaintiff, and if November 7 still works for the deposition of Ms. Maxwell, I think we are done. If not, then I expect we will try to rearrange things again to try depose the Plaintiff on November 5 and go to the Court with respect to Ms. Maxwell. + +Sent from my iPad + +On Oct 3, 2018, at 1:38 AM, Michael wrote: + +Dear all. We are confirmed for deposition on the 5th. Mike + +Sent from my iPhone + +On Oct 2, 2018, at 6:35 PM, Laura Menninger wrote: + +Hello Sigrid + +I have asked since August to have a phone conferral to schedule all the depositions. I did not receive a response. I also emailed you two available dates on September 4, to which I received no response. I understand that you had multiple conferrals with the other defendants' counsel regarding deposition dates without including me. On our phone conferral yesterday, you were not sure which dates your side could do, thus limiting the usefulness of the call. + +In any event, I can accept a November 8 deposition date for Ghislaine in NY. I am available on either Nov 5 or 7 for in NY. + +Thank you, -Laura + +On Oct 2, 2018, at 1:23 PM, Sigrid McCawley wrote: + +Hello Laura, + +As you know, we have been seeking Defendant Maxwell's deposition since August and have provided multiple date options in an effort to accommodate you and your client. Based on our meet and confer call yesterday, you indicated that a deposition on November 7th or 8 th in New York may be an option for Maxwell given that the parties will be in New York for the mediation on November 9th. Accordingly, we propose that deposition take place on November 7th and Defendant Maxwell's deposition take place on November 8th both in New York. If you and your cocounsel do not agree with these dates then we will depose Defendant Maxwell on October 25th and will go to the Court to determine whether Defendant Maxwell's deposition must be held in the US or London on that date. + +Kindly let me know by close of business today. + +Thank you, Sigrid \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820480/EFTA02820480.metadata.json b/marker2/court-jane-doe-43/EFTA02820480/EFTA02820480.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9432b69f2e18ee4fe12c61dbbbdae83547b81793 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820480/EFTA02820480.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820480.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 2579, + "elapsed_seconds": 1.05, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 97 + ], + [ + "Line", + 40 + ], + [ + "Text", + 22 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820480" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820481/EFTA02820481.md b/marker2/court-jane-doe-43/EFTA02820481/EFTA02820481.md new file mode 100644 index 0000000000000000000000000000000000000000..8f8a64988e4ba6ee4a3c01fbe78750f57094b47f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820481/EFTA02820481.md @@ -0,0 +1,41 @@ +![](_page_0_Picture_1.jpeg) + +October 4, 2018 + +## Via ECF + +Hon. John G. Koeltl United States District Court Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 Haddon. and v c Laura A. Menninger + +150 East 10th Avenue Denver. Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflow.com Imenninger@hmflow.com + +Re: v. Jeffrey Epstein, et al., 17-cv-00616 (JGK) + +Dear Judge Koeltl: + +I write in response to Plaintiff's request for a Local Civil Rule 37.2 pm-motion conference. + +On Monday of this week, the parties engaged in their first all-counsel telephonic conference regarding the scheduling of depositions, in particular the deposition of Ms. Maxwell. On Tuesday, Ms. McCawley for Plaintiff wrote and offered a Maxwell deposition date of November 8 in New York, requesting a response "by close of business today." At 4:36 p.m. that day, undersigned counsel accepted the date of November 8 and the location of New York. See Ex. I (emails of counsel). Six hours later, Mr. Boies for Plaintiff changed that offer, stating that Ms. Maxwell had to be deposed on November 7 and Plaintiff (who previously all agreed would be de sed November 5) must be moved to November 8. He offered no explanation as to why needed to be rescheduled nor has there ever been a discussion with undersigned regarding any demand to have all defendants deposed prior to plaintiff. Ms. Maxwell and her -----' available to travel to New York for the depositions the week of November 5 — both I I on November 5th or 7th and Ms. Maxwell's on November 8 as proposed by Plaintiff. Indeed as all parties and their counsel are scheduled to be in New York for the mediation on November 9, having several depositions that week promotes efficiency and cost-reduction for all parties.' + +Unfortunately, what should be a simple and routine matter of scheduling party depositions has reached this impasse. Plaintiff's recitation of the history of attempts to schedule the depositions omits significant points. Plaintiff served deposition notices on August 10 for all parties without consultation as to their availability in violation of Local Civil Rule 26.4; counsel for Ms. Maxwell informed them that she was unavailable for August 28.2 Undersigned counsel offered a phone + +I Counsel and the parties arc spread across the U.S. and Europe. + +2 On August 28. undersigned counsel was in a previously scheduled two day motions hearing in the U.S. District Court for the District of Colorado, Casc Number 16-cr-00347-WYD. + +Hon. John G. Koeltl October 4, 2018 Page 2 + +conference for all counsel to schedule available dates; Plaintiff never responded. On September 4, undersigned counsel offered October 9 and 10th for Ms. Maxwell's deposition; Plaintiff never responded. Instead, more than 3 weeks later, Plaintiff's counsel served a second deposition notice for Ms. Maxwell for October 15, in violation of Local Civil Rule 26.4. Again, undersigned counsel notified Plaintiff that she is unavailable for October 15 due to previously scheduled depositions and offered new dates of October 23-25 in London where both Ms. Maxwell and her counsel have previously scheduled work commitments. Plaintiff "accepted" the date of October 25 but demanded that the location be New York, where neither counsel nor Ms. Maxwell will be present. + +Plaintiff never communicated to undersigned that her agreement to deposition in New York on November 5 was somehow contingent upon completion of her deposition of defendants by then. Indeed, as the attached shows, Ms. McCawley expressly offered, and counsel for Maxwell accepted, a deposition date for Ms. Maxwell after Plaintiff's. Likewise, counsel is unaware of any authority for making one partv's deposition date contingent upon another's. Ms. Maxwell is not the party who has noticed I deposition nor scheduled the dates. Again, a simple call with counsel for all parties, with their client's and counsel's availability known to the call participants, could resolve all of these issues. + +Unfortunately, yesterday, Plaintiff's counsel for the third time served a deposition notice to Ms. Maxwell with a date and location she knows does not work and ignored the agreement she had already reached for a different date and time. Local Rule 26.4 states the obvious: counsel must "cooperate with each other...in all phases of the discovery process and to be courteous in their dealings with each other including in matters related to scheduling and timing of various discovery procedures." Counsel for Maxwell simply requests that the Court enforce the agreement of the parties, memorialized in the attached email, that the deposition for Ms. Maxwell occur in New York on November 8, 2018. Counsel has not stated they are unavailable on that date, to the contrary, they proposed the date and location and Ms. Maxwell accepted. There is no good faith basis to now serve a deposition notice for another date and location other than that proposed. + +Counsel for Ms. Maxwell respectfully requests a telephone conference with the Court for purposes of resolving the matter without the need for the filing of a motion. + +Respectfully submitted, + +HADDON, AND P.C. + +Is/ Laura A. Menninger Laura A. Menninger + +Attachment: Exhibit I \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820481/EFTA02820481.metadata.json b/marker2/court-jane-doe-43/EFTA02820481/EFTA02820481.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d5fc947a25682a8a579a0deeaca02d224d35f4db --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820481/EFTA02820481.metadata.json @@ -0,0 +1,130 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820481.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 5251, + "elapsed_seconds": 0.84, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Via ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 50.79600000000001, + 197.64 + ], + [ + 102.47271728515625, + 197.64 + ], + [ + 102.47271728515625, + 213.7330322265625 + ], + [ + 50.79600000000001, + 213.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 99 + ], + [ + "Line", + 42 + ], + [ + "Text", + 9 + ], + [ + "Footnote", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 38 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820481" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820481/_page_0_Picture_1.jpeg b/marker2/court-jane-doe-43/EFTA02820481/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a063ef5d2a5d2504cce0203bd341b747d80fc1a1 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820481/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:6c5d212009de37b2610319be24d64632c1a4d007781b41f1908b17685a5aba15 +size 6405 diff --git a/marker2/court-jane-doe-43/EFTA02820483/EFTA02820483.md b/marker2/court-jane-doe-43/EFTA02820483/EFTA02820483.md new file mode 100644 index 0000000000000000000000000000000000000000..82bf724acd63b5cfda88ccfea756cb0e1a90cf02 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820483/EFTA02820483.md @@ -0,0 +1,31 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +Plaintiff, + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +USOC SONY DOCUMENT ELECTRONICALLY FILED DOC# DATE FILED: + +No. I7-Civ-00616 (JGK) + +## ORDER FOR ADMISSION PRO HAC VICE + +The motion of Scott J. Link for admission to appear Pro Hac Vice in the above-captioned action is granted. + +Applicant has declared that he is a member in good standing of the bar of the state of Florida and that his contact information is as follows: + +Applicant Name: Scott J. Link Firm Name: Link & Rockenbach, PA Address: 1555 Palm Beach Lakes Boulevard, Suite 930 City/State/Zip: West Palm Beach, Florida 33401 Telephone/Fax: (561)847-4408; (561) 855-2891 [fax] Email: scott@linkrocklaw.com + +Applicant, having requested admission Pro Hac Vice to appear for all purposes as cocounsel for Defendant Jeffrey Epstein in the above-entitled action. + +IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above-captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. + +Dated: if ) /( ,20I8 + +Um tates Inc a Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820483/EFTA02820483.metadata.json b/marker2/court-jane-doe-43/EFTA02820483/EFTA02820483.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..80fad8db1ae3d22cdd0a42290722d1d5f672e555 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820483/EFTA02820483.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820483.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1296, + "elapsed_seconds": 1.05, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 60.65999984741211, + 59.94 + ], + [ + 261.936, + 59.94 + ], + [ + 261.936, + 86.9495849609375 + ], + [ + 60.65999984741211, + 86.9495849609375 + ] + ] + }, + { + "title": "ORDER FOR ADMISSION \nPRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 318.7499694824219, + 174.96 + ], + [ + 452.26800000000003, + 174.96 + ], + [ + 452.26800000000003, + 199.26 + ], + [ + 318.7499694824219, + 199.26 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 84 + ], + [ + "Line", + 36 + ], + [ + "Text", + 14 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820483" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820484/EFTA02820484.md b/marker2/court-jane-doe-43/EFTA02820484/EFTA02820484.md new file mode 100644 index 0000000000000000000000000000000000000000..c4080795ebcafbb558f8b6cd9cfd7b29e8cbe10f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820484/EFTA02820484.md @@ -0,0 +1,96 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +Plaintiff, + +- against - + +JEFFREY EPSTEIN, ET AL., + +Defendants. + +X + + + + + + + + +X + +USDC SDNY +DOCUMENT +ELECTRONICALLY FILED +DOC#                      +DATE FILED: 10-9-18 + +17 Civ. 616 (JGK) + +Amended + +ORDER OF REFERENCE +TO A MAGISTRATE JUDGE + +*Hell* +*10/15/18* + +JOHN G. KOELTL, District Judge: + +The above entitled action is referred to the designated Magistrate Judge for the following + +purpose(s): + +\_ X General Pretrial (includes scheduling, +discovery, non-dispositive pretrial motions, +and settlement) + +\_ Consent under 28 U.S.C. §636(c) for all +purposes (including trial) + +\_ Specific Non-Dispositive +Motion/Dispute:\* + +\_ Consent under 28 U.S.C. §636(c) for +limited purpose (e.g., dispositive motion, +preliminary injunction) + +\_\_\_\_\_ +\_\_\_\_\_ + +Purpose: \_\_\_\_\_ + +\_ If referral is for discovery disputes when +the District Judge is unavailable, the time +period of the referral is: \_\_\_\_\_ + +\_ Habeas Corpus + +\_ Social Security + +\_ Settlement\* + +\_ Dispositive Motion (i.e., motion requiring +a Report and Recommendation) + +\_ Inquest After Default/Damages Hearing + +\_ Particular Motion: \_\_\_\_\_ +\_\_\_\_\_ + +All such motions: \_\_\_\_\_ + +SO ORDERED. + +DATED: New York, New York +October 4, 2018 + +*John G. Koeltl* + +John G. Koeltl +United States District Judge + +\* Do not check if already referred for general pretrial. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820484/EFTA02820484.metadata.json b/marker2/court-jane-doe-43/EFTA02820484/EFTA02820484.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..aeb877492a58acf3cee924c86dc78f77b55425df --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820484/EFTA02820484.metadata.json @@ -0,0 +1,113 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820484.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1451, + "elapsed_seconds": 7.56, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.823999999999998, + 29.97 + ], + [ + 253.36799999999997, + 29.97 + ], + [ + 253.36799999999997, + 57.50999999999999 + ], + [ + 31.823999999999998, + 57.50999999999999 + ] + ] + }, + { + "title": "ORDER OF REFERENCE TO A MAGISTRATE JUDGE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 364.75199999999995, + 153.89999999999998 + ], + [ + 526.932, + 153.89999999999998 + ], + [ + 526.932, + 179.82 + ], + [ + 364.75199999999995, + 179.82 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 117 + ], + [ + "Text", + 60 + ], + [ + "Line", + 54 + ], + [ + "SectionHeader", + 5 + ], + [ + "PageHeader", + 2 + ], + [ + "Footnote", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820484" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820485/EFTA02820485.md b/marker2/court-jane-doe-43/EFTA02820485/EFTA02820485.md new file mode 100644 index 0000000000000000000000000000000000000000..d24e04f2d007ab8218d65bde0ca76e7bfc8a9dbf --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820485/EFTA02820485.md @@ -0,0 +1,36 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43, + +-against- + +JEFFREY EPSTEIN, et al., + +Plaintiff, + +Defendants. + +X + +X + +| USDC SDNY | | +|----------------------|-----------| +| DOCUMENT | | +| ELECTRONICALLY FILED | | +| DOC #: | | +| DATE FILED: | 10/9/2018 | + +17-CV-00616 (JGK)(SN) + +ORDER + +SARAH NETBURN, United States Magistrate Judge: + +A conference to discuss the parties' October 4, 2018 letters shall be held at 2:00 p.m. on Friday, October 12, 2018. At that time, the parties should jointly call at (212) 805- 0286. + +SO ORDERED. + +DATED: October 9, 2018 New York, New York + +1-) SARAH NETBURN United States Magistrate Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820485/EFTA02820485.metadata.json b/marker2/court-jane-doe-43/EFTA02820485/EFTA02820485.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f5cab31f1953d6b64a694299b4be441aa0a8e83f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820485/EFTA02820485.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820485.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 734, + "elapsed_seconds": 1.21, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 72.9 + ], + [ + 293.59381103515625, + 72.9 + ], + [ + 293.59381103515625, + 100.10302734375 + ], + [ + 69.156, + 100.10302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 56 + ], + [ + "Line", + 28 + ], + [ + "Text", + 14 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Form", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820485" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820486/EFTA02820486.md b/marker2/court-jane-doe-43/EFTA02820486/EFTA02820486.md new file mode 100644 index 0000000000000000000000000000000000000000..73109894857a9af0b2c8f7cf834443b2fe06050f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820486/EFTA02820486.md @@ -0,0 +1,35 @@ +![](_page_0_Picture_1.jpeg) + +October 10, 2018 + +## Via CM/ECF + +The Honorable Magistrate Judge Sarah Netburn United States District Court United States Courthouse 500 Pearl Street New York, NY 10007 + +1555 Palm Beach Lakes Blvd., Suite 930 West Palm Beach, FL 33401 TEL: (561) 8474408 I FAX: (561)855-2891 + +Re: Jane Doe 43 v. Jeffrey Epstein, et aL United States District Court, Southern District of New York Case No. 17-CV-00616 Letter Motion re Discovery Pre-Hearing Conference (October 12, 2018) + +Dear Judge Netbum: + +This firm is co-counsel for Defendant Jeffrey Epstein and we are writing this letter pursuant to Local Civil Rule 37.2. On October 4, 2018, Plaintiff filed a letter motion (D.E. 151) asking the Court for a pre-motion discovery conference to discuss the timing and location of Defendant Maxwell's deposition. That matter has been set for a telephonic hearing on October 12. 2018. at 2:00 a.m. before United States Magistrate Judge Sarah Netburn (D.E. 155). + +An issue has arisen concerning deposition scheduling of all parties, and we respectfully request that the Court address those issues at the October 12, 2018, hearing as well. Specifically, while the parties had previously agreed to a deposition schedule, including setting Plaintiff's deposition for November 5, 2018, Plaintiff's counsel has withdrawn the November 5 date and has now taken the position that he will not make Plaintiff available for deposition until after the depositions of the four Defendants have been taken. There is nothing in the Federal Rules of Civil Procedure or the Local Rules of this Court that allows a plaintiff to dictate the order of depositions or requires that the Defendants' depositions occur first. See Federal Rule of Civil Procedure 26(d)(3). In fact, it is customary in litigation that a plaintiff's deposition be conducted first so that the plaintiff cannot rely on the testimony of the defendants in formulating her positions in the case, mainly when it is a "she said" versus "he said" type litigation. Also see, e.g., McKenzie Management & Research Co. v. Lee Nat'l Corp., 36 A.D.2d 602, 318 N.Y.S.2d 355 (1971X"It is recognized that normally right of priority of examination is accorded the defendant, in the absence of special circumstances."); Serio v. Rhulen, 29 A.D. 3d 1195, 815 N.Y.S.2d 320 (2006Xsame); Klevens Cons:. Co. v. Stale, 87 Misc. 2d 108, 383 N.Y.S.2d 844 (1976X"The rationale for this rule is that the defendant is presumed blameless until claimant proves otherwise and thus should be accorded the opportunity in the first instance to examine plaintiff to determine what plaintiff's lawsuit is about."). + +The Honorable Magistrate Judge Sarah Netbum October 10, 2018 Page 2 + +Currently, Mr. Epstein's deposition is scheduled on October 12, 2018. Mr. Epstein's deposition is premature until this Court and the parties arrive at an agreeable deposition schedule. Accordingly, we have advised Plaintiff's counsel that Mr. Epstein will not appear for his deposition until sequencing issues and other discovery matters are resolved. + +The Civil Scheduling Order entered by The Honorable John G. Koeltl (D.E. 141) dated August 8, 2018, does not provide that all Defendants' depositions must be completed before the Plaintiff is required to sit for her deposition. + +Mr. Epstein respectfully requests this Court's assistance in arriving at a mutually fair and acceptable deposition schedule at the October 12, 2018, pre-motion discovery conference. + +Sincerely, + +/s/ Scott J. Link + +Scott J. Link + +SJUtIc + +cc: All counsel of record (ECF) 20A5436 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820486/EFTA02820486.metadata.json b/marker2/court-jane-doe-43/EFTA02820486/EFTA02820486.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3e779159b10dc1b853e0538d043aa32475449a11 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820486/EFTA02820486.metadata.json @@ -0,0 +1,126 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820486.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3569, + "elapsed_seconds": 0.69, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Via CM/ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 54.467999999999996, + 206.54999999999998 + ], + [ + 129.44467163085938, + 206.54999999999998 + ], + [ + 129.44467163085938, + 221.9830322265625 + ], + [ + 54.467999999999996, + 221.9830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 89 + ], + [ + "Line", + 43 + ], + [ + "Text", + 7 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 21 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820486" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820486/_page_0_Picture_1.jpeg b/marker2/court-jane-doe-43/EFTA02820486/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..4431bdbfea554bda7a12dce7f60f894fffe5334d --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820486/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:3d1c5cc1ce425c03773bb3de988b499e416e3f4de12947b15aa7946ee8df68f9 +size 12946 diff --git a/marker2/court-jane-doe-43/EFTA02820488/EFTA02820488.md b/marker2/court-jane-doe-43/EFTA02820488/EFTA02820488.md new file mode 100644 index 0000000000000000000000000000000000000000..54422dfa569abe7a7d16a2ab39b24ea6350d90ef --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820488/EFTA02820488.md @@ -0,0 +1,27 @@ +## VIA CM/ECF + +October 11, 2018 + +The Honorable Magistrate Judge Sarah Netburn Thurgood Marshall Courthouse 40 Foley Square, Room 430 New York, NY 10007 + +> Re: v. Epstein, et al. Case No.: 17-cv-00616 (JGK) + +Dear Judge Netburn, + +With less than two days' notice, Mr. Epstein's counsel unilaterally and unjustifiably seeks to cancel his deposition which has long been noticed by agreement for October 12, 2018. Plaintiff has worked for months to attempt to schedule this deposition, including agreeing to repeated postponements requested by Mr. Epstein's counsel. The October 12, 2018 date has been agreed to for weeks, and counsel for Plaintiff (David Boies) is already on his way to Florida to take the deposition. + +Plaintiff first noticed Mr. Epstein's deposition for August 21, 2018. Mr. Epstein's counsel asserted that Mr. Epstein was not available on that date, and his deposition was then re-noticed for September 19, 2018. Defendants' counsel again requested a delay and on September 17, 2018, Plaintiff re-noticed the deposition for September 25, 2018, a date requested by Mr. Epstein's counsel. Plaintiff also agreed to hold the deposition in Florida as requested by Defendant Epstein, and to do so at his counsel's offices. Thereafter, even though the September 25 date had been agreed to at Mr. Epstein's request, Mr. Epstein's counsel again requested a delay in the scheduling of the deposition—this time to October 12, 2018. Accordingly, on September 26, 2018, Plaintiff re-noticed Defendant Epstein for the date and location requested by Defendant Epstein's counsel, Friday October 12, 2018 in West Palm Beach, Florida. + +Nothing has changed since this deposition was agreed to and noticed last month. The cases Mr. Epstein's counsel cites are wholly inapposite to the facts of this case. + +Judge Koeltl put the parties on an expedited discovery schedule at the hearing on August 7, 2018 and, in accordance with that schedule, Plaintiff immediately attempted to obtain the depositions of the named Defendants by serving notices on August 10, 2018. Plaintiff has made every effort to be exceedingly reasonable and patient with this deposition scheduling. Defendant Epstein has no + +Honorable Magistrate Judge Sarah Netburn October 11, 2018 Page 2 + +valid justification for unilaterally terminating his deposition scheduled for Friday October 12, 2018. See John Wiley & Sons, Inc. v. Book Dog Books, 298 F.R.D. 145 (S.D.N.Y. 2014) (court sanctioning party under Rule 37(d) when the party failed to appear at the second day of deposition because the plaintiff refused to produce a witness the following week explaining that "it is well established that a party cannot unilaterally refuse to fulfill its discovery obligations as retaliation for another party's discovery violation."); Fu v. Consolidated Edison Co. of New York, 2018 WL 4373995 (S.D.N.Y. 2018)(court sanctioning plaintiff where defendant made multiple attempts to coordinate scheduling of plaintiffs deposition and plaintiff failed to attend her deposition claiming that the defense had made threats against her holding "[w]here a party fails to appear for a deposition, Rule 37(d) requires cost shifting: 'the court must require the party failing [to appear] to pay the reasonable expenses, including attorney's fees cause by that failure.") (quoting in re Bear Sterns Cos., Secs., Derviative, & Erisa Litig., 308 F.R.D. 113, 119 (S.D.N.Y. 2015). + +Accordingly, Plaintiff requests that Defendant Epstein be sanctioned for this conduct, including by an award of attorney's fees and costs, and that his deposition take place as noticed and scheduled by agreement tomorrow, October 12, 2018. + +Sincerely, + +/s/ Sigrid McCawley Sigrid McCawley \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820488/EFTA02820488.metadata.json b/marker2/court-jane-doe-43/EFTA02820488/EFTA02820488.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f51f07d6ffdfc82e0dbb556ce0e1bf741e68cceb --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820488/EFTA02820488.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820488.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + 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+| ELECTRONICALLY FILED | | +| DOC #: | | +| DATE FILED: | 10/12/2018 | + +17-CV-00616 (JGK)(SN) + +ORDER + +X + +SARAH NETBURN, United States Magistrate Judge: + +In light of the parties' representation that they have resolved the deposition scheduling dispute, this afternoon's conference is ADJOURNED sine die. + +SO ORDERED. + +DATED: October 12, 2018 New York, New York + +is) vYI -- SARAH NETBURN United States Magistrate Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820490/EFTA02820490.metadata.json b/marker2/court-jane-doe-43/EFTA02820490/EFTA02820490.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ed38ec6f6b2833b6ab89e2bd3fa797b78a76b173 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820490/EFTA02820490.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820490.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": 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IN SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE + +I, Brittany N. hereby declare as follows: + +- I. I have never been convicted of a felony. +- 2. I have never been censured, suspended, disbarred or denied admission or readmission by any court. +- 3. Them are no pending disciplinary proceedings against me in any state or federal court. +- 4. I am a member in good standing of the bar of the State of Florida. + +I hereby declare under penalty of perjury that the foregoing statements are true and correct. + +Dated: October 29, 2018 + +Fort Lauderdale, Florida Res tfull submitted, POTTINGER, LLC + +/s/ Brittany N. + +Brittany N. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: brittany@epllc.com; ecf@epllc.com Attorney for Plaintiff Jane Doe 43 + +![](_page_1_Picture_106.jpeg) + +# The Florida Bar + +651 East Jefferson Street +Tallahassee, FL 32399-2300 + +Joshua E. [REDACTED] +Executive Director + +850/561-5600 +www.FLORIDABAR.org + +State of Florida ) + +County of [REDACTED] ) + +In Re: 0118247 + +Brittany Nicole [REDACTED] +Pottinger LLC +[REDACTED] Pottinger LLC 425 N Andrews Ave Ste 2 +Ft Lauderdale, FL 33301-3268 + +I CERTIFY THE FOLLOWING: + +I am the custodian of membership records of The Florida Bar. + +Membership records of The Florida Bar indicate that The Florida Bar member listed above was admitted to practice law in the state of Florida on **September 21, 2015**. + +The Florida Bar member above is an active member in good standing of The Florida Bar who is eligible to practice law in the state of Florida. + +Dated this 29th day of **October, 2018**. + +![]()Pam Gerard, Manager +Membership Records Dept. +The Florida Bar + +PG:R10 +CTM-26453 + +![](_page_1_Picture_123.jpeg) \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820491/EFTA02820491.metadata.json 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+Address: 425 North Andrews Avenue, Suite 2 + +City / State / Zip: Fort Lauderdale, Florida 33301 + +Telephone / Fax: (954) 524-2820/ (954) 524-2822 + +Applicant having requested admission Pro Hat Vice to appear for al purposes as counsel for Plaintiff Jane Doe 43 in the above entitled action; + +IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. 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I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3 + +Dated: October 29, 2018 + +Fort Lauderdale, Florida Respectfully submitted, + +POTT1NGER, LLC + +/s/ Brittany N. + +Brittany N. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: brittany@epllc.com + +Attorney for Plaintiff Jane Doe 43 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820494/EFTA02820494.metadata.json b/marker2/court-jane-doe-43/EFTA02820494/EFTA02820494.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8d7870cd955ffdb7f5cd0a40474a4168816994e0 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820494/EFTA02820494.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820494.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1143, + "elapsed_seconds": 0.81, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 63.647999999999996, + 62.37 + ], + [ + 289.5074768066406, + 62.37 + ], + [ + 289.5074768066406, + 91.10302734375 + ], + [ + 63.647999999999996, + 91.10302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 33 + ], + [ + "Text", + 15 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820494" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820495/EFTA02820495.md b/marker2/court-jane-doe-43/EFTA02820495/EFTA02820495.md new file mode 100644 index 0000000000000000000000000000000000000000..3bf9750c0556254dfd6e2099845f090351def66a --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820495/EFTA02820495.md @@ -0,0 +1,46 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff, + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +## AFFIRMATION OF BRITTANY N. IN SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE + +I, Brittany N. hereby declare as follows: + +- I. I have never been convicted of a felony. +- 2. I have never been censured, suspended, disbarred or denied admission or readmission by any court. +- 3. Them are no pending disciplinary proceedings against me in any state or federal court. +- 4. I am a member in good standing of the bar of the State of Florida. + +I hereby declare under penalty of perjury that the foregoing statements are true and correct. + +Dated: October 29, 2018 + +Fort Lauderdale, Florida Res tfull submitted, POTTINGER, LLC + +/s/ Brittany N. + +Brittany N. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: brittany@epllc.com; ecf@epllc.com Attorney for Plaintiff Jane Doe 43 + +## fpupremr (Court of jitortba Certificate of Octal Rptanbing + +I JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that + +BRITTANY NICOLE + +was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida on September 21, 2015, is presently in good standing, and that the private and professional character of the attorney appear to be good. + +> WITNESS my hand and the Seal of the Supreme Court of Florida at Tallahassee, the Capital, this October 30, 2018. + +![](_page_1_Picture_6.jpeg) + +Clerk of the Supreme Court of Florida. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820495/EFTA02820495.metadata.json b/marker2/court-jane-doe-43/EFTA02820495/EFTA02820495.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..df63d018c9e4422507a94bf0a23f071c0ebb7b20 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820495/EFTA02820495.metadata.json @@ -0,0 +1,184 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820495.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1632, + "elapsed_seconds": 0.84, + "image_assets": [ + "_page_1_Picture_6.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 63.647999999999996, + 62.37 + ], + [ + 289.5074768066406, + 62.37 + ], + [ + 289.5074768066406, + 91.10302734375 + ], + [ + 63.647999999999996, + 91.10302734375 + ] + ] + }, + { + "title": "AFFIRMATION OF \nBRITTANY N. \nIN SUPPORT OF \nAPPLICATION FOR \nADMISSION \nPRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 373.32, + 174.14999999999998 + ], + [ + 493.563232421875, + 174.14999999999998 + ], + [ + 493.563232421875, + 257.2330322265625 + ], + [ + 373.32, + 257.2330322265625 + ] + ] + }, + { + "title": "fpupremr (Court of jitortba \nCertificate of Octal Rptanbing", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 139.82500000000002, + 112.26129150390625 + ], + [ + 479.5024108886719, + 112.26129150390625 + ], + [ + 479.5024108886719, + 179.13775634765625 + ], + [ + 139.82500000000002, + 179.13775634765625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 36 + ], + [ + "Text", + 12 + ], + [ + "ListItem", + 4 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820495" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820495/_page_1_Picture_6.jpeg b/marker2/court-jane-doe-43/EFTA02820495/_page_1_Picture_6.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3178b85c5f90e3947685574d891f04e05d89b846 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820495/_page_1_Picture_6.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:ffe810a80ed1fcffd342e1ebc85a88e8edbf69a10f1d26c0896afbdefed8e3d0 +size 15862 diff --git a/marker2/court-jane-doe-43/EFTA02820497/EFTA02820497.md b/marker2/court-jane-doe-43/EFTA02820497/EFTA02820497.md new file mode 100644 index 0000000000000000000000000000000000000000..5a2799e46e285b8018167aa82f292eca99c58479 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820497/EFTA02820497.md @@ -0,0 +1,13 @@ +## fpupreme Court of Liftortba Certificate of oob \*tartbing + +I JOHN 4. TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that + +BRITTANY NICOLE + +was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida on September 21, 2015, is presently in good standing, and that the private and professional character of the attorney appear to be good. + +> WITNESS my hand and the Seal of the Supreme Court of Florida at Tallahassee, the Capital, this October 30, 2018. + +![](_page_0_Picture_6.jpeg) + +17 Clerk of the Supreme Court of Florida. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820497/EFTA02820497.metadata.json b/marker2/court-jane-doe-43/EFTA02820497/EFTA02820497.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..77d057d6e90f5bfc928e99b40f8b817431808606 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820497/EFTA02820497.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820497.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 608, + "elapsed_seconds": 0.55, + "image_assets": [ + "_page_0_Picture_6.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "fpupreme Court of Liftortba \nCertificate of oob *tartbing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 139.82500000000002, + 112.2757568359375 + ], + [ + 478.4914245605469, + 112.2757568359375 + ], + [ + 478.4914245605469, + 179.50775146484375 + ], + [ + 139.82500000000002, + 179.50775146484375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 34 + ], + [ + "Line", + 16 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820497" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820497/_page_0_Picture_6.jpeg b/marker2/court-jane-doe-43/EFTA02820497/_page_0_Picture_6.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5f39437bc4d3a6caee22dbb588c9bcdd9791361b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820497/_page_0_Picture_6.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:99db642de65fd3eab8c0ff2fb2a6d3d7cf5d71ccf908e41a354432b140a1c415 +size 15856 diff --git a/marker2/court-jane-doe-43/EFTA02820498/EFTA02820498.md b/marker2/court-jane-doe-43/EFTA02820498/EFTA02820498.md new file mode 100644 index 0000000000000000000000000000000000000000..3810c087e0ee5d7301c69e8c5ca2ef25d2fe295c --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820498/EFTA02820498.md @@ -0,0 +1,33 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintiff + +v. + +JEFFREY EPSTEIN, GH1SLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +## ORDER FOR ADMISSION PRO HAC VICE + +The motion of Brittany N. to appear Pro Hac Vice in the above-captioned action is granted. + +Applicant has declared that he is a member in good standing of the bar of the State of Florida; and that her contact information is as follows: + +Applicant Name: Brittany N. + +Firm Name: Pottinzer LLC + +Address: 425 North Andrews Avenue, Suite 2 + +City / State / Zip: Fort Lauderdale, Florida 33301 + +Telephone / Fax: (954) 524-2820/ (954) 524-2822 + +Applicant having requested admission Pro Hac Vice to appear for al purposes as counsel for Plaintiff Jane Doe 43 in the above entitled action; + +IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules Governing discipline of attorneys. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820498/EFTA02820498.metadata.json b/marker2/court-jane-doe-43/EFTA02820498/EFTA02820498.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7d7115987e444c77633f2cb8f70d8720b02f1314 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820498/EFTA02820498.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820498.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1142, + "elapsed_seconds": 0.9, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 64.25999999999999, + 57.50999999999999 + ], + [ + 289.5074768066406, + 57.50999999999999 + ], + [ + 289.5074768066406, + 86.60302734375 + ], + [ + 64.25999999999999, + 86.60302734375 + ] + ] + }, + { + "title": "ORDER FOR ADMISSION \nPRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 373.93199999999996, + 168.48 + ], + [ + 524.9116821289062, + 168.48 + ], + [ + 524.9116821289062, + 197.60302734375 + ], + [ + 373.93199999999996, + 197.60302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 31 + ], + [ + "Text", + 17 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820498" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820499/EFTA02820499.md b/marker2/court-jane-doe-43/EFTA02820499/EFTA02820499.md new file mode 100644 index 0000000000000000000000000000000000000000..ff4d04cdaf49a0c73c4140c8ee20a4d1fe84add5 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820499/EFTA02820499.md @@ -0,0 +1,29 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +Plaintd, + +v. + +JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +No. 17 Civ. 00616 (JGK) + +## MOTION FOR ADMISSION PRO HAC VICE + +Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, Brittany N. hereby moves this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Plaintiff Jane Doe 43 in the abovecaptioned action. + +I am in good standing of the bar of the State of Florida and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3 + +Dated: October 31, 2018 Fort Lauderdale, Florida Respectfully submitted, + +POTTINGER, LLC + +/s/ Brittany N. + +Brittany N. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: brittany@epllc.com + +Attorney for Plaintiff Jane Doe 43 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820499/EFTA02820499.metadata.json b/marker2/court-jane-doe-43/EFTA02820499/EFTA02820499.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e934b57a6078dd2ba3ac5ff344d9ab4e37604cc5 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820499/EFTA02820499.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820499.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1145, + "elapsed_seconds": 0.82, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 64.25999999999999, + 62.37 + ], + [ + 289.5074768066406, + 62.37 + ], + [ + 289.5074768066406, + 91.10302734375 + ], + [ + 64.25999999999999, + 91.10302734375 + ] + ] + }, + { + "title": "MOTION FOR ADMISSION \nPRO HAC VICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 373.93199999999996, + 173.34 + ], + [ + 532.7816772460938, + 173.34 + ], + [ + 532.7816772460938, + 201.7330322265625 + ], + [ + 373.93199999999996, + 201.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 33 + ], + [ + "Text", + 14 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820499" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820500/EFTA02820500.md b/marker2/court-jane-doe-43/EFTA02820500/EFTA02820500.md new file mode 100644 index 0000000000000000000000000000000000000000..e2b6fcbb56e0df91767169ca3440aef27a67a60b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820500/EFTA02820500.md @@ -0,0 +1,58 @@ +## United States District Court Southern District Of New York + +X + +Plaintiff, + +v. + +Jeffrey E stein, Ghislaine Maxwell, Lesley Groff and Natalya + +Defendants. + +X + +No. 17 Civ. 0616 (JGK) + +## PROTECTIVE ORDER + +Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information or information which will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in this case, IT IS ORDERED: + +- 1. This Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. + +- 2. As used in this Protective Order, "document" is defined as provided in FED.R.Civ.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term. +- 3. Information confidential +- (a) plaintiff Maxwell, designated "CONFIDENTIAL" shall be information that and implicates common law and statutory privacy interests is of and (b) defendants Jeffrey Epstein, Ghislaine Lesley Groff and Natalya +- 4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case. +- 5. CONFIDENTIAL documents, materials, and/or information (collectively "CONFIDENTIAL INFORMATION") shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to: + - a. attorneys actively working on this case; + - b. persons regularly employed or associated with the attorneys actively working on this case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case; + - c. the parties; + - d. expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case; + +- e. the Court and its employees ("Court Personnel") in this case; +- f. stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action; +- g. deponents, witnesses, or potential witnesses; and +- h. other persons by written agreement of the parties. +- 6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person listed above (other than counsel, persons employed by counsel, Court Personnel and stenographic reporters), counsel shall provide such person with a copy of this Protective Order and obtain from such person a written acknowledgment stating that he or she has read this Protective Order and agrees to be bound by its provisions. All such acknowledgments shall be retained by counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated by opposing counsel. +- 7. Documents are designated as CONFIDENTIAL by placing or affixing on them (in a manner that will not interfere with their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by number. To the extent practical, the respective legend shall be placed near the number. +- 8. Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an attorney for the designating party, that there is a valid and good faith basis for + +such designation, made at the time of disclosure or production to the receiving party, and that disclosure of such information to persons other than those permitted access to such material would cause a privacy harm to the designating party. + +- 9. Whenever a deposition involves the disclosure of CONFIDENTIAL INFORMATION, the deposition or portions thereof shall be designated as CONFIDENTIAL and shall be subject to the provisions of this Protective Order. Such designation shall be made on the record during the deposition whenever possible, but a party may designate portions of depositions as CONFIDENTIAL after transcription, provided written notice of the designation is promptly given to all counsel of record within thirty (30) days after notice by the court reporter of the completion of the transcript, and until the expiration of such thirty (30) days after notice by the court reporter of the completion of the transcript, no party or counsel for any such party may share the contents of the deposition outside the limitations of this Protective Order. +- 10. Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. +- 11. A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the disputed + +information. The written notice shall identify the information to which the objection is made. If the parties cannot resolve the objection within ten (10) business days after the time the notice is received, it shall be the obligation of the party designating the information as CONFIDENTIAL to file an appropriate motion requesting that the Court determine whether the disputed information should be subject to the terms of this Protective Order. If such a motion is timely filed, the disputed information shall be treated as CONFIDENTIAL under the terms of this Protective Order until the Court rules on the motion. If the designating party fails to file such a motion within the prescribed time, the disputed information shall lose its designation as CONFIDENTIAL and shall not thereafter be treated as CONFIDENTIAL in accordance with this Protective Order. In connection with a motion filed under this provision, the party designating the information as CONFIDENTIAL shall bear the burden of establishing that good cause exists for the disputed information to be treated as CONFIDENTIAL. + +- 12. At the conclusion of this case, unless other arrangements are agreed upon, each document and all copies thereof which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL documents. Where the parties agree to destroy CONFIDENTIAL documents, + +the destroying party shall provide all parties with an affidavit confirming the destruction. + +- 13. This Protective Order shall have no force and effect on the use of any CONFIDENTIAL INFORMATION at trial in this matter. +- 14. 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Magistrate Sarah Netburn Thurgood Marshall Courthouse Southern District of New York 40 Foley Square, Room 430 New York, New York 10007 + +Haddon. and r.e Laura A. Menninger + +I50 East 10th Avenue Denver. Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmtlaw.com Imenninger@hmftow.com + +Re: v. Jeffrey Epstein, et al., 17-cv-00616 (JGK) + +Dear Judge Netburn: + +I write to ask the Court to enter the attached proposed Protective Order in advance of my client, Ms. Ghislaine Maxwell's, deposition in this matter on Thursday, November 8, 2018. + +As this Court is aware, the parties ultimately agreed Ms. Maxwell's deposition would occur in New York on November 8, 2018. At the time the parties reached that agreement on October 12, 2018, counsel for Plaintiff and for the other Defendants all oral/ indicated their agreement to use the protective order that was agreed to by the same counsel in v. Maxwell, 15-cv-7433-RWS, Doc. #62, and signed by Judge Robert Sweet. + +Last Tuesday, in advance of producing documents responsive to Plaintiff's Request for Production of Documents, I circulated that same protective order and asked whether I could submit it as a proposed joint protective order. On Thursday afternoon and on Sunday, counsel for Plaintiff submitted proposed changes to the protective order. Undersigned counsel agreed to one of the changes and countered the other proposed change. Today, counsel for Mr. Epstein proposed other changes. In sum, the parties have been unable to agree on the changes as of today's date. + +Due to the sensitive nature of the topics at issue in this case, it is imperative that a protective order be in place prior to Ms. Maxwell's production of documents and prior to her deposition on Thursday. See, e.g., id. at Doc. # 953 (Opinion and Order of Hon. Robert W. Sweet) (discussing reliance by parties and witnesses on the protective order concerning topics of a highly sensitive nature). While counsel may all ultimately agree to modifications to the attached protective order, Ms. Maxwell wants to ensure that the deposition proceed as scheduled. Travel for counsel and the parties are required for the New York deposition. Therefore, Ms. Maxwell requests that, in the interim, this Court adopt the same protective order so that the documents may be produced and the deposition may proceed, both of which may include designation of Confidential Information. + +Hon. Sarah Netburn November 6, 2018 Page 2 + +Counsel for Ms. Maxwell respectfully requests a telephone conference with the Court for purposes of resolving the matter without the need for the filing of a motion. + +Respectfully submitted, + +HADDON, AND , P.C. + +/s/ Laura A. Menninger + +Laura A. 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I now appear in this case as co-counsel for Defendants and Lesley Groff as well. + +Dated: November 6, 2018 Respectfully Submitted, West Palm Beach, FL + +LINK & ROCICENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 930 West Palm Beach, Florida 33401 (561) 847-4408; (561) 855-2891 [fax] scott@linkrocklaw.com + +By: /s/ Scott J. Link Scott J. Link (FBN 602991) Co-counsel or Defendants Jeffrey Epstein, and Lesley Groff + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on November 6, 2018, I served a copy of this document upon counsel for the parties listed on the following Service List through the Court's ECF filing system. + +> LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 930 West Palm Beach, Florida 33401 (561) 847-4408; (561) 855-2891 [fax] scon@linkrocklaw.com + +By: /s/ Scott J. Link Scott J. Link (FBN 602991), Pro Hac Vice Co-counsel .or Defendants Jeffrey Epstein, and Lesley Groff + +## SERVICE LIST + +v. Jeffrey Epstein, et at Case No. 17-Civ-616 (JGK)(SN) United States District Court, Southern District of New York + +Michael C. Justin Y.K. 1114 Avenue of the Americas New York, NY 10036 mmiller@steptoe.com jcu@steptoe.com Tel. 212-206-3900 Fax 212-506-3950 Counsel or Defendants Jeffrey Epstein, and Lesley Groff + +J. Stanley er AinN. Br Pottinger LLC 425 N. Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301 Tel. 954-5242820 brad@eplIc.com stan@epllc.com brittany@epllc.com Counsel for Plaintiff + +Sigrid McCaa Meredith David Boies Boies Schiller Flexner LLP smccawley@bsfllp.com mschultz@bsfllp.com dboies@bsfllp.com 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 Tel. 954-356-0011 Counsel for Plaintiff + +Paul G. Cassell S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 Tel. 801-585-5202 cassellp@law.utah.edu Counsel for Plaintiff + +Laura A. Menninger + +Jeffrey Pa toliuca + +Haddon, & P.C. + +150 East 101 Avenue + +Denver, CO 80203 + +lmenninger@hmflaw.com + +jpagliuca@hmflaw.com + +Counsel for Defendant Ghislaine Maxwell \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820508/EFTA02820508.metadata.json b/marker2/court-jane-doe-43/EFTA02820508/EFTA02820508.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f2a79902420319b245be054d3fde7fc650e7dbfe --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820508/EFTA02820508.metadata.json @@ -0,0 +1,227 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820508.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2371, + "elapsed_seconds": 0.85, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 72.08999999999999 + ], + [ + 293.59381103515625, + 72.08999999999999 + ], + [ + 293.59381103515625, + 100.10302734375 + ], + [ + 68.544, + 100.10302734375 + ] + ] + }, + { + "title": "APPEARANCE OF COUNSEL FOR DEFENDANTS \nLESLEY GROFF AND", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 165.24, + 320.76 + ], + [ + 447.5624694824219, + 320.76 + ], + [ + 447.5624694824219, + 349.4830322265625 + ], + [ + 165.24, + 349.4830322265625 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 223.38, + 72.08999999999999 + ], + [ + 388.9223937988281, + 72.08999999999999 + ], + [ + 388.9223937988281, + 86.2330322265625 + ], + [ + 223.38, + 86.2330322265625 + ] + ] + }, + { + "title": "SERVICE LIST", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 261.324, + 319.14000000000004 + ], + [ + 351.515380859375, + 319.14000000000004 + ], + [ + 351.515380859375, + 334.4830322265625 + ], + [ + 261.324, + 334.4830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 52 + ], + [ + "Line", + 25 + ], + [ + "Text", + 12 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 120 + ], + [ + "Line", + 59 + ], + [ + "Text", + 8 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 11 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820508" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820511/EFTA02820511.md b/marker2/court-jane-doe-43/EFTA02820511/EFTA02820511.md new file mode 100644 index 0000000000000000000000000000000000000000..5dfc83a9501285864409d49e8cd5977e14a9048b --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820511/EFTA02820511.md @@ -0,0 +1,25 @@ +![](_page_0_Picture_1.jpeg) + +November 6, 2018 + +## Via CM/ECF + +The Honorable Magistrate Sarah Netburn United States District Court Thurgood Marshall Courthouse 40 Foley Square, Room 430 New York, NY 10007 + +Re: Jane Doe 43 v. Jeffrey Epstein, et al. United States District Court, Southern District of New York Case No. 174-CV-00616 (JGK) Letter re Protective Order + +Dear Magistrate Netburn: + +This firm is co-counsel for Defendants Jeffrey Epstein, and Lesley Groff and we are writing this letter pursuant to Local Rule 37.2. We have no objection to the Court entering the proposed Protective Order provided by Laura Menninger on behalf of Defendant Ghislaine Maxwell (D.E. 163). The parties in this case verbally agreed to use the same Protective Order as was entered by The Honorable Robert Sweet in Case No. 15-cv-7433-RWS (D.E. 62). + +Thank you for your consideration. + +Sincerely, + +Is/ Scott J. Link + +Scott J. 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Jeffre E stein, Ghislaine Maxwell, Lesley Groff and Natalya Defendants. ------------- + +## PROTECTIVE ORDER + +Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information in this case, IT IS ORDERED: + +- 1. This Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure which has been designated as CONFIDENTIAL pursuant to the terms of this Order. +- 2. As used in this Protective Order, "document" is defined as provided in FED. R. + - CIV. P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term. + +- 3. Information designated "CONFIDENTIAL" shall be information that a person has a good faith basis to believe that the material is entitled to confidential treatment under the Federal Rules of Civil Procedure. +- 4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case. +- 5. CONFIDENTIAL documents, materials, and/or information (collectively "CONFIDENTIAL INFORMATION") shall not, without the consent of the person producing it or further Order of the Court, be disclosed except that such information may be disclosed to: + - a. attorneys actively working on this case; + - b. persons regularly employed or associated with the attorneys actively working on this case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case; + - c. the parties; + - d. expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case; + - e. the Court and its employees ("Court Personnel") in this case; + - f. stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action; + - g. deponents, witnesses, or potential witnesses; and + - h. other persons by written agreement of the parties. + +- 6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person listed above (other than counsel, persons employed by counsel, Court Personnel and stenographic reporters), counsel shall provide such person with a copy of this Protective Order and obtain from such person a written acknowledgment stating that he or she has read this Protective Order and agrees to be bound by its provisions. All such acknowledgments shall be retained by counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated by opposing counsel. +- 7. Documents are designated as CONFIDENTIAL by placing or affixing on them (in a manner that will not interfere with their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by number. To the extent practical, the respective legend shall be placed near the number. +- 8. Only the person producing the CONFIDENTIAL INFORMATION or a person who has a right to have such producing party keep their information confidential, may designate it as "CONFIDENTIAL". Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an attorney for the designating person, that there is a valid and good faith basis under applicable law for asserting CONFIDENTIAL treatment of such information, made at the time of disclosure or production to the receiving party, and that disclosure of such information to persons other than those permitted access to such material would cause a significant privacy harm to the designating person. + +- 9. Whenever a deposition involves the disclosure of CONFIDENTIAL INFORMATION, the deposition or portions thereof shall be designated as CONFIDENTIAL and shall be subject to the provisions of this Protective Order. Such designation shall be made on the record during the deposition whenever possible, but a person may designate portions of depositions as CONFIDENTIAL after transcription, provided written notice of the designation is promptly given to all counsel of record within thirty (30) days after notice by the court reporter of the completion of the transcript, and until the expiration of such thirty (30) days after notice by the court reporter of the completion of the transcript, no party or counsel for any such party may share the contents of the deposition outside the limitations of this Protective Order. +- 10. Whenever a person seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. +- II. A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the person designating the disputed information. The written notice shall identify the information to which the objection is made. If the parties cannot resolve the objection within ten (10) business days after the time the notice is received, it shall be the obligation of the person designating the information as CONFIDENTIAL to file an appropriate motion requesting that the Court determine whether the disputed information should be subject to the terms of this Protective Order. If such a motion is timely + +filed, the disputed information shall be treated as CONFIDENTIAL under the terms of this Protective Order until the Court rules on the motion. If the designating person fails to file such a motion within the prescribed time, the disputed information shall lose its designation as CONFIDENTIAL and shall not thereafter be treated as CONFIDENTIAL in accordance with this Protective Order. In connection with a motion filed under this provision, the person designating the information as CONFIDENTIAL shall bear the burden of establishing that good cause exists for the disputed information to be treated as CONFIDENTIAL. + +- 12. At the conclusion of this case, unless other arrangements are agreed upon, each document and all hard copies thereof which have been designated as CONFIDENTIAL shall be returned to the person that produced the document, or the parties may elect to destroy CONFIDENTIAL documents. Where the parties agree to destroy CONFIDENTIAL hard copy documents, the destroying party shall provide all parties with an affidavit confirming the destruction. As to all electronic copies, the party in receipt of the CONFIDENTIAL document will submit an affidavit attesting that they will hold as CONFIDENTIAL all electronic copies and will not distribute the electronic copies absent an Order of the Court. For purposes of this Protective Order, an Order of the Court does not include a subpoena issued without the approval of a court. +- 13. In the event that any party who has maintained possession of electronic copies of information designated CONFIDENTIAL by another person receives a subpoena for the affected materials, the party-in-possession shall within 3 business days notify in writing (a) the person who designated the information as + +CONFIDENTIAL, (b) any person who had the right to have the information contained therein kept as CONFIDENTIAL, and (c) all other parties to this action, of the existence of the subpoena and forward a copy of such subpoena to each of them. Unless so ordered by a court, the party receiving the subpoena shall not produce such CONFIDENTIAL materials within 12 days of receipt of any such subpoena so as to afford the opportunity by affected persons to file a motion to quash or for a protective order. + +- 14. This Protective Order shall have no force and effect on the use of any CONFIDENTIAL INFORMATION at trial in this matter. +- 15. 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Jeffrey Epstein, et at, Case No.: 17-cv-00616 (JGK) — Response to Defendant Maxwell's Letter re Protective Order + +Dear Magistrate Netburn, + +Plaintiff first sent out her notice seeking to depose Defendant Maxwell on August 10, 2018. Due to numerous rescheduling requests from the Defendants, we are now in November and Plaintiff is finally getting to depose Defendant Maxwell this Thursday, November 8, 2018. All of the other Defendants in the case have asserted their Fifth Amendment rights and refused to provide substantive testimony. It is critical that Ms. Maxwell's deposition proceed now as discovery is set to close on January 25, 2018. + +Plaintiff also served requests for production on Defendant Maxwell and despite those requests originally being due over three weeks ago, Plaintiff granted Defendant Maxwell her requested two week extension under the express agreement that Plaintiff would have the documents in advance of Maxwell's deposition. Defendant Maxwell refused to produce the documents last week asserting that she will not produce any documents until the Plaintiff agrees to a Protective Order. + +Unlike the case referenced by Defendant Maxwell that was pending before Judge Sweet, the Plaintiff in this case was not a minor at the time the Defendants subjected her to sexual trafficking. Therefore, the concerns that would typically require a broad Protective Order, were not at issue in this case. Nevertheless, in an effort to avoid unnecessary disputes with this Court, Plaintiff agreed to Defendant Maxwell's proposed protective order with only slight modifications. The modifications were intended to prevent for abuse of the protective order and to ensure that only the person to whom the confidential information belonged could mark it as confidential to avoid a defendant making sweeping unjustified confidentiality designations. Attached to this correspondence is the Plaintiff's revisions to Defendant Maxwell's proposed Protective Order. Thereafter, the Epstein Defendants proposed a number of broad changes to the + +![](_page_1_Picture_1.jpeg) + +Honorable Magistrate Sarah Netbum November 6, 2018 Page 2 + +Protective Order in an admitted attempt to allow anybody to "designate anything they want as confidential," without the need for that confidential designation to be justified under the Federal Rules of Civil Procedure. + +We have agreed to hold all documents produced, and the deposition itself, confidential until the Court rules on what protective order, if any, is appropriate. Under these circumstances, we see no possible justification for Ms. Maxwell to continue to withhold documents or not appear for her deposition. + +Plaintiff respectfully requests that the Court order Defendant Maxwell to produce her documents today and sit for her long scheduled deposition on Thursday, November 8, 2018. If the Court is inclined to enter a Protective Order in this matter, Plaintiff respectfully requests that it enter the Plaintiff's proposed version attached hereto. + +Sincerely, + +Sigrid S. McCawley Sigrid S. 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McCawley. Esq. Telephone: (954) 377-4236 Email: smccawlev@bsfllo.com + +November 6, MI 8 + +## VIA CM/ECF + +Honorable Magistrate Sarah Netbum United States District Court Thurgood Marshall Courthouse 40 Foley Square, Rm 430 New York, NY 10007 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et aL, Case No.: 17-cv-00616 (JGK) — Response to Defendants Jeffrey Epstein, and Lesley Groff 's Letter re Protective Order + +Dear Magistrate Netbum, + +We are in receipt of Scott Link's letter to the Court this morning. As Mr. Link has been informed, there is no verbal agreement to use the protective order entered by Judge Sweet as the protective order in this case. We believe the circumstances here are quite different, and that the order entered by Judge Sweet in the case before him cannot be justified in the case before Your Honor. + +Sincerely, + +Sigrid S. McCawley Sigrid S. 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Menninger + +150 East 10th Avenue Denver, Colorado 80203 pm 303.831.7364 rx 303.832.2628 www.hmflow.com Imenninger@hmflow.com + +November 6, 2018 + +## Via ECF + +The Hon. Magistrate Sarah Netbum Thurgood Marshall Courthouse Southern District of New York 40 Foley Square, Room 430 New York, New York 10007 + +Re: v. Jeffrey Epstein, et al., 17-cv-00616 (JGK) + +Dear Judge Netburn: + +I write in reply to correspondence from Ms. McCawley of today's date and in further support of my request to enter the proposed protective order I submitted last night. + +Plaintiff's request that Ms. Maxwell needs to be "ordered" to sit for her deposition on November 8, 2018, a date that both parties agreed to and have planned for, lacks factual or legal basis. It is Ms. Maxwell who has sought to have the protective order issue resolved prior to the scheduled deposition and it has been Plaintiff's counsel who have commenced gamesmanship around its terms. Mr. Boies on behalf of Plaintiff stated to counsel that he agreed to use the protective order and then did an about-face at the last minute just before Ms. Maxwell was to produce her documents. Likewise, the prior record before this Court demonstrates it was Plaintiff who served deposition notices for parties without coordinating with counsel's schedules in violation of Local Rule 26.4(a), Plaintiff's counsel who ignored offered deposition dates in September, and who offered the November 8 deposition date, only to reverse course hours after Ms. Maxwell accepted it. It took an application by Ms. Maxwell to this Court to get Plaintiff's counsel to respect the agreement they already made for that date. See Doc. #s 152, 152-1. + +Regarding the competing proposed protective orders Plaintiff's proposal is not a "slight modification" to the one her counsel agreed to in the matter. To the contrary, Plaintiff at paragraph 12 seeks to hold indefinitely in her possession electronic copies of the Confidential information, rather than to return or destroy the Confidential information at the conclusion of the case as she a ed to do in . As has become clear from press-inquiries, Plaintiff's counsel's clients, both have cooperated in journalist interviews including soonto-be published series of stories concerning Mr. Epstein. The new request by Plaintiff's counsel to indefinitely possess Confidential information in electronic form beyond the end of the case has not been justified — not in direct request to the counsel and certainly not to this Court. There is no legitimate case-based reason for doing so. + +Hon. Sarah Netburn November 6, 2018 Page 2 + +Given Plaintiff's counsel's agreement at this point to hold the documents Confidential pursuant to the terms of the proposed Orders, Ms. Maxwell will produce her documents. She requests, however, that this Court sign the protective order used in as she earlier proposed, and as Plaintiff's counsel earlier agreed, with the right of the parties to seek modifications in the future upon good cause if necessary. + +Respectfully submitted, + +HADDON, AND P.C. + +Is/ Laura A. Menninger + +Laura A. 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This Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. +- 2. As used in this Protective Order, "document" is defined as provided in FED.R.CIV.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term. + +- 3. Information designated "CONFIDENTIAL" shall be information that is confidential and implicates common law and statutory privacy interests, including information reflecting medical or psychological conditions, medical or psychological treatment, prescriptions for controlled substances, non-public personal financial information, sexual activity or sexual contact, education records, email addresses, telephone numbers, home addresses, social security numbers and similarly personally identifying information for parties and thirdparty witnesses, any information subject to N.Y. Civil Rights Law § 50 or 51, or any other information deemed private by a Court of competent jurisdiction to include the tort of publication of private facts. +- 4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case. +- 5. CONFIDENTIAL documents, materials, and/or information (collectively "CONFIDENTIAL INFORMATION") shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to: + - a. attorneys actively working on this case; + - b. persons regularly employed or associated with the attorneys actively working on this case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case; + - c. the parties; + +- d. expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case; +- e. the Court and its employees ("Court Personnel") in this case; +- f. stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action; +- g. deponents, witnesses, or potential witnesses; and +- h. other persons by written agreement of the parties. +- 6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person listed above (other than counsel, persons employed by counsel, Court Personnel and stenographic reporters), counsel shall provide such person with a copy of this Protective Order and obtain from such person a written acknowledgment stating that he or she has read this Protective Order and agrees to be bound by its provisions. All such acknowledgments shall be retained by counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated by opposing counsel. +- 7. Documents are designated as CONFIDENTIAL by placing or affixing on them (in a manner that will not interfere with their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by number. To the extent practical, the respective legend shall be placed near the number. + +- 8. Only the person producing the CONFIDENTIAL INFORMATION or a person who has a right to have such producing party keep their information confidential, may designate it as "CONFIDENTIAL." Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an unrepresented person or an attorney for the designating party, that there is a valid and good faith basis for such designation, made at the time of disclosure or production to the receiving party, and that disclosure of such information to persons other than those permitted access to such material would cause a privacy harm to the designating party. +- 9. Whenever a deposition involves the disclosure of CONFIDENTIAL INFORMATION, the deposition or portions thereof shall be designated as CONFIDENTIAL and shall be subject to the provisions of this Protective Order. Such designation shall be made on the record during the deposition whenever possible, but a party may designate portions of depositions as CONFIDENTIAL after transcription, provided written notice of the designation is promptly given to all counsel of record within thirty (30) days after notice by the court reporter of the completion of the transcript, and until the expiration of such thirty (30) days after notice by the court reporter of the completion of the transcript, no party or counsel for any such party may share the contents of the deposition outside the limitations of this Protective Order. + +- 10. Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. +- 11. A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the disputed information. The written notice shall identify the information to which the objection is made. If the parties cannot resolve the objection within ten (10) business days after the time the notice is received, it shall be the obligation of the party designating the information as CONFIDENTIAL to file an appropriate motion requesting that the Court determine whether the disputed information should be subject to the terms of this Protective Order. If such a motion is timely filed, the disputed information shall be treated as CONFIDENTIAL under the terms of this Protective Order until the Court rules on the motion. If the designating party fails to file such a motion within the prescribed time, the disputed information shall lose its designation as CONFIDENTIAL and shall not thereafter be treated as CONFIDENTIAL in accordance with this Protective Order. In connection with a motion filed under this provision, the party designating the information as CONFIDENTIAL shall bear the burden of establishing that good cause exists for the disputed information to be treated as CONFIDENTIAL. + +12. At the conclusion of this case, unless other arrangements are agreed upon, each document and all hard copies thereof which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL hardcopy documents or electronic files. Where the parties agree to destroy CONFIDENTIAL hard copy documents and electronic tiles, the destroying party shall provide all parties with an affidavit confirming the destruction. As to all electronic non-file copies such as emails, the party in receipt of the CONFIDENTIAL document will submit an affidavit attesting that they will hold as CONFIDENTIAL all such electronic non-file copies and will not distribute the electronic copies absent an Order of a Court of competent jurisdiction. For purposes of this Protective Order, an Order of the Court does not include a subpoena. + +13. In the event that any party who has maintained possession of electronic copies of information designated CONFIDENTIAL by another person receives a subpoena for the affected materials, the party-in-possession shall respond that the materials are not disclosable absent an Order of the Court. + +13,14. This Protective Order shall have no force and effect on the use of any CONFIDENTIAL INFORMATION at trial in this matter. + +44715. 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b/marker2/court-jane-doe-43/EFTA02820530/EFTA02820530.md new file mode 100644 index 0000000000000000000000000000000000000000..bacddfa52d07c66e0e036d1ea6d01f9ad4df2516 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820530/EFTA02820530.md @@ -0,0 +1,57 @@ +## United States District Court Southern District Of New York + +X + +Plaintiff, + +N . + +Jeffre E stein, Ghislaine Maxwell, Lesley Groff and Natalya + +Defendants. + +X + +No. 17 Civ. 0616 (JGK) + +## PROTECTIVE ORDER + +Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information in this case, IT IS + +## ORDERED: + +- 1. This Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. +- 2. As used in this Protective Order, "document" is defined as provided in FED.R.Civ.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term. + +- 3. Information designated "CONFIDENTIAL" shall be information that is confidential and implicates common law and statutory privacy interests, including information reflecting medical or psychological conditions, medical or psychological treatment, prescriptions for controlled substances, non-public personal financial information, sexual activity or sexual contact, education records, email addresses, telephone numbers, home addresses, social security numbers and similarly personally identifying information for parties and thirdparty witnesses, any information subject to N.Y. Civil Rights Law § 50 or 51, or any other information deemed private by a Court of competent jurisdiction to include the tort of publication of private facts. +- 4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case. +- 5. CONFIDENTIAL documents, materials, and/or information (collectively "CONFIDENTIAL INFORMATION") shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to: + - a. attorneys actively working on this case; + - b. persons regularly employed or associated with the attorneys actively working on this case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case; + - c. the parties; + +- d. expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case; +- e. the Court and its employees ("Court Personnel") in this case; +- f. stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action; +- g. deponents, witnesses, or potential witnesses; and +- h. other persons by written agreement of the parties. +- 6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person listed above (other than counsel, persons employed by counsel, Court Personnel and stenographic reporters), counsel shall provide such person with a copy of this Protective Order and obtain from such person a written acknowledgment stating that he or she has read this Protective Order and agrees to be bound by its provisions. All such acknowledgments shall be retained by counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated by opposing counsel. +- 7. Documents are designated as CONFIDENTIAL by placing or affixing on them (in a manner that will not interfere with their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by number. To the extent practical, the respective legend shall be placed near the number. + +- 8. Only the person producing the CONFIDENTIAL INFORMATION or a person who has a right to have such producing party keep their information confidential, may designate it as "CONFIDENTIAL." Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an unrepresented person or an attorney for the designating party, that there is a valid and good faith basis for such designation, made at the time of disclosure or production to the receiving party, and that disclosure of such information to persons other than those permitted access to such material would cause a privacy harm to the designating party. +- 9. Whenever a deposition involves the disclosure of CONFIDENTIAL INFORMATION, the deposition or portions thereof shall be designated as CONFIDENTIAL and shall be subject to the provisions of this Protective Order. Such designation shall be made on the record during the deposition whenever possible, but a party may designate portions of depositions as CONFIDENTIAL after transcription, provided written notice of the designation is promptly given to all counsel of record within thirty (30) days after notice by the court reporter of the completion of the transcript, and until the expiration of such thirty (30) days after notice by the court reporter of the completion of the transcript, no party or counsel for any such party may share the contents of the deposition outside the limitations of this Protective Order. + +- 10. Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. +- 11. A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the disputed information. The written notice shall identify the information to which the objection is made. If the parties cannot resolve the objection within ten (10) business days after the time the notice is received, it shall be the obligation of the party designating the information as CONFIDENTIAL to file an appropriate motion requesting that the Court determine whether the disputed information should be subject to the terms of this Protective Order. If such a motion is timely filed, the disputed information shall be treated as CONFIDENTIAL under the terms of this Protective Order until the Court rules on the motion. If the designating party fails to file such a motion within the prescribed time, the disputed information shall lose its designation as CONFIDENTIAL and shall not thereafter be treated as CONFIDENTIAL in accordance with this Protective Order. In connection with a motion filed under this provision, the party designating the information as CONFIDENTIAL shall bear the burden of establishing that good cause exists for the disputed information to be treated as CONFIDENTIAL. + +12. At the conclusion of this case, unless other arrangements are agreed upon, each document and all hard copies thereof which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL hardcopy documents or electronic files. Where the parties agree to destroy CONFIDENTIAL hard copy documents and electronic files, the destroying party shall provide all parties with an affidavit confirming the destruction. As to all electronic non-file copies such as emails, the party in receipt of the CONFIDENTIAL document will submit an affidavit attesting that they will hold as CONFIDENTIAL all such electronic non-file copies and will not distribute the electronic copies absent an Order of a Court of competent jurisdiction. For purposes of this Protective Order, an Order of the Court does not include a subpoena. + +13. In the event that any party who has maintained possession of electronic copies of information designated CONFIDENTIAL by another person receives a subpoena for the affected materials, the party-in-possession shall respond that the materials are not disclosable absent an Order of the Court. + +13,14. This Protective Order shall have no force and effect on the use of any CONFIDENTIAL INFORMATION at trial in this matter. + +44 This Protective Order may be modified by the Court at any time for good cause shown following notice to all parties and an opportunity for them to be heard. + +BY THE COURT + +UNITED STATES DISTRICT JUDGE \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820530/EFTA02820530.metadata.json b/marker2/court-jane-doe-43/EFTA02820530/EFTA02820530.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..32c517dabd6741288822ab7e0e55e3b2858c9c0d --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820530/EFTA02820530.metadata.json @@ -0,0 +1,360 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820530.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": 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"previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820530" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820537/EFTA02820537.md b/marker2/court-jane-doe-43/EFTA02820537/EFTA02820537.md new file mode 100644 index 0000000000000000000000000000000000000000..0a4703fcdb08fbf57e8fd4a938076120a5eebf5f --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820537/EFTA02820537.md @@ -0,0 +1,91 @@ +From: Paul Cassell [mailto:cassellp@law.utah.edu] + +Sent: Friday, November 16, 2018 11:55 AM + +To: Laur r; 'Sigrid McCawley'; Scott J. Link; brad@epllc.com; Stan Pottinger; Meredith + +'Brittany (brittany@egasa= Jeff Pagliuca + +Subject: RE: Protective Order -proposed paragraph 3 + +Dear Laura, + +We have received your proposed paragraph 3 in the protective order, which would include the following: + +Information designated "CONFIDENTIAL" shall be information that is confidential and implicates common law and statutory privacy interests, including information reflecting medical or psychological conditions, medical or psychological treatment, prescriptions for controlled substances, non-public personal financial information, sexual activity or sexual contact, education records, email addresses, telephone numbers, home addresses, social security numbers and similarly personally identifying information for parties and third-party witnesses, any information subject to N.Y. Civil Rights Law § 50 or 51, or any other information deemed private by a Court of competent jurisdiction to include the tort of publication of private facts. + +We propose a more precise paragraph 3 for the protective order, as follows: + +Information designated "CONFIDENTIAL" shall be information that is confidential whose public release would violate common law and statutory privacy interests, including information describing medical or psychological conditions, details of medical or psychological treatment, prescriptions for controlled substances, non-public personal financial information, the details of sexual activity or sexual contact, education records, email addresses, telephone numbers, home addresses, social security numbers and similar personal identifying information for parties and third-party witnesses, and copyrighted or trademarked materials. + +We believe that your proposed protective order would sweep in a considerable amount of material that should not be made confidential. For example, your protective order covers information "reflecting ... sexual activity or contact." Given that this case involves sexual trafficking, a great deal of material would be covered by this language. + +Please let us know if our proposed alternative is acceptable to you. If not, it seems we should present our varying formulations to the judge. + +Paul Cassell for + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law and University Distinguished Professor of Law Quinney College of Law at the University of Utah 383 S. University St., Salt Lake City, UT 84112-0730 (801) 585-5202 (phone) (801) 585-2750 (fax) rasselloPlaw iitah edli + +You can access my publications on httolissrn com/author=30160 + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Any views he expresses in this email are his own. + +From: Laura Menninger + +Sent: Thursday, November 15, 2018 8:43 AM + +To: 'Sigrid McCawley' ; Scott J. Link ; brad@epllc.com; Paul Cassell ; Stan Pottinger ; Meredith ; 'Brittany (brittany@epllc.com)' ; Jeff Pagliuca + +Subject: RE: Protective Order + +Hi Sigrid — + +Attached please find a draft protective order. + +Consistent with the judge's comments on the record, I have removed the language from the preamble, proposed at paragraph 3 a list of categories of confidential information, adopted your version of paragraph 8, and tried to capture her ruling regarding paragraphs 12-13. I did add one other small change to paragraph 8 for your consideration, to address the issue of a non-represented person being able to designate their information confidential. + +Thank you, Laura + +![](_page_1_Picture_13.jpeg) + +Laura A. Menninger Haddon, and S P.C. 150 East 10th Avenue Denver, Colorado 80203 Main 303.831.7364 FX 303.832.2628 Imenninger@hmflaw.com www.hmflaw.com + +CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous email messages attached to it may contain information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended + +recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you. + +From: Sigrid McCawley (mailto:smccawlev(ftsfllo.com] + +Sent: Thursday, November 15, 2018 7:59 AM + +To: Laura Mennin J. Link; ; 'Paul Cassell (racsellnOlaw torah erlo/y; Stan + +h • 'Brittany Pottinger; Meredith(hrittanveollc corny + +Subject: Protective r er + +Hello Laura — it is our understanding that the proposed protective order is due tomorrow. Can you please send us a copy of the categories you are proposing for paragraph 3 about the categories that will be considered as confidential information so that the parties can submit a revised proposed protective order per the court's ruling as set forth below. + +ORDER granting [163] Letter Motion for Discovery. In addition to the rulings made on the record during the November 7, 2018 conference, the Court adopts the Paragraph 8 from the Plaintiffs proposed Protective Order. (ECF No. 166-1). The parties shall file a revised proposed Protective Order no later than November 16, 2018. + +Sigrid McCawley + +Partner + +BOIES SCHILLER FLEXNER LLP + +401 E. Las Olas Blvd. Suite 1200 + +Fort Lauderdale, FL, 33301 + +(t) +1 954 377 4223 + +(m)+1 954 770 5377 + +smer-awlev@bstllo corn + +www.bsfllo.com + +The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that. among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination. distnbution. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. 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Magistrate Sarah Netbum Thurgood Marshall Courthouse Southern District of New York 40 Foley Square, Room 430 New York, New York 10007 + +Re: v. Jeffrey Epstein, et at, 17-cv-00616 (JGK) + +Dear Judge Netburn: + +Haddon. and v c Laura A. Menninger + +150 East 10th Avenue Denver. Colorado 80203 PH 303.831.7364 DC 303.832.2628 www.hmflaw.com Imenninger@hmflaw.com + +Pursuant to the Court's Order of November 8, 2016 (Doc. # 163) and comments made on the record on November 7, 2016, defendant Ghislaine Maxwell submits the following revised proposed Protective Order for the Court's consideration. The other Defendants join in Ms. Maxwell's request that the Court adopt this proposed Protective Order. Unfortunately, plaintiff disputes the proposed paragraph 3 definition of "confidential information" as reflected in the attached email. + +Ms. Maxwell's proposed Protective Order reflects the Court's Order with regard to the preamble, paragraph 8, and paragraphs 12 and 13. Ms. Maxwell's proposed paragraph 3 reads as follows: + +3. Information designated "CONFIDENTIAL" shall be information that is confidential and implicates common law and statutory privacy interests, including information reflecting medical or psychological conditions, medical or psychological treatment, prescriptions for controlled substances, non-public personal financial information, sexual activity or sexual contact, education records, email addresses, telephone numbers, home addresses, social security numbers and similarly personally identifying information for parties and third-party witnesses, any information subject to N.Y. Civil Rights Law § 50 or 51, or any other information deemed private by a Court of competent jurisdiction to include the tort of publication of private facts. + +Ms. Maxwell believes that the above list adequately captures the type of confidential information likely to be sought (or which already has been sought) from parties and third-party witnesses. The inclusion of the specific statutory and common law rights potentially implicated (N.Y. Civil Rights Law § 50 and 51 and the common law tort of publication of private facts) provides meaningful guidance to the parties and the Court in the event of a dispute concerning what information should or should not be deemed Confidential. + +Hon. Sarah Netburn November 16, 2018 Page 2 + +Plaintiff's proposal eliminates the specific statutory and common law rights at issue and adds the phrase "details of any" sexual activity or contact, as well as "copyrighted or trademarked materials." Adding the phrase "details of sexual activity or conduct does not provide meaningful guidance. Does that mean a general discussion of sexual activity or conduct would not be Confidential? How are the parties to know what is a "detail of sexual activity or conduct versus non-detailed activity or conduct? The phrase muddies the definition more than clarifies. It is frankly hard enough for a lawyer to try to argue such a distinction; when unrepresented third-party witnesses are deposed in this matter and asked about sensitive personal sexual conduct or activity, they should be afforded the privacy of a Confidential designation over their disclosures without risk of towing the line between a detailed or a general description. + +Moreover, the statutory and common law rights at issue are easily measured by the cases construing those rights. The N.Y. Civil Rights Law § 50-b, for example, makes confidential the identity of any victim of a sex offense. It is frankly puzzling to me that Plaintiff does not want that information held Confidential. Likewise, the tort of publication of a private fact enjoys a substantial body of case law informing what types of facts are "private," the publication of which gives rise to a civil cause of action. Should the parties dispute whether a fact falls within the ambit of privacy, case law can be used to support or refute any such designation. + +Plaintiff argues that the definition "would sweep in a considerable amount of material that should not be made confidential," given that the topic of this case involves "sexual trafficking." In fact, it is because the case involves sexual trafficking that Plaintiff argues she should be permitted to engage in far-ranging inquiries regarding sexual activities, habits and conduct, including (most especially) consensual sexual conduct amongst adults. Plaintiff has yet to articulate why they need to make public any such Confidential information for a case-related, versus a media-related, purpose. + +Ms. Maxwell also made one small addition to paragraph 8, as indicated by the redline, to allow non-represented third-party witnesses the ability to designate materials Confidential. + +For the foregoing reasons, Ms. Maxwell respectfully requests that the Court enter the attached proposed Protective Order. + +Respectfully submitted, + +HADDON, AND P.C. + +/s/ Laura A. Menninger Laura A. 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Jeffrey Epstein, et al. Case No.: 17-cv-00616-JGK-SN + +Dear Magistrate Judge Netbum: + +The parties have worked together to resolve the issues of the Protective Order and to incorporate your honor's ruling. The only point of contention is the scope of the language of Paragraph 3 of the Protective Order. + +Ms. Maxwell's proposed paragraph 3 in the protective order would include the following: + +Information designated "CONFIDENTIAL" shall be information that is confidential and implicates common law and statutory privacy interests, including information reflecting medical or psychological conditions, medical or psychological treatment, prescriptions for controlled substances, non-public personal financial information, sexual activity or sexual contact, education records, email addresses, telephone numbers, home addresses, social security numbers and similarly personally identifying information for parties and third-party witnesses, any information subject to N.Y. Civil Rights Law § 50 or 51, or any other information deemed private by a Court of competent jurisdiction to include the tort of publication of private facts. + +We propose a more precise paragraph 3 for the protective order, as follows: + +Information designated "CONFIDENTIAL" shall be information that is confidential whose public release would violate common law and statutory privacy interests, including information describing medical or psychological conditions, details of medical or psychological treatment, prescriptions for controlled + +![](_page_1_Picture_1.jpeg) + +Honorable Magistrate Judge Sarah Netburn November 16, 2018 Page 2 + +> substances, non-public personal financial information, the details of sexual activity or sexual contact, education records, email addresses, telephone numbers, home addresses, social security numbers and similar personal identifying information for parties and third-party witnesses, and copyrighted or trademarked materials. + +Ms. Maxwell's proposed protective order would sweep in a considerable amount of material that should not be made confidential. For example, Ms. Maxwell proposed language would cover information "reflecting ... sexual activity or contact." Given that this case involves sexual trafficking, a great deal of material would be covered by this language. + +Accordingly, we request that paragraph 3 of the protective order read as we propose above. As a final note, Plaintiff would be remiss not to address Defendant's repeated, unnecessary statements about "media". Plaintiff's suggested changes to the Protective Order are tailored to address confidentiality concerns while not overburdening the Court with multiple sealed filings. + +Sincerely, + +/s/ Sigrid S. McCawley Sigrid S. 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This Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. +- 2. As used in this Protective Order, "document" is defined as provided in FED.R.CIV.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term. + +- 3. Information designated "CONFIDENTIAL" shall be information whose public release would violate common law and statutory privacy interests, including information reflecting medical or psychological conditions, medical or psychological treatment, prescriptions for controlled substances, non-public personal financial information, sexual activity or sexual contact, education records, email addresses, telephone numbers, home addresses, social security numbers and similarly personally identifying information for parties and thirdparty witnesses, any information subject to N.Y. Civil Rights Law § 50 or 51, or any other information deemed private by a Court of competent jurisdiction to include the tort of publication of private facts. +- 4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case. +- 5. CONFIDENTIAL documents, materials, and/or information (collectively "CONFIDENTIAL INFORMATION") shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to: + - a. attorneys actively working on this case; + - b. persons regularly employed or associated with the attorneys actively working on this case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case; + - c. the parties; + +- d. expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case; +- e. the Court and its employees ("Court Personnel") in this case; +- f. stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action; +- g. deponents, witnesses, or potential witnesses; and +- h. other persons by written agreement of the parties. +- 6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person listed above (other than counsel, persons employed by counsel, Court Personnel and stenographic reporters), counsel shall provide such person with a copy of this Protective Order and obtain from such person a written acknowledgment stating that he or she has read this Protective Order and agrees to be bound by its provisions. All such acknowledgments shall be retained by counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated by opposing counsel. +- 7. Documents are designated as CONFIDENTIAL by placing or affixing on them (in a manner that will not interfere with their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by number. To the extent practical, the respective legend shall be placed near the number. + +- 8. Only the person producing the CONFIDENTIAL INFORMATION or a person who has a right to have such producing party keep their information confidential, may designate it as "CONFIDENTIAL." Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an unrepresented person or an attorney for the designating party, that there is a valid and good faith basis for such designation, made at the time of disclosure or production to the receiving party, and that disclosure of such information to persons other than those permitted access to such material would cause a privacy harm to the designating party. +- 9. Whenever a deposition involves the disclosure of CONFIDENTIAL INFORMATION, the deposition or portions thereof shall be designated as CONFIDENTIAL and shall be subject to the provisions of this Protective Order. Such designation shall be made on the record during the deposition whenever possible, but a party may designate portions of depositions as CONFIDENTIAL after transcription, provided written notice of the designation is promptly given to all counsel of record within thirty (30) days after notice by the court reporter of the completion of the transcript, and until the expiration of such thirty (30) days after notice by the court reporter of the completion of the transcript, no party or counsel for any such party may share the contents of the deposition outside the limitations of this Protective Order. + +- 10. Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. +- 11. A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the disputed information. The written notice shall identify the information to which the objection is made. If the parties cannot resolve the objection within ten (10) business days after the time the notice is received, it shall be the obligation of the party designating the information as CONFIDENTIAL to file an appropriate motion requesting that the Court determine whether the disputed information should be subject to the terms of this Protective Order. If such a motion is timely filed, the disputed information shall be treated as CONFIDENTIAL under the terms of this Protective Order until the Court rules on the motion. If the designating party fails to file such a motion within the prescribed time, the disputed information shall lose its designation as CONFIDENTIAL and shall not thereafter be treated as CONFIDENTIAL in accordance with this Protective Order. In connection with a motion filed under this provision, the party designating the information as CONFIDENTIAL shall bear the burden of establishing that good cause exists for the disputed information to be treated as CONFIDENTIAL. + +- 12. At the conclusion of this case, unless other arrangements are agreed upon, each document and all hard copies thereof which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL hardcopy documents or electronic files. Where the parties agree to destroy CONFIDENTIAL hard copy documents and electronic files, the destroying party shall provide all parties with an affidavit confirming the destruction. As to all electronic non-file copies such as emails, the party in receipt of the CONFIDENTIAL document will submit an affidavit attesting that they will hold as CONFIDENTIAL all such electronic non-file copies and will not distribute the electronic copies absent an Order of a Court of competent jurisdiction. For purposes of this Protective Order, an Order of the Court does not include a subpoena. +- 13. In the event that any party who has maintained possession of electronic copies of information designated CONFIDENTIAL by another person receives a subpoena for the affected materials, the party-in-possession shall respond that the materials are not disclosable absent an Order of the Court. +- 14. This Protective Order shall have no force and effect on the use of any CONFIDENTIAL INFORMATION at trial in this matter. +- 15. 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Magistrate Sarah Netbum Thurgood Marshall Courthouse Southern District of New York 40 Foley Square, Room 430 New York, New York 10007 + +Re: v. Jeffrey Epstein, et al., 17-cv-00616 (JGK) + +Dear Judge Netburn: + +Haddon. and S P.0 Laura A. Menninger + +150 Eost 10th Avenue Denver. Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflow.com Imenningerahmflow.com + +Pursuant to the Court's Order of November 21, 2018 (Doc. # 173), defendant Ghislaine Maxwell submits the following revised proposed Protective Order for the Court's consideration. + +Respectfully submitted, + +HADDON, AND P.C. + +/s/ Laura A. Menninger + +Laura A. 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McCAWLEY - and - + +17 PAUL G. CASSELL Attorney for Plaintiff + +18 LINK & ROCKENBACH, P.C. + +19 Jeffrey Epstein, Lesley Groff and + +20 BY: SCOTT J. LINK + +21 HADDON, AND P.C. + +22 Haddon, & , P.C. + +23 + +24 + +25 + +Plaintiff, New York, N.Y. + +17 Civ. 0616(JGK) + +HON. SARAH NETBURN, + +Attorneys for Defendants + +Attorneys for Defendant Ghislain Maxwell + +BY: LAURA A. MENNINGER + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +(In ; speakerphone call initiated) + +THE COURT: Good afternoon. This is Judge Netburn. I nave you here with my law clerk and with a court reporter. + +What I'm going to ask is that each party state its appearance for the record, and then if I can request that whenever anybody speaks, that that person identify themself again so that the court reporter can properly attribute your comments to the correct person. And then last housekeeping matter is that when I do these telephone conference, I do them as a courtesy to the parties. Obviously, you can't read body language over the phone, so please be considerate of one another and do your very best not to speak over somebody who is speaking. + +So, who is here on behalf of the plaintiff? + +MS. McCAWLEY: Good afternoon, your Honor. This is Sigrid McCawley, from the law firm of Boies, Schiller & Flexner, and I represent the plaintiff , and I have on the line with me as well Paul Cassell, who is our co-counsel who also represents plaintiff, + +THE COURT: Thank you. + +MR. CASSELL: Good afternoon, your Honor. + +THE COURT: Good afternoon. + +And on behalf of Mr. Epstein and others? + +MR. LINK: Good afternoon, your Honor. This is Scott Link on behalf of defendants Epstein, and Groff, and we + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +really appreciate your time this afternoon. Thank you. + +MS. MENNINGER: Good afternoon, your Honor. Laura Menninger on behalf of defendant Ghislain Maxwell. + +THE COURT: Thank you. + +All right. So I have a series of letters from the parties regarding the dispute over the confidentiality order. My understanding is that the parties agree in principle to a confidentiality order but we have some disputes over its scope. + +Having reviewed the two versions that were filed yesterday, I believe the primary disputes are on paragraph 3, where the definition of what is confidential is being negotiated, and then with respect to paragraph 8, about who is the qualified designating party. And then in the plaintiff's proposal there is a paragraph 13, regarding what to do with respect to electronic information that is sought by subpoena from a nonparty. + +Are those the three areas in dispute at this point? + +MS. MENNINGER: Your Honor, this is Laura Menninger for Ms. Maxwell. + +There also is a dispute in paragraph 12 that relates to the paragraph 13, that is whether electronic copies could be -- after the conclusion of the case. + +THE COURT: Sorry. You cut out for a minute. Whether electronic copies? + +MS. MENNINGER: Could be maintained after the + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +conclusion of the case. + +THE COURT: OK. I see what you are referring to. + +All right. So let's begin with paragraph 3, which is the definition of "confidential." And as I understand it, defendant Maxwell seeks a definition that would encompass information that is, quote, confidential, and implicates common law and statutory privacy interests. Whereas the designation from the plaintiff is, in my opinion, more broad, which just requires a good faith basis to believe that the material is entitled to confidential treatment. + +So the plaintiff here seems to be advocating for a more broad definition of confidentiality. I think the problem with that is should there be a dispute that I need to resolve as to whether something is appropriate or not, I think the way it is written in paragraph 3 would require me to evaluate whether or not the designating party had a good faith basis and potentially even their own subjective view. And to the extent there is an objective test that is implicit here, I'm not quite sure what I would be weighing that against. So I'm not -- I'm a little concerned that paragraph 3 is so broad. + +That said, I think -- you know, I guess I'm curious to hear what the nature of the conversations have been on this particular topic to get a sense of where the real concerns lie. + +MS. McCAWLEY: Your Honor, this is Sigrid McCawley for the plaintiff. If I could just address that briefly? + +4 5 6 7 8 9 10 11 12 13 14 The one -- with respect to paragraph 3, the one thing that is also different between the version that we proposed and the version that Ms. Maxwell proposed which relates to paragraph 3 is in the beginning, the opening paragraph of Ms. Maxwell's protective order, you will see additional language that is not in our protective order, and that is the sentence that says, "Upon" -- at the very beginning of the protective order, "Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information or information which will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in this case, it is so ordered." That language is not included in our introductory paragraph. + +15 16 17 18 19 20 21 We have in our proposal order, "Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information in this case, it is so ordered," because in our view that language allows the defendants to mark in a broad manner information as confidential that may not have -- they may not have a good faith basis for asserting confidentiality. + +22 THE COURT: Can we pull back the lens for a minute? + +23 24 What are the types of documents that we are talking about here that the parties have concern over? + +25 MS. McCAWLEY: This is Sigrid McCawley again for the + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +plaintiff. + +Your Honor, we started this conversation by in this case not proposing a protective order; it is the defendants who wanted the protective order. We agreed to it in good faith in order to try to move discovery along in this case. + +My understanding is the types of -- you know, I see this as a sexual trafficking case, and the types of information that will be exchanged may have information of a sexual nature. However, unlike prior cases that we have had that have dealt with minors, the plaintiff in this case was not a minor at the time she was trafficked. So we were -- we believe that we did not need a protective order in this case as an initial matter. The defendants would like a protective order in this matter. + +THE COURT: So maybe, Ms. Menninger, you can tell me what it is that you believe you are -- what is motivating you here? What are you worried about producing that you want to keep confidential? + +MS. MENNINGER: Your Honor, I believe that the majority of the concerns will be related to discussions during depositions about sexual activities. Plaintiff has alleged not only that my client ran a sex trafficking organization but she claims also that she was directed by my client and the Epstein defendants to have sex with third parties, including Alan Dershowitz, for example. And so to the extent my client or Mr. Dershowitz or anyone else is going to be asked about their + +4 5 6 7 8 private sexual activity, I believe that would implicate their privacy rights for the reasons that Judge Sweet articulated in the opinion that I had referenced in my moving letter. He analyzed it largely on the basis of sexual activity -- or sexual conduct being encompassed within a right of privacy -- a broad right of privacy and that people who will be in pretrial litigation have a right of some type around their private affairs, to include sexual activity. + +9 10 11 12 13 I will say that plaintiffs have requested things like tax returns. They've requested credit card statements. They've requested photographs. They requested all kinds of materials relating to my client's personal life. The requests range from the years 1997 through today. + +14 15 16 17 18 19 20 21 22 23 So to sort of -- I think in my view there is a mechanism within the protective order that should the other parties disagree with the designation of confidentiality, to raise that concern, and then if the parties still can't agree, to bring it to the Court's attention. I think, in my view, that's the more cost-effective and efficient way to go about this rather than a third party who get involved or a witness who is called to testify, having to raise it individually themselves in a motion to quash or a motion for a protective order. + +24 25 I think it is not just documents that we're talking about but based on my experience in the v. Maxwell + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +matter, it largely came up during the course of deposition testimony. There were also medical records that were being sought, psychiatric records being sought and I anticipate that would occur in this case as well. + +THE COURT: Make sure that everybody is speaking as slowly and as clearly as possible so that the court reporter can be sure to get everybody's statement. + +I guess my concern here is -- I think that this goes for both paragraphs, both paragraph 3's, that when the dispute comes up, I need to have a standard against which I can measure an application. And so, in my opinion, it is more effective if we can have some more detail. And so if the parties are prepared to agree to deem confidential, for instance, you know, information that relates to, you know, sexual conduct or sexual activity, you know, information that discloses personal identifying information, which would cover tax returns, information that discloses medical records, you know, and then, if necessary, there can be some sort of a catchall, but at least then I think that will save disputes in the first instance, and if there are disputes, it will give me some sense of what is intended here. + +(Pause) + +MS. McCAWLEY: Your Honor, this is Sigrid McCawley for the plaintiff. + +The concern I have with the broadbrush of sexual + +4 5 6 7 8 9 10 11 12 activity is that the case we brought is obviously for violation under the Sexual Trafficking Act, so it would encompass essentially everything that's going to transpire in the case. And while that -- there may be a way to modify that, for example, sexual activity as it relates to minors or something in that regard if we are going to have a witness who was abused by, or allegedly abused by the defendants when they were underage, I will be willing to talk about something like that would cover or protect from that issue. But to have a very broad definition of any sexual activity would -- you know, everything we would be filing would be almost entirely under seal, in my view. + +13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Well, you know, your point is well taken that this is the topic of this case, and as a result, I think very little would be authorized to be filed under seal should it be relevant to an issue that the Court is going to decide. And so my -- you know, right now we're really talking about discovery and exchanging information, and I think it's reasonable for nonparties especially, but even parties, to, you know, to disclose information without a fear that it's going to be passed along to the New York Times. And so, you know, it may ultimately be covered by the press because it may ultimately be tried, or there may be motion practice where all of this is disclosed. But for the purposes of discovery, I'm less sympathetic to the argument that this case is about sexual + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +trafficking and therefore everything needs to be available to the public. + +Is there a way that you think you can narrow the issue to accommodate your concerns? + +MS. MENNINGER: Your Honor, this is Laura Menninger on behalf of Ms. Maxwell. + +I am happy to draft a list of potential topics that I think are encompassed by the subject matter and circulate it. I don't have -- I agree with all of the ones your Honor suggested, and I would like to just take a look back at the discovery requests thus far and see if there are any additional discrete areas along with the language for a catchall that we could use as our measuring stick going forward. + +THE COURT: What is your response to Ms. McCawley's general concern, and, therefore, what if we limited the sexual nature documents to those that concern nonparties? + +MS. MENNINGER: Your Honor, I can only speak from the experience of the last case in which my client was asked by these same counsel about her consensual sexual adult relationships with others, including Mr. Epstein. So I don't think addressing -- we are only talking about minors or nonconsensual activities, those are the only things that are likely to come up. If they are not planning to ask questions about adult consensual relationships, then I probably would have less of a concern. But we actually had a couple rounds of + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +litigation before Judge Sweet in that case over whether my client had to answer questions regarding her adult consensual sexual activities, and ultimately, relying on the protective order, he ordered her to answer those questions. + +So I'm -- I don't think that the distinction about whether it is a case involving alleged trafficking of minors or adults changes what I anticipate may be asked. I could be completely wrong and they don't plan to ask those same kind of questions in this case. + +THE COURT: OK. Why don't I ask you, Ms. Menninger, to send a revised paragraph 3. I think the goal here is to be as specific as possible. And, again, because of the nature of this litigation, I think it's likely that much of the information that you seek to hold confidential for purposes of discovery would ultimately be disclosed certainly at a trial. Obviously, this protective order makes clear of that. + +MS. MENNINGER: Right. + +THE COURT: But even in the context of any motion practice, it may well be that the Court needs to rely on this information in order to render a decision, which would then make that confidential information a judicial document for which the public has a presumptive right of access. OK. + +MS. MENNINGER: All right. Yes, your Honor. I am happy to do that. + +This is Laura Menninger. + +4 (Pause) + +5 6 7 8 9 10 11 -- in the opening paragraph of the protective order that talks about annoyance, embarrassment, or oppression, I think that that should be removed, and so I would adopt the plaintiff's version of the sort of preliminary whereas clause for the protective order. But let's see if we can be more specific in paragraph 3 as to what it is that we are seeking to protect. + +12 OK. Paragraph 8. + +13 14 15 16 17 18 Paragraph 8, as I understand it, has to do with who has the right to designate something as confidential. And in my experience it has always been the producing party who has the obligation and the right to do so, but maybe in this case there are other concerns that I am not focusing on. Who wants to address this in the first instance? + +19 20 MS. McCAWLEY: Your Honor, this is Sigrid McCawley. I am the one who proposed the language for paragraph 8. + +21 22 23 24 25 The concern we had was from other actions -- Ms. Menninger has referenced the action before Judge Sweet, where one party would designate wholescale a nonparty, for example, all of their testimony confidential irrespective of whether the nonparty believes that it should be held + +THE COURT: OK. So let's see what that is. I don't think that the proviso that the defendants have in their -- Sorry. + +4 + +5 MS. McCAWLEY: I'm so sorry. + +6 THE COURT: We will never get a record here. + +7 MS. McCAWLEY: I'm sorry. + +8 9 10 11 12 13 14 So with this paragraph, I proposed to change the language such that only the person that is actually producing the confidential information, the one who owns that confidential information, would be able to designate it as confidential to protect from having a party wholescale designate things as confidential that weren't that individual's confidential information. + +15 16 17 THE COURT: And your example is a nonparty gets deposed and then the defendant says everything in that nonparty's deposition should be confidential? + +18 MS. McCAWLEY: Exactly. + +19 20 21 22 23 24 25 THE COURT: Well, in part I would imagine that that would be -- we would have some limitations based on the revised paragraph 3 that will be more specific about what can and cannot be designated as confidential. And so, you know, I don't think testimony that, you know, one party believes is intended to annoy or to harass is an appropriate designation. But if that nonparty were speaking about something more narrow + +confidential. And so this paragraph, I adjusted it to provide -- + +THE COURT: Sorry. Ms. McCawley, you've got to speak half as fast. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +and more particularized, how would you feel about that designation? + +MS. McCAWLEY: Well, it can certainly be, for example, if that individual provided testimony with respect to something in this matter that they did not want to mark as confidential or, for example, produce photographs of the defendants with them that they did not want marked as confidential, under the old version of this protective order, the defendants could come in and mark it as confidential and the nonparty would have no control over that situation. + +So this is meant to -- in other words, the party who is providing the information, whether it be by subpoena or whether it be a party to this agreement, has the ability to mark their information confidential if they want it to be protected in that manner, but no other person can do that other than the person who is producing the information. + +THE COURT: OK. Ms. Menninger, that's certainly the most traditional way to proceed. What's the reason for not doing it that way? + +(Pause) + +MR. LINK: Your Honor, this Scott Link. Can I be heard on this for just a minute? + +THE COURT: Sure. + +MS. MENNINGER: I'm having some trouble hearing everyone. + +4 MR. LINK: -- topic for one moment? + +5 THE COURT: Yes. + +6 7 8 MR. LINK: So, first, I think it's unfair to expect a third-party witness, some of whom are not represented by lawyers, to have to make the decision about confidentiality. + +9 10 11 12 13 14 15 16 17 18 19 Second, when a third-party witness comes in and gives testimony that relates to potential, for example, sexual activity with one of the defendants, then that defendant should have the right to designate that information as confidential. It's one thing to say that the defendant -- you know, that whoever the third-party witness is doesn't have an interest in maintain confidentiality, but that's really only half of the equation, because the person that they're testifying about may in fact want to keep that particular sexual relationship or consensual relationship from being in The New York Times, like you said. + +20 21 22 23 24 25 So I think it just creates more of an issue for us if we leave it to an unrepresented person to control whether the confidentiality applies, particularly where you're going to give us a definition now in paragraph 3 that should be more limiting in what can be designated. And, frankly, if a party goes too far in the designation, then we'll be back before you, + +MR. LINK: OK. This is Scott Link, your Honor. May I be heard on this -- + +THE COURT: Yes. + +4 Thank you, your Honor. + +5 THE COURT: Thank you. + +6 7 MS. McCAWLEY: Your Honor, this is Sigrid McCawley again. + +8 9 10 11 12 13 14 15 16 17 18 19 20 Just to address Mr. Link's comments in a reply from the plaintiff, exactly what he is saying is what we're trying to prevent, having to come back to you multiple times over something like this. So the party who is, for example, a nonparty witness who brings to a deposition photographs showing that witness with the defendant, those are that nonparty's photographs and they should be able to mark them as confidential and (unintelligible). So choose or not mark them as confidential, it is their material to designate. It shouldn't be that a party to the litigation can then coax that in confidentiality through this order. In other words, it creates more layers of dispute relating to confidentiality than is necessary. + +21 22 23 24 25 THE COURT: I guess one question I have is, you know, what confidence do you have that a lay witness who comes to testify will have any understanding of the concept of confidentiality and any rights that he or she might be able to invoke to keep from the press his or her sexual activity? That + +and obviously you can do whatever you think is appropriate from the attorney's fees and costs and enforce the protective order that you've signed off on. + +is question number one. + +And question number two is, you know, with respect to the comment else may be disclosed. about their made by Mr. Link, which is that, you know, someone implicated in a way that they wish not to be You know, obviously, the nonparty is free to talk own experiences in whatever way they wish outside of the context of the litigation, but in the context of this litigation, if they are called upon to disclose information that might be I'll say confidential to a party, why shouldn't that party be able to protect his or her interests? + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +MS. McCAWLEY: This is Sigrid McCawley again. + +So to address the first point, in this litigation thus far, we've only had obviously a few handful of depositions, and all of the nonparty deponents are represented by counsel. So this is not -- it is a hypothetical that we are posing, of course, but it is not a circumstance that has arisen in this case with respect to any nonparty witnesses. + +On this second point of -- you made the point that they are free to disclose. Obviously, a nonparty is in control of their information if they want to disclose it, and that is why courts typically have the standard that everything is open and public. So we're going against that standard by folding in a situation where a party could designate some other individual's information as being confidential. So, it cuts against what the standard is for federal court disclosures + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +generally, and that individual has the right to disclose that if they so choose. + +THE COURT: OK. All right. I think I'm going to take paragraph 8 under advisement and think a little bit, and I will issue an order later on as to how to proceed on that topic. + +Let's -- + +MS. MENNINGER: Your Honor, this is Laura Menninger again. If I may just quickly, I want to correct one misstatement. + +There were a number of -- there are a number of witnesses in this case who have been implicated by plaintiff and do not have counsel. I think there are something like 80 witnesses who have been endorsed. And certainly if plaintiff counsel believes that they -- each of those people have counsel, they have not shared that information with us. So I do actually believe this is quite a big concern that there will be people involved in the pretrial discovery process who do not have lawyers make the kind of assessment that paragraph 8 suggests they have a lawyer who would make it for them. + +THE COURT: OK. OK. I appreciate that. + +OK. Let's move to paragraph 12 and 13, which I think are connected. + +Paragraph 12, as I understand it, the issue in dispute is with respect to the retention of electronic copies and a representation that they would be not distributed at the + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +conclusion of the litigation. And I take it that the defendants' concern is that that paragraph and paragraph that provision in paragraph 12 implies that electronic documents would be retained, and I presume that what you want is full destruction of those documents. + +You know, in this day and age -- + +MS. MENNINGER: Your Honor, Laura Menninger. + +THE COURT: Yes. + +MS. MENNINGER: That is correct. In the last case we had that provision so that there would be destruction. Obviously, if the case goes to trial, anything that is aired publicly at the trial would not be destroyed. If there are motions practice where documents are legal documents and relied upon by the Court, they enjoy the protections of the matter. But I do -- it is our request that there not be material held indefinitely afterwards if they don't qualify under one of those exceptions (unintelligible) because the pretrial discovery process should not be used for ulterior purposes like gathering material in subsequent media, you know, participation, that shouldn't be the reason why these materials are (unintelligible) for purposes of use at trial or as judicial documents so that the matters can be resolved, as they should be, through the court system. + +MS. McCAWLEY: Your Honor, this is Sigrid McCawley for the plaintiff. + +And I proposed the language in 12, but Ms. Menninger, 4 in response to that language, proposed paragraph 13. So that was what we were negotiating. I want to make clear, 13 is not my language. It was an accommodation with when I proposed 12. + +5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 And the reason why I proposed 12 is really more of a technical reason. It is in my view -- and I have limited IT experience, but in my view, the order that was -- is the prior order that we had talked about makes it -- makes you attest to the fact that you have destroyed all electronic information that has been marked as confidential. And as you know, in this electronic age, what happens is if you are filing, for example, pleadings under seal, those documents get attached as filings. Then they get moved by email to different individuals, circulated in drafts. They get sent to experts. They get moved electronically in a number of ways that in my view is virtually impossible as an attorney to attest that you have destroyed every single electronic -- you've extracted it from other filings, other pdfs, and destroyed every single piece of that confidential information, particularly when there are large-scale confidentiality designations in a case where things are -- the majority or the bulk of the information in the case is designated confidential such that anytime discovery is used in any manner, you would have to track down every single email or electronic version of that document and make sure you have destroyed it. + +4 5 6 7 8 So this is really from my perspective as a practitioner, practically being able to say I have destroyed certifying I have destroyed everything I think is really an impossibility in that regard. So that is why I proposed the language, to attest that you've not destroyed it, you won't destroy it, you will hold on to it, and not do so without a court order, but I think it's virtually impossible to attest that you have been able to destroy it all. + +9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 THE COURT: Well, I think that's a reasonable concern given the technology. And I guess as to paragraph 13, my reaction was -- and I think maybe this is what gave the defendants some pause -- I mean, why can't paragraph 13 simply say that absent a court order, you know, that the party is not going to respond to a subpoena? You know, obviously notify the designating party that a subpoena has been served, but the protective order just prohibits you from responding. And you can tell the party that subpoenas you, sorry, I'm bound by a court order. You know, I can make an application to the Court for permission to respond, but absent a court order, I can't produce these documents. And in that way there will be no -- I think that will be a good protection for the defendants against some production of documents, whether electronic or otherwise, that may be still accessible to the plaintiffs after the litigation is over. + +25 + +MS. McCAWLEY: Yes, your Honor. This is Sigrid + +4 I'm comfortable with that modification or any modification of paragraph 13 in that regard. + +5 6 MS. MENNINGER: This is Laura Menninger on behalf of Ms. Maxwell. + +7 8 9 10 11 12 13 14 15 My only small concern to the paragraph 13 suggestion is just to make sure we all are clear about what a court order means, because in some contexts, in some cases, subpoenas are viewed as court orders, and so I did not want a subpoena to be construed as having the same force and effect as an actual, you know, review and consideration by a judicial officer and then giving rise to a court order. So with the caveat that a court order really means that and it is not a subpoena, I don't have a problem with that aspect of paragraph 13. + +16 17 18 19 20 21 22 23 24 25 Getting back to the issues that Ms. McCawley raised regarding, you know, the difficulty of complying with destroying electronic copies, I think as long as there were a certification that an attempt has been made to destroy electronic copies, recognizing that perhaps not every single one was caught, would then alleviate the defendants' concerns. My concern, I think as the Court understands, is that intentionally holding on to electronic copies and then participating in trying to get a court order to release those copies kind of undercuts the utility of the protective order in + +McCawley again. + +I'm sorry, Laura. + +4 5 6 7 8 9 10 11 12 13 a way that makes -- would parties feel reluctant to thought was going to live potentially make witnesses and provide information which they on forever in a lawyer's file regardless of whether it ultimately became public in a courtroom. And so, you know, I think there could be language maybe better crafted which said you make a good faith effort to destroy the electronic copy, you know, that that would alleviate the practicality concerns raised by Ms. McCawley but also give some comfort to parties or third-party are understandably reluctant to have the limited documents exist forever and also ensure that the witnesses who categories of litigation process is not being for ulterior purposes with regards to the media. + +14 15 16 17 18 19 20 21 22 23 THE COURT: Well, I am -- I think we're on our way to finding a solution. Obviously, a good faith effort, the beauty is in the eye of the beholder. And Ms. McCawley raises the, you know, probable experience of lawyers during the course of the litigation e-mailing documents back and forth. Look at this. What do you think about this? Etc. Etc. And to comply with any good-faith obligation would -- you know, the lawyers need to then, you know, cull through their emails almost like an e-discovery search to find out -- to find documents. That seems a little bit much. + +24 25 You know, maybe the -- you know, as long as they represent that they've destroyed their -- + +4 5 MS. MENNINGER: That is my problem, too. This is Laura Menninger. + +6 I apologize, your Honor. + +7 8 THE COURT: Well, we can try another phone call or we can have people come in. + +9 (Pause) + +10 MS. McCAWLEY: Your Honor, this is Sigrid McCawley. + +11 12 13 14 15 I'm hearing fine. I think it is when -- I think if it is possible, you seem to get louder and a little quieter. I don't know if it is possible to get closer to where the microphone is at all so that Ms. Menninger and Mr. Link can hear better. + +16 17 THE COURT: I'm happy to try. I haven't moved and I'm pretty close. + +18 19 20 21 22 23 24 25 In any event, my concern is about what obligations would be on counsel of all sides, all parties, to sort of go through their email and other electronic file retention to destroy documents. And it seems perfectly reasonable to require a party to, for example, destroy an electronic file, so maybe the file set, but it seems less reasonable to require lawyers at the conclusion of this litigation to search through the thousands of internal emails and identify and delete those + +MR. LINK: This is Scott Link. Maybe it is my phone that is cutting out, but I'm only hearing a few words here and there for the last 20/30 seconds. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +emails that have a document attached to them. That seems burdensome and unnecessary. + +You know, in my experience, and I take it that you all have had litigation experience between each other, but I find that lawyers often overlitigate protective orders for fear of nefarious conduct that very rarely comes to pass. And maybe you all have experience to know that that conduct may arise, but the parties are going to sign this protective order and they're going to agree to be bound by it and to keep in confidence the information that they receive, and they will be held in contempt if they fail to comply. And, you know, I'm not sure that any wordsmithing that we're going to do here with respect to the destruction of electronic documents is going to be that much more powerful than the fact that I will hold the party in contempt if they violate any of the terms of this protective order. + +So I think, you know, requiring a party to destroy their electronic file maybe is reasonable, but I don't think it is reasonable to require them to comb through three years worth of emails to see whether or not there are any attachments that might be of confidential material, and that the party will agree that they won't produce any documents in response to a subpoena after -- you know, absent a court order from a competent jurisdiction. + +It seems to me that should be that should be -- + +4 MS. MENNINGER: Your Honor, this is Laura Menninger, for Ms. Maxwell. + +5 6 7 8 9 10 11 12 13 14 15 16 17 18 I appreciate your comments and I understand where they are coming from. The other reason I had referenced Judge Sweet's opinion in the matter is that in that opinion he talks about plaintiff's counsel supporting the protective order throughout the litigation of that matter and then afterwards, when the Miami Herald had an application to have access to the confidential information, that they reversed position and supported the Miami Herald's application so that the Miami Herald, who I now have been observing by reporter as about her counsel their of yesterday, is writing a story about this - case and has introduced . And have supported their application to have access to the confidential information after the conclusion of the case and after the (unintelligible). + +19 20 21 22 23 24 25 So Judge Sweet ruled that he declined the invitation to do so in that opinion. I think that is while I do think that in most cases parties are concerned about things that never come to pass, in this particular case, I had to -- we have reason to be concerned that even though the protective order says what it says, should the case resolve afterwards, there may be a changed position by plaintiff's + +MS. MENNINGER: Your Honor, this is + +THE COURT: Go ahead. + +counsel. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +MS. McCAWLEY: Your Honor, this is Sigrid McCawley for the plaintiff. + +That isn't accurate and it needs to stand corrected. If you look at the filings that we submitted, the Miami Herald was trying to get access to information under the protective order as well as other third parties. There are two appeals pending. We did not file any of those appeals. They are by other third parties who had access to the information. We said that if they are going to be accessing information, it has to be to all of the information, it cannot be to a selective portion of the confidential information. And that was the position that we took in that litigation. And Judge Sweet did not make any comment that Laura had just stated that he did. Those orders stand for themselves, as we read, by the Court. + +THE COURT: OK. Well, again, I'm not quite sure we can account for all of the potential scenarios that the parties are contemplating or anticipating. I think we can revise paragraphs 12 and 13 to require the destruction of electronic files and that, you know, the commitment to keep in confidence all materials held that are designated confidential and the prohibition against disclosing any confidential materials absent an order from a court signed by a judge. + +I understand that there is a deposition happening tomorrow and that there are documents that are to be turned + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +over today. I'm going to consider paragraph 8. I may not get you my thoughts before the day is over. The documents should be produced immediately, and they should be kept in confidence, and any protective order will apply to those documents. But for time being they are to be kept in confidence, and the deposition should be kept in confidence until the protective order is entered. + +Are there any -- + +MS. MENNINGER: Your Honor, this is Laura Menninger. + +I produced the documents yesterday under the confidentiality agreement. We'll keep it confidential as you just suggested, and I appreciate the comments about the deposition tomorrow. + +THE COURT: OK. So I will turn to this last outstanding issue in the next day or two and give you my thoughts and then ask you to send me a revised protective order sometime next week. + +Anything further from either side? + +MR. LINK: Your Honor, this is Scott Link. Nothing for us, your Honor. Thank you. + +MS. McCAWLEY: That is Sigrid McCawley. + +Thank you, your Honor. We appreciate your time. + +MS. MENNINGER: Thank you, your Honor. This is Laura Menninger. + +THE COURT: All right. Thank you. + + (Adjourned) + +MR. CASSELL: Your Honor, this is Paul Cassell. 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b/marker2/court-jane-doe-43/EFTA02820581/EFTA02820581.md @@ -0,0 +1,27 @@ +## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK + +JANE DOE 43 + +USA / Plaintiff(s) + +Case No.: 17CV616 + +JEFFREY EPSTEIN + +Defendant(s) + +## NOTICE OF FILING OF OFFICIAL TR ANSCR I P I + +CONFERNECE Notice is hereby given that an official transcript of a held on has been filed by the court reporter/transcriber in the above-captioned matter. 1 1 /7/1 8 + +Redaction responsibilities apply to the attorneys of record or pro se parties, even if the person requesting the transcript is a judge or a member of the public or media. + +The parties have seven (7) calendar days from the date of filing of this NOTICE to file with the court any NOTICE OF INTENT TO REQUEST REDACTION of this transcript. A copy of said NOTICE must also be served on the court reporter. If no such NOTICE is filed, the transcript may be made remotely electronically available to the public without redaction after ninety (90) calendar days. + +This process may only be used to redact the following personal data identifiers: Social Security numbers; dates of birth; minors' names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information may proceed by motion. + +I (we) certify that the foregoing is a correct transcript from the record of proceedings in the aboveentitled matter. + +/s VINCENT BOLONGA + +Court Reporter/Transcriber Date \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820581/EFTA02820581.metadata.json b/marker2/court-jane-doe-43/EFTA02820581/EFTA02820581.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..16f1955d476b6260d463802c340c8a1c479a05b3 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820581/EFTA02820581.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820581.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1439, + "elapsed_seconds": 0.84, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE UNITED STATES DISTRICT COURT \nFOR THE SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 154.224, + 67.23 + ], + [ + 418.71282958984375, + 67.23 + ], + [ + 418.71282958984375, + 96.363037109375 + ], + [ + 154.224, + 96.363037109375 + ] + ] + }, + { + "title": "NOTICE OF FILING OF OFFICIAL TR ANSCR I P I", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 168.3, + 307.79888916015625 + ], + [ + 446.148, + 307.79888916015625 + ], + [ + 446.148, + 322.1835632324219 + ], + [ + 168.3, + 322.1835632324219 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 56 + ], + [ + "Line", + 28 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820581" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820582/EFTA02820582.md b/marker2/court-jane-doe-43/EFTA02820582/EFTA02820582.md new file mode 100644 index 0000000000000000000000000000000000000000..7ebc85c32ed0e27c9c582df6925f6b6f86514ce0 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820582/EFTA02820582.md @@ -0,0 +1,58 @@ +## United States District Court Southern District Of New York + +Plaintiff, + +v. + +Jeffre E stein, Ghislaine Maxwell, Lesley Groff and Natalya + +Defendants. + +X + +X + +DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 11/29/2018 + +No. 17 Civ. 0616 (JGK) + +## PROTECTIVE ORDER + +Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information in this case, IT IS + +## ORDERED: + +- I. This Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. +- 2. As used in this Protective Order, "document" is defined as provided in FED.R.CIV.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term. + +- 3. Information designated "CONFIDENTIAL" shall be information whose public release would violate common law and statutory privacy interests, including information reflecting medical or psychological conditions, medical or psychological treatment, prescriptions for controlled substances, non-public personal financial information, sexual activity or sexual contact, education records, email addresses, telephone numbers, home addresses, social security numbers and similarly personally identifying information for parties and thirdparty witnesses, any information subject to N.Y. Civil Rights Law § 50 or 51, or any other information deemed private by a Court of competent jurisdiction to include the tort of publication of private facts. +- 4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case. +- 5. CONFIDENTIAL documents, materials, and/or information (collectively "CONFIDENTIAL INFORMATION") shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to: + - a. attorneys actively working on this case; + - b. persons regularly employed or associated with the attorneys actively working on this case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case; + - c. the parties; + +- d. expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case; +- e. the Court and its employees ("Court Personnel") in this case; +- f. stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action; +- g. deponents, witnesses, or potential witnesses; and +- h. other persons by written agreement of the parties. +- 6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person listed above (other than counsel, persons employed by counsel, Court Personnel and stenographic reporters), counsel shall provide such person with a copy of this Protective Order and obtain from such person a written acknowledgment stating that he or she has read this Protective Order and agrees to be bound by its provisions. All such acknowledgments shall be retained by counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated by opposing counsel. +- 7. Documents are designated as CONFIDENTIAL by placing or affixing on them (in a manner that will not interfere with their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by number. To the extent practical, the respective legend shall be placed near the number. + +- 8. Only the person producing the CONFIDENTIAL INFORMATION or a person who has a right to have such producing party keep their information confidential, may designate it as "CONFIDENTIAL." Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an unrepresented person or an attorney for the designating party, that there is a valid and good faith basis for such designation, made at the time of disclosure or production to the receiving party, and that disclosure of such information to persons other than those permitted access to such material would cause a privacy harm to the designating party. +- 9. Whenever a deposition involves the disclosure of CONFIDENTIAL INFORMATION, the deposition or portions thereof shall be designated as CONFIDENTIAL and shall be subject to the provisions of this Protective Order. Such designation shall be made on the record during the deposition whenever possible, but a party may designate portions of depositions as CONFIDENTIAL after transcription, provided written notice of the designation is promptly given to all counsel of record within thirty (30) days after notice by the court reporter of the completion of the transcript, and until the expiration of such thirty (30) days after notice by the court reporter of the completion of the transcript, no party or counsel for any such party may share the contents of the deposition outside the limitations of this Protective Order. + +- 10. Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. +- 11. A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the disputed information. The written notice shall identify the information to which the objection is made. If the parties cannot resolve the objection within ten (10) business days after the time the notice is received, it shall be the obligation of the party designating the information as CONFIDENTIAL to file an appropriate motion requesting that the Court determine whether the disputed information should be subject to the terms of this Protective Order. If such a motion is timely filed, the disputed information shall be treated as CONFIDENTIAL under the terms of this Protective Order until the Court rules on the motion. If the designating party fails to file such a motion within the prescribed time, the disputed information shall lose its designation as CONFIDENTIAL and shall not thereafter be treated as CONFIDENTIAL in accordance with this Protective Order. In connection with a motion filed under this provision, the party designating the information as CONFIDENTIAL shall bear the burden of establishing that good cause exists for the disputed information to be treated as CONFIDENTIAL. + +- 12. At the conclusion of this case, unless other arrangements are agreed upon, each document and all hard copies thereof which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL hardcopy documents or electronic files. Where the parties agree to destroy CONFIDENTIAL hard copy documents and electronic files, the destroying party shall provide all parties with an affidavit confirming the destruction. As to all electronic non-file copies such as emails, the party in receipt of the CONFIDENTIAL document will submit an affidavit attesting that they will hold as CONFIDENTIAL all such electronic non-file copies and will not distribute the electronic copies absent an Order of a Court of competent jurisdiction. For purposes of this Protective Order, an Order of the Court does not include a subpoena. +- 13. In the event that any party who has maintained possession of electronic copies of information designated CONFIDENTIAL by another person receives a subpoena for the affected materials, the party-in-possession shall respond that the materials are not disclosable absent an Order of the Court. +- 14. This Protective Order shall have no force and effect on the use of any CONFIDENTIAL INFORMATION at trial in this matter. +- 15. 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b/marker2/court-jane-doe-43/EFTA02820588/EFTA02820588.md @@ -0,0 +1,25 @@ +![](_page_0_Picture_1.jpeg) + +Sigrid S. McCawley, Esq. Telephone: (954) 356-0011 Email: smccawley@bstllp.com + +## VIA CM/ECF + +December 11, 2018 + +Honorable Magistrate Judge Sarah Netbum United States District Court Thurgood Marshall Courthouse 40 Foley Square, Rm 430 New York, NY 10007 + +> Re: Jane Doe 43 v. Jeffrey Epstein, et al., Case No • 17-cv-00616- GK-SN — Letter Motion Seeking Extension of Time to File Expert Witness Report + +Dear Judge Netbum, + +We write today to request a short extension of time to the expert witness report deadline in this matter. Presently, under the schedule, any expert report would need to be submitted by December 24, 2018. Plaintiff's experts have been traveling out of the country and have been unavailable and therefore, Plaintiff respectfully requests that it be granted until January 18, 2019 to submit her expert report, with Defendants' rebuttal reports to follow 30 days later. This proposal should not interfere with the fact discovery deadline of January 25, 2019, nor alter the March 15, 2019 trial date. Plaintiff has conferred with the Defendants on this issue and they were not amenable to the relief sought. + +Plaintiff has not asked for any extensions of time in this matter that resulted from its own conduct' and is only seeking this extension as a result of unavoidable conflicts in her expert's schedule. + +Sincerely, + +Sigrid S. McCawley Sigrid S. McCawley + +cc: All Counsel of Record + +1On January 31, 2018, Plaintiff filed a letter motion to Judge Koeltl requesting an extension of to file a consolidated opposition to Defendants' Motion to Dismiss (DE79 & 80) and Defendants' Supplemental Motion to Dismiss (DE 104 & 105) because multiple defendants were filing briefs at different times and the extension was related to that consolidation. \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820588/EFTA02820588.metadata.json b/marker2/court-jane-doe-43/EFTA02820588/EFTA02820588.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d82e0ea5e43ea998b3b71ecc1ed46e4d2ece9534 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820588/EFTA02820588.metadata.json @@ -0,0 +1,96 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820588.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1803, + "elapsed_seconds": 0.82, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA CM/ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 161.19 + ], + [ + 147.3926544189453, + 161.19 + ], + [ + 147.3926544189453, + 175.863037109375 + ], + [ + 68.544, + 175.863037109375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 41 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Footnote", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820588" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820588/_page_0_Picture_1.jpeg b/marker2/court-jane-doe-43/EFTA02820588/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..7bd485c10811647cbdd43be9f999766bebd650bd --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820588/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:54a9d7660eec0e882211a1268af8400748f0eac54fab84ed66ff87b1bf8be3d6 +size 6933 diff --git a/marker2/court-jane-doe-43/EFTA02820589/EFTA02820589.md b/marker2/court-jane-doe-43/EFTA02820589/EFTA02820589.md new file mode 100644 index 0000000000000000000000000000000000000000..60e862f165eb1b5504e4b94706d3a2cf93e66cf3 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820589/EFTA02820589.md @@ -0,0 +1,311 @@ +PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 Telephone: 801-585-5202 cassellp@law.utah.edte + +December 13, 2018 + +### VIA CM/ECF + +Honorable Magistrate Judge Sarah Netbum United States District Court Thurgood Marshall Courthouse 40 Foley Square, Rm 430 New York, NY 10007 + +Re: Jane Doe 43 v. Jeffrey Epstein, et at, Case No.: 17-cv-00616 (MK) — Letter Motion Seeking Pre-Motion Conference + +Dear Judge Netbum, + +We write today to request a pre-motion conference, pursuant to Local Civil Rule 37.2, to seek the Court's guidance as to compelling defendant Maxwell to produce requested documents. + +As the Court will recall, this is a case in which the plaintiff, has alleged that she was sexually trafficked by Jeffrey Epstein and his co-defendants, including defendant Ghislaine Maxwell. Maxwell is the only one of the four defendants who did not invoke her Fifth Amendment right against self-incrimination to refuse to produce documents. But in response to production, Ms. Maxwell produced very little information. requests for + +Following that limited production, counsel for Eguests for production, via email. See Attachment A. Counsel for E. Maxwell then conferred via telephone on November 21, 2018, but were unsuccessful in narrowing many of the substantive disputes. clarified her + +While there are various individual issues about the requests for production, there are several overarching disputes that we think might usefully be discussed in a premotion conference. + +This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah. + +# The Relevant Time Period for Production + +The parties dispute the relevant time period for production. believes that the relevant time period extends for the multiple years during which the sex trafficking organization operated. But Ms. Maxwell has refused to produce for years that organization was in operation, taking the position that the "relevant period" for this case is narrowly confined to just September 2006 through April 2007. + +complaint spans a much broader time period than those eight months. For example, paragraph 14 of the First Amended Complaint ("FAC") alleges that "Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise." And with regard to events following 2007, the First Amended Complaint specifically alleges that (among other things) "In and after May 2007, Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's coverup induded efforts to intimidate witnesses who might provide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done." FAC at 165. + +Judge Koeltl has already recognized the breadth of the allegations in denying a motion to strike a part of the complaint dealing with earlier events. In particular, Judge Koeltl recognized that under Rule 404(b), evidence of trafficking other girls or women lirsex ti trafficking organization could be relevant to showing what happened to + +The portion of the amended complaint subject to the motion to strike provides specific fads in support of the plaintiffs allegations that she was recruited an enticed into performing sex acts with Epstein as part of a larger enterprise to provide Epstein with young females for sex, in which each defendant allegedly played a specific role. The defendants contend that the plaintiff was a younger woman who willingly accepted the blandishments of a wealthy older man. The knowledge and intent of the defendants will plainly be an issue. The paragraphs of the amended complaint that the defendants seek to strike may be evidence of the defendants' knowledge and intent in their dealings with the plaintiff. See Federal Rule of Evidence 404(b). Accordingly, the motion to strike is denied. + +Transcript ("Tr.") of Aug. 7, 2018, hearing at 47-48. + +In light of the breadth complaint - and Judge Koeltl's earlier ruling — Ms. Maxwell should produce documents for a much broader period of time, as indicated in particular requests for production. For example, Request for Production Number 1 requests Maxwell's passport entries from 2000 to 2008. Ms. Maxwell should produce for that entire time period, as that may assist in showing her traveling in connection with sexually trafficking women and girls. + +# Ms. Maxwell's Financial Information + +has sought financial information from Ms. Maxwell, including her tax returns. See, e.g. RFP 16 (requesting tax returns and related information). Ms. Maxwell has declined to produce . Maxwell has taken the position that the request is "harassing" because, in her view, her "financial information is not at issue in this matter and information relating thereto is irrelevant." But numerous financial issues are interwoven into this case. For example, as alleged in 162 of the First Amended Complaint, "Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiffs continued compliance with Epstein's sexual demands ...." Maxwell's financial ability to provide things of value is thus directly at issue. In addition, as alleged in 166 of the First Amended Complaint, "Defendants knowingly benefitted financially and received things of value as a result of coercing and inducing Plaintiff into sexual compliance and otherwise participating in their illegal venture and enterprise." These things of value she received from being a leader in Epstein's sex trafficking organization may very well appear in income or other entries on Ms. Maxwell's tax returns. + +The "thin s of value" addressed in the Complaint tie directly into the statutory provisions that relies upon in filing her complaint. Under 18 U.S.C. § 1591, anyone who "benefits, financially or by receiving anything of value from participation in a [sex trafficking] venture" is potentially covered by the statute (emphasis added). Thus, Ms. Maxwell's receipt (or distribution) of "things of value" may be an element of the cause of action that course, tax returns frequently reflect "things of value." has to prove at trial. Of + +# Employee or Business Records Associated with Jeffrey Epstein + +. Maxwell to produce "[a]ll documents relating to any employee lists or records associated with you, Jeffrey Epstein or any related entity." In addition to raising the question of the relevant time period discussed above, Ms. Maxwell has argued that the term "entity" is unduly broad. has responded by clarifying that "[w]ith regard to 'entity,' an entity associated with Ms. + +Maxwell might be a means for receiving or transmitting 'things of value' that are the subject of this litigation, as specifically discussed in the complaint." See Attachment A. Maxwell still has declined to produce. + +Information in Ms. Maxwell's possession regarding employee or business records associated with Jeffrey Epstein is clearly relevant in a case involving an alleged sex trafficking organization. And the use of such terms as "entity" as appropriate, given that Mr. Epstein has invoked his Fifth Amendment rights rather than explain how the organization was structured. has good reason for believing that business "entities" of various types have been used to conceal the existence of the sex trafficking organization, and Ms. Maxwell should be directed to produce. + +# Information about the Adequacy of the Search + +For many of the requests made by Maxwell has indicated that she has been unable to locate any responsive documents. A significant reason may well be due to Ms. Maxwell's inappropriate limitation of the "relevant period" to just a few months — a subject discussed above. But more broadly, in connection with those responses where documents have not been located (or any otherwise restricted search was done), should be provided a description of Ms. Maxwell's search efforts. + +raised this point with Ms. Maxwell's counsel. She received only this terse response back: "In response to your inquiry about our search efforts: Ms. Maxwell and her legal team conducted searches of her paper files, electronic devices, and cloud-based storage, e.g., internet email services." + +is entitled to a more fulsome description of the efforts that were made to locate responsive documents. Ms. Maxwell should be directed to explain what search terms were used, what data bases and/or email accounts were searched, how they were searched, and what document preservation efforts were made. + +# Conclusion + +The parties conducted a meet and confer conference call on November 21, 2018. Unfortunately, we have been unable to resolve these discovery issues without the Court's guidance. + +Accordingly, Plaintiff respectfully requests a pre-motion discovery conference pursuant to Local Rule 37.2 and Your Honor's Individual Practice Rules. + +Respectfully submitted, + +![]()cc: All Counsel of Record + +From: Paul Cassell Sent: Thursday, November 29, 2018 3:46 PM To: Aneisha Christie Subject: FW: meet and confer on Ms. Maxwell's discovery production + +From: Paul Cassell + +Sent: Wednesday, November 14, 2018 8:07 PM + +To: Laura Menninger + +Cc: Smccawlev@BSFLLP.com; Meredith ; Brad ;Stan Pottinger • Brittany ;Scott Link •Jeff Pag huca ; Meredith + +Subject: RE: meet and confer on Ms. Maxwell's discovery production + +Dear Laura, + +I write in connection with your client's, Ms. Maxwell's, recent discovery responses - specifically her responses to my client's, , requests for production. As you know, last week I called you about setting up a call to discuss all this. Due to your schedule, you proposed that this be handled in writing. According, per your suggestion, this email is in the nature of a meet and confer. If you believe that discussing the matter over the phone would be productive in resolving any of the disputes, please let me know and we can quickly set up a call. + +We note that you have made a "preliminary statement and general objections" to answering the requests for production. We do not believe that any of these preliminary statements justify the refusals to produce specifically discussed below. Also, with regard to objections to definitions and to instructions, again, we do not believe that they justify any of refusals to produce specifically discussed below. + +For several requests, you indicate a concern about a possible privilege log that might extend beyond the requirements of the local civil rule. We are only requesting, where privileged materials exist, a privilege log in compliance with the local rule. + +Also, at several points, you raise concerns about privacy and "harassment." But, as you know, Judge Nesbet has previously entered a protective order in this case, which should obviate concerns about producing financial information and the like. + +Issues surrounding the "relevant period" are discussed in the following paragraphs in connection with Document Request No. I. We believe that the "relevant time period" for all requests (unless otherwise specifically indicated) is September 2006 to the present, as Epstein's sex trafficking enterprise and, later, the coverup associated with the enterprise spans that time period. Accordingly, unless otherwise specifically narrowed, production should be for that entire time period. Indeed, on several requests, we have asked for information earlier than 2006, because of the connection to the Epstein sex trafficking enterprise, which Ms. Maxwell was a part of dating back to around 1999. + +Document Request No. 1: A copy of your passport from 2000-2008. + +You have refused to produce for the entire nine years described above, indicating that, in your view, the "relevant period" for this case is September 2006 through April 2007. However, complaint + +spans a much broader time period. For example, paragraph 14 of the First Amended Complaint ("FAC") alleges that "Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise." And with regard to events following 2007, the First Amended Complaint specifically alleges that (among other things) "In and after May 2007, Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's coverup included efforts to intimidate witnesses who might provide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done." FAC at 1 65. Maxwell's communications with Epstein "in and after 2007" are directly connected to these allegations in the Complaint. + +Judge Koeltl has already recognized the breadth of the allegations in denying a motion to strike a part of the complaint dealing with earlier events: + +The portion of the amended complaint subject to the motion to strike provides specific facts in support of the plaintiffs allegations that she was recruited an enticed into performing sex acts with Epstein as part of a larger enterprise to provide Epstein with young females for sex, in which each defendant allegedly played a specific role. The defendants contend that the plaintiff was a younger woman who willingly accepted the blandishments of a wealthy older man. The knowledge and intent of the defendants will plainly be an issue. The paragraphs of the amended complaint that the defendants seek to strike may be evidence of the defendants' knowledge and intent in their dealings with the plaintiff. See Federal Rule of Evidence 404(6). Accordingly, the motion to strike is denied. + +Transcript ("Tr.") of Aug. 7, 2018, hearing at 47-48. + +In light of the breadth complaint — and Judge Koeltl's earlier rulings — you should produce Ms. Maxwell's passport for the entire requested time period (2000 to 2008). + +### Document Request No. 2: All documents relating to communications with Jeffrey Epstein from 1999 — present. + +You object to production on grounds of undue burden and similar concerns. But given the allegations in the complaint regarding Ms. Maxwell's deep and pervasive involvement in Epstein's long-running sex trafficking organization, it is not unduly burdensome to require production of documents concerning communications between Maxwell and Epstein. With regard to alleged privileged materials, a privilege log should be immediately provided. With regard to the relevant time period, the relevant time period is 1999 to present. With regard to events preceding 2006, Judge Koeltl has already specifically ruled on this subject. And with regard to events following 2007, the First Amended Complaint specifically alleges that (among other things) "In and after May 2007, Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's coverup included efforts to intimidate witnesses who might provide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done." FAC at 1 65. Maxwell's communications with Epstein "in and after 2007" are directly connected to these allegations in the Complaint. + +## Document Request No. 16: All tax returns and supporting documentation filed by you from 2002-2008. + +You object on grounds that this request is "harassing" because, in your view, Ms. Maxwell's "personal financial information is not at issue in this matter and information relating thereto is irrelevant." But numerous financial issues are interwoven into this case. For example, as alleged in 1 62 of the First Amended Complaint, "Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiff's continued compliance with Epstein's sexual demands ...." Maxwell's financial ability to provide things of + +value is thus directly at issue. In addition, as alleged in 1 66 of the First Amended Complaint, "Defendants knowingly benefitted financially and received things of value as a result of coercing and inducing Plaintiff into sexual compliance and otherwise participating in their illegal venture and enterprise." These things of value may very well appear in income or other entries on Ms. Maxwell's tax returns. + +The "things of value" addressed in the Complaint tie directly into the statutory provisions that relies upon. Under 18 U.S.C. § 1591, anyone who "benefits, financially or by receiving anything of value from participation in a [sex trafficking] venture" is potentially covered by the statute (emphasis added). Thus, Ms. Maxwell's receipt (or distribution) of "things of value" may be elements that has to prove at trial. Of course, tax returns frequently reflect "things of value." + +Document Request No. 17: All tax returns and supporting documentation filed by you from 2015-2017. + +You raise similar objections to those advanced above in connection with this request. But in view of the allegations that Maxwell continued to participate in Epstein's sex trafficking organization (as alleged in, for example, 1 65 of the First Amended Complaint), this information is directly connected to the case. + +Document Request No. 19: All documents relating to communications with any named Defendant from January I, 2000 — present. + +You indicate that you are withholding documents outside the "relevant period" — but, as indicated above the relevant period extends more broadly than you maintain. You also indicate you are withholding some documents pursuant to a "common interest agreement." Please provide the appropriate privilege log for these materials. + +Document Request No. 20: All joint defense agreements ever in place between you and any of the other named Defendants. + +You indicate that you are withholding documents based on privilege in connection with this request. Please provide the appropriate privilege log for these documents. You also indicate that this request is unduly burdensome, but it is difficult to understand this objection since you appear to have already located the relevant documents. + +Document Request No. 21: All common interest agreements ever in place between you and any of the other named Defendants. + +You indicate that you are withholding documents based on privilege in connection with this request. What is your basis for claiming such an agreement is privileged? If you have a basis, please provide the appropriate privilege log for these documents. You also indicate that this request is unduly burdensome, but it is difficult to understand this objection since you appear to have already located the relevant documents. + +Document Request No. 22: All documents evidencing you having a common interest privilege with any of the other named Defendants. + +You indicate that you are withholding documents based on privilege in connection with this request. What is your basis for claiming such evidence is privileged? If you have a basis, please provide the appropriate privilege log for these documents. You also indicate that this request is unduly burdensome, but it is difficult to understand this objection since you appear to have already located the relevant documents. + +#### Document Request No. 23: All documents relating to communications with Alan Dershowitz from 1997 re 'enl + +You indicate that this request calls for documents not relevant to this action, but it appears you may intend to call Mr. Dershowitz at the trial in this matter. Accordingly, Dershowitz's communications with Ms. Maxwell are relevant. You also refer to attorney-work product, so a privilege log is required. Are you claiming a joint defense/common interest agreement? If so information about such subjects is not privileged. With regard to the time frame, the time frame is connected to Epstein's long-running and on-going sex trafficking enterprise that is at the heart of this case. + +## Document Request No. 26: All documents relating to communications with any of the following individuals from 1999 — present: Jean Luc Brunel and + +You indicate that you are withholding documents outside the "relevant period" — but, as indicated above the relevant period extends more broadly than you maintain. With regard to the time frame, the time frame is connected to Epstein's long-running and on-going sex trafficking enterprise that is at the heart of this case, as well as the subsequent coverup of the activities of that enterprise. + +### Document Request No. 27: All video tapes, audio tapes, photographs or any other print or electronic media relating to females under the age of 18, who are not family members, from the period of 2000 — present. + +You object that this request is unduly broad. But given that . Maxwell's deep and long-running involvement in a sexual trafficking enterprise that involved trafficking females under the age of 18, this request goes to central issues in this case. It is also not clear why you indicate that you are withholding photographs of "Ms. Maxwell as a child," as such photographs would fall outside the time period requested. You should produce all documents responsive to this request, as they may tend to demonstrate Ms. Maxwell's involvement in the sexual trafficking of girls under the age of 18. We are not seeking commercially produced materials that are copyrighted. + +### Document Request No. 28: All documents relating to your travel from the period of 2000 —present. including but not limited to, any travel on Jeffrey Epstein's planes, commercial flights, helicopters and records indicating passengers traveling with you, hotel records, and credit card receipts. + +It is not clear with you are withholding documents here as privileged, but if so, please provide the appropriate privilege log. You indicate that you are withholding documents outside the "relevant period" — but, as indicated above the relevant period extends more broadly than you maintain. With regard to the time frame, the time frame is connected to Epstein's long-running and on-going sex trafficking enterprise that is at the heart of this case, as well as the subsequent coverup of the activities of that enterprise. + +### Document Request No. 29: All documents relating to payments made from Jeffrey Epstein or any related entity to any of the Defendants from 2000 — present, including payments for work performed, gifts, bonuses, vehicles, living expenses, and payments to your charitable endeavors including the TerraMar project. + +What materials and/or data did you search? You indicate that you have only searched for documents within the "relevant period" — but, as indicated above the relevant period extends more broadly than you maintain. With regard to the time frame, the time frame is connected to Epstein's long-running and on-going sex trafficking enterprise that is at the heart of this case, as well as the subsequent coverup of the activities of that enterprise. + +Document Request No. 34: All flight logs or passenger manifests for any aircraft owned or controlled by Jeffrey Epstein. + +You indicate that you are withholding documents outside the "relevant period" — but, as indicated above the relevant period extends more broadly than you maintain. With regard to the time frame, the time frame is connected to Epstein's long-running and on-going sex trafficking enterprise that is at the heart of this case, as well as the subsequent coverup of the activities of that enterprise. + +Document Request No. 35: All flight logs or passenger manifests for any aircraft owned of controlled by any of the Defendants in this action. + +You indicate that you are withholding documents outside the "relevant period" — but, as indicated above the relevant period extends more broadly than you maintain. With regard to the time frame, the time frame is connected to Epstein's long-running and on-going sex trafficking enterprise that is at the heart of this case, as well as the subsequent coverup of the activities of that enterprise. + +Document Request No. 36: All flight logs or passenger manifest for any aircraft owned or controlled by any entity associated with any of the Defendants. + +You indicate that you are withholding documents outside the "relevant period" — but, as indicated above the relevant period extends more broadly than you maintain. With regard to the time frame, the time frame is connected to Epstein's long-running and on-going sex trafficking enterprise that is at the heart of this case, as well as the subsequent coverup of the activities of that enterprise. + +Document Request No. 45 All telephone records associated with you, including cell phone records from January 1, 2016 — present. + +You indicate that you are withholding documents outside the "relevant period" — but, as indicated above the relevant period extends more broadly than you maintain. With regard to the time frame, the time frame is connected to Epstein's long-running and on-going sex trafficking enterprise that is at the heart of this case. And with regard to events following 2007, the First Amended Complaint specifically alleges that (among other things) "In and after May 2007, Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's coverup included efforts to intimidate witnesses who might provide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done." FAC at 1 65. Maxwell's communications with Epstein "in and after 2007" are directly connected to these allegations in the Complaint. + +Document Request No. 47 All documents identifying any location you resided or stayed overnight from September 2006-May 2007. + +You indicate that you are withholding documents outside the "relevant period" — but, as indicated above the relevant period extends more broadly than you maintain. With regard to the time frame, the time frame is connected to Epstein's long-running and on-going sex trafficking enterprise that is at the heart of this case, as well as the subsequent coverup of the activities of that enterprise. + +You indicate that you are withholding documents outside the "relevant period" — but, as indicated above the relevant period extends more broadly than you maintain. With regard to the time frame, the time frame is connected to Epstein's long-running and on-going sex trafficking enterprise that is at the heart of this case, as well as the subsequent coverup of the activities of that enterprise. + +Document Request No. 60 All documents relating to any employee lists or records associated with you, Jeffrey Epstein or any related entity. + +You indicate that you are withholding documents outside the "relevant period" — but, as indicated above the relevant period extends more broadly than you maintain. With regard to the time frame, the time frame is connected to Epstein's long-running and on-going sex trafficking enterprise that is at the heart of this case, as well as the subsequent coverup of the activities of that enterprise. + +With regard to "entity," an entity associated with Ms. Maxwell might be a means for receiving or transmitting "things of value" that are the subject of this litigation, as specifically discussed in the complaint. + +Document Request No. 62 All travel records between 2000 and the present reflecting your presence in: (a) Palm Beach, Florida or immediately surrounding areas; (b) 9 E. 71st Street, New York, NY 10021; (c) New Mexico; (d) U.S. Virgin Islands; (e) any jet or aircraft owned or controlled by Jeffrey Epstein. + +You indicate that you are withholding documents outside the "relevant period" — but, as indicated above the relevant period extends more broadly than you maintain. With regard to the time frame, the time frame is connected to Epstein's long-running and on-going sex trafficking enterprise that is at the heart of this case, as well as the subsequent coverup of the activities of that enterprise. + +Document Request No. 67 All documents relating to M) from 2000 to present. + +You indicate that certain materials responsive to this request may be the subject of a court order precluding their production. If so, we are not asking you to violate that court order. With regard to other materials, however, has alleged that Maxwell re tedly was involved in sexually trafficking her as part Epstein's sex trafficking enterprise. In particular, alleges that she is a victim of Ms. Maxwell's and Mr. Epstein's sex trafficking enterprise. Accordingly. materials about are directly relevant to the sex trafficking enterprise at the heart of his case. + +### Adequacy of the Search + +Finally, you have indicated in response to a number of our requests that you were unable to locate any responsive documents. We believe a significant part of this is due to your inappropriate limitation of the "relevant period" to just a few months — a subject discussed above, particularly in our discussion of Request for Production No. 1. In connection with those responses where documents have not been located (or any otherwise restricted search was done), we believe that we are entitled to a description of your search efforts. So what data and/or documents did you search? + +I hope that you will agree with our position on these issues, as this would avoid a discovery dispute. Please indicate your position in these issues at your earliest convenience and, in any event, no later November 19, 2018. + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law and University Distinguished Professor of Law + +S.J. Quinney College of Law at the University of Utah + +383 S. University St., Salt Lake City, UT 84112-0730 + +(801) 585.5202 (phone) (801) 585.2750 (fax) + +cassellp@law.utah.edu + +You can access my publications on htto://ssrn.com/author=30160 + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Any views he expresses in this email are his own. + +From: Laura Menninger + +Sent: Tuesday, November 6, 2018 5:55 PM + +To: Paul Cassell + +Cc: Smccawlev@BSFLLP.com; Meredith :Brad ; Jeff + +Pagliuca + +Subject: Re: meet and confer on Ms. Maxwell's discovery production + +Paul - + +Monday is Veteran's Day and I have a number of things already scheduled. Tuesday I'm in a mediation all day and Wednesday we have Mr. Zinoviev's deposition scheduled (pending Scott's trial calendar). + +Because of my tight schedule, please just let me know what your concerns are in writing and I will get back to you as soon as possible. If there is anything that can be addressed before the deposition, I will make every effort to do so. + +Thanks, + +-Laura + +On Nov 6, 2018, at 4:27 PM, Paul Cassell cassellp@law.utah.edu> wrote: + +Hi Laura, + +Yes, perhaps the Thursday deposition timing is too tight. And you're not available on Friday. + +So, what about this coming Monday, Nov. 12? Times that work for us on Monday are 9 AM, 10 AM, 2 PM and 3 PM (mountain). + +Paul Cassell for + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law and University Distinguished Professor of Law + +S.J. Quinney College of Law at the University of Utah + +383 S. University St., Salt Lake City, UT 84112-0730 + +(801) 585-5202 (phone) (801) 585-2750 (fax) + +cassellp@law.utah.edu + +CONFIDENTIAL: This electronic message • along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Any views he expresses in this email are his own. + +From: Laura Menninger + +Sent: Tuesday, November 6, 2018 4:16 PM + +To: Paul Cassell casselloOlaw.utah.edu> + +Cc: Smccawley@BSFLLP.com; Meredith .Brad arad@eollc.com>; Stan Pottinger ; Brittany ; Scott Link • Jeff Pagliuca + +Subject: Re: meet and confer on Ms. Maxwell's discovery production + +Paul • + +I will be with Ms Maxwell in her deposition on Nov 8 unless there is something I'm not aware of. We can try to speak then during a break. If you want to write out your concerns before then and send to me, I would be more prepared to try to work out issues when we speak. I'm not available on Friday. + +Thank you, Laura + +On Nov 6, 2018, at 6:06 PM, Paul Cassell wrote: + +Hi Laura, + +Our team has looked at Ms. Maxwell's discovery production and believe there are a number of deficiencies. Is there a convenient time to set up a conference call to meet and confer on this issue? Some times that work for our team are: + +Nov. 8 - 9 AM mountain, 10 AM mountain, 1 PM mountain + +Nov. 9 - 9 AM mountain, 11 AM mountain, noon mountain, 1 PM mountain + +Thanks in advance for giving us times that work, and looking forward to trying to resolve some of these issues. + +Paul Cassell for + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law and University Distinguished Professor of Law + +S.J. Quinney College of Law at the University of Utah + +383 S. University St., Salt Lake City, UT 84112-0730 + +(801) 585.5202 (phone) (801) 585-2750 (fax) + +cassellp@law.utah.edu + +You can access my publications on http://ssrn.com/author=30160 + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar, but not the bars of other states. Any views he expresses in this email are his own. + +The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that. among other piotectlans, is the subject of attorney-client privilege. attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient. you are hereby notified that any dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. II you have received this communication in error. please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. 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Magistrate Sarah Netbum Thurgood Marshall Courthouse Southern District of New York 40 Foley Square, Room 430 New York, New York 10007 + +Haddon. and S P.0 Laura A. Menninger + +150 East 10th Avenue Denver. Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflow.com Imenninger@hmflaw.com + +Re: v. Jeffrey Epstein, et at. 17-cv-00616 (JGK) Response to Letter Motion Seeking Extension of Expert Disclosure Deadline + +Dear Judge Netburn: + +At the scheduling conference before Judge Koeltl in this matter on August 7, 2018, Plaintiff proposed that all discovery be completed by December 31, 2018, presumably to include expert discovery. (ECF 144 at 66) Acceding to the defense's request, Judge Koeltl instead offered January 25, 2019 and reiterated there was no reason why discovery could not be complete by then. He ordered that any modifications to the schedule would require "good cause" shown. Id.at 68. + +Plaintiff's request for a 25-day extension of time to submit expert disclosures lacks such "good cause." She provides no meaningful explanation as to her inability to secure the experts' reports and disclosures in a timely fashion. The fact that the un-named, unquantified, and unspecified experts have been "traveling out of the country" for unknown reasons over an undetermined period of time does not satisfy the type of "good cause" contemplated by Rule 16(bX4) or as ordered by Judge Koeltl. + +The Second Circuit has emphasized that "a finding of 'good cause' depends on the diligence of the moving party." v. Columbia Pictures Indus., 204 F.3d 326, 340 (2d Cir. 2000). The letter motion is silent with respect to Plaintiff's counsel's efforts to timely secure the reports. Further, "'[g]ood cause' is a more exacting standard than the 'excusable neglect' standard; in other words, 'the mistake or inadvertence of counsel will not support a finding of good cause."' Scott v. City of N.Y. Dells' of Correction, No. 04 Civ. 9638, 2007 WL 4178405, \*4 (S.D.N.Y. Nov. 26, 2007). + +Additionally, the schedule proposed by Plaintiff's counsel, as explained during the parties' telephonic meet-and-confer, prejudices the defense. Plaintiff proposes that the defense's rebuttal expert disclosures be 30 days later, or February 19, without any modification to other deadlines. However, as Plaintiff knows, the dispositive motion deadline in this case is February 15. The ability Hon. Sarah Netburn December 13, 2018 Page 2 + +to conduct all expert discovery including depositions in unknown locations, find and secure rebuttal experts, disclose their reports and file a summary judgment motion in the same 30 day period is simply untenable and forces the defendants to bear the burden of Plaintiff's lack of diligence. + +Defendant proposed a one-week or ten-day extension of all deadlines as a compromise but Plaintiff rejected that proposal and instead seeks the one-sided benefit of a full month extra for her disclosures, without any modification of the dispositive motions deadline or trial. This Court should deny her request. + +Respectfully submitted, + +HADDON, AND P.C. + +/s/ Laura A. Menninger Laura A. 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Magistrate Sarah Netbum Thurgood Marshall Courthouse Southern District of New York 40 Foley Square, Room 430 New York, New York 10007 + +Haddon, and Pc Laura A. Menninger + +150 Eost 10th Avenue Denver. Colorado 80203 PH 303.831.7364 DI 303.832.2628 www.hmflaw.com Imenningerehmflaw.com + +Re: v. Jeffrey Epstein, et al., 17-cv-00616 (JGK) + +Unopposed Letter Motion Seeking Extension of Time to Respond to Letter Motion for Pit-Motion Conference and to Adjourn Pre-Motion Conference (ECF 179. 1811 + +Dear Judge Netbum: + +By Order of the Court, counsel for Ms. Maxwell was to file a response by today's date concerning Plaintiff's request for a pre-motion conference (ECF 179), a conference which this Court scheduled for Thursday, December 20, 2018 (ECF 181). + +This letter motion is to advise the Court that the parties have reached a resolution of the case and are awaiting notarized signatures of the parties. It is therefore likely that no response or hearing will be necessary. + +In the interest of conserving judicial resources, the parties hereby request a one-week adjournment of the time for Ms. Maxwell to respond to the allegations made in Plaintiffs letter motion and an indefinite adjournment of the hearing scheduled for Thursday. The parties request leave to contact the Court within a week if resolution is not finalized to re-schedule the conference consistent with the Court's calendar. + +Respectfully submitted, + +HADDON, AND P.C. + +/s/ Laura A. Menninger Laura A. 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[D.E \_1 The Court, having reviewed the Stipulation, hereby + +ORDERS AND ADJUDGES that each and every issue, claim, including all claims for all forms of damages, prejudgment interest, and costs, is hereby dismissed with prejudice, each party to bear its own attorneys' fees and costs. + +DONE AND ORDERED in at New York, New York, this day of 2018. + +United States District Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820606/EFTA02820606.metadata.json b/marker2/court-jane-doe-43/EFTA02820606/EFTA02820606.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f3cd256043867c2105fe6833b2943b66dd314fe7 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820606/EFTA02820606.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820606.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 792, + "elapsed_seconds": 0.65, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 293.59381103515625, + 71.28 + ], + [ + 293.59381103515625, + 100.10302734375 + ], + [ + 68.544, + 100.10302734375 + ] + ] + }, + { + "title": "AGREED FINAL ORDER OF DISMISSAL WITH PREJUDICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 135.864, + 320.76 + ], + [ + 476.6607666015625, + 320.76 + ], + [ + 476.6607666015625, + 335.60302734375 + ], + [ + 135.864, + 335.60302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "Line", + 22 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820606" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820607/EFTA02820607.md b/marker2/court-jane-doe-43/EFTA02820607/EFTA02820607.md new file mode 100644 index 0000000000000000000000000000000000000000..5439dcb57cb5d14fd2fceb38fa84d227492c62bd --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820607/EFTA02820607.md @@ -0,0 +1,33 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, + +v. + +JEFFREY EPSTEIN GHISLAINE MAXWELL GROFF and NATALYA LESLEY + +Defendants. + +No. 17-Civ-00616 (..1OK) + +## STIPULATION OF DISMISSAL WITH PREJUDICE + +IT IS HEREBY STIPULATED AND AGREED, by and among Plaintiff, and Defendants, Jeffrey Epstein, Ghislaine Maxwell, and Lesley Groff, pursuant to Federal Rule of Civil Procedure 41, that each and every issue, claim, including all claims for all forms of damages, prejudgment interest, and costs be dismissed with prejudice, each party to bear its own attorneys' fees, costs, and expenses. The parties hereby request the Court to enter the attached Agreed Final Order of Dismissal With Prejudice. + +DATED: December 20, 2018 + +LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Blvd., Suite 930 West Palm Beach, FL 33401 (561) 847-4408 scott@linkrocklaw.com + +By: /s/ Scott J. Link SCOTT J. LINK, pro hac vice Counsel or Defendants Jeffrey Epstein, and Lesley Groff + +DATED: December 20, 2018 + +BOWS SCHILLER FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 smccawley@bsflIp.com mschultz@bsfllp.com + +By: /s/ Sigrid McCawley. with permission SIGRID MCCAWLEY, ro hac vice MEREDITH ro hac vice Counsel for Plaintiff + +DATED: December 20, 2018 + +HADDON,, & , P.C. 150 East 1 Avenue Denver, CO 80203 Imenninger@hmflaw.com jpagliuca@hmflaw.com + +By: /s/ Laura A. Menninger. with permission LAURA A. 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JEFFREY EPSTEIN OHISLAINE MAXWELL, LESLEY GROFF and A Defendants. + +No. 17-Civ-00616 (JGK) + +## STIPULATION OF DISMISSAL WITH PREJUDICE + +IT IS HEREBY STIPULATED AND AGREED, by and among Plaintiff, and Defendants, Jeffrey Epstein, Ghislaine Maxwell, and Lesley Groff, pursuant to Federal Rule of Civil Procedure 41, that each and every issue, claim, including all claims for all forms of damages, prejudgment interest, and costs be dismissed with prejudice, each party to bear its own attorneys' fees, costs, and expenses. The parties hereby request the Court to enter the attached Agreed Final Order of Dismissal With Prejudice. + +DATED: December 20, 2018 + +LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Blvd., Suite 930 West Palm Beach, FL 33401 (561) 847-4408 scott@linkrocklaw. + +By: con J. LINK, pro hac ce Counsel or Defendants effrey Epstein, and Lesley - + +DATED: December 20, 2018 + +BOLES SCHILLER FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954)356-0011 • smccawley@bsfllp.com mschultz®bsfllp.com + +By: SIGRID MCCA EY ro hac vice MEREDITH ro hoc vice Counsel forPlaintiff + +DATED: December 20, 2018 + +HADDON, n& IIMM P.C. + +150 East 10 Avenue + +Denver, CO 80203 + +Imenninger®hmflaw.com + +jpagliuc mflaw.com LAURA A. MENNINGER (LM-13 + +JEFFREY PAGLIUCA, pro hac vice + +Counsel for Defendant Ghisloine + +Maxwell + +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, + +v. + +JEFFREY EPSTEIN GHISLAINE MAXWELL LESLEY GROFF and NATALYA + +Defendants. + +No. 17-Civ-00616 (JGK) + +## AGREED FINAL ORDER OF DISMISSAL WITH PREJUDICE + +THIS CAUSE came before the Court upon the Stipulation of Dismissal With Prejudice entered into by and among Plaintiff, and Defendants, Jeffrey Epstein, Ghislaine Maxwell, and Lesley Groff. [D.E \_.1 The Court, having reviewed the Stipulation, hereby + +ORDERS AND ADJUDGES that each and every issue, claim, including all claims for all forms of damages, prejudgment interest, and costs, is hereby dismissed with prejudice, each party to bear its own attorneys' fees and costs. + +DONE AND ORDERED in at New York, New York, this day of 2018. + +United States District Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820609/EFTA02820609.metadata.json b/marker2/court-jane-doe-43/EFTA02820609/EFTA02820609.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7f39bef5e66270b227ae47835f1c1e1e6b4aaec1 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820609/EFTA02820609.metadata.json @@ -0,0 +1,231 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820609.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2199, + "elapsed_seconds": 0.79, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 86.904, + 104.49 + ], + [ + 291.444091796875, + 104.49 + ], + [ + 291.444091796875, + 131.72406005859375 + ], + [ + 86.904, + 131.72406005859375 + ] + ] + }, + { + "title": "STIPULATION OF DISMISSAL WITH PREJUDICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 170.74800000000002, + 328.86 + ], + [ + 431.376953125, + 328.86 + ], + [ + 431.376953125, + 343.96405029296875 + ], + [ + 170.74800000000002, + 343.96405029296875 + ] + ] + }, + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 293.59381103515625, + 71.28 + ], + [ + 293.59381103515625, + 100.10302734375 + ], + [ + 68.544, + 100.10302734375 + ] + ] + }, + { + "title": "AGREED FINAL ORDER OF DISMISSAL WITH PREJUDICE", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 135.864, + 319.95000000000005 + ], + [ + 476.6607666015625, + 319.95000000000005 + ], + [ + 476.6607666015625, + 335.60302734375 + ], + [ + 135.864, + 335.60302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 39 + ], + [ + "Text", + 9 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 26 + ], + [ + "Line", + 13 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Caption", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 22 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820609" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820612/EFTA02820612.md b/marker2/court-jane-doe-43/EFTA02820612/EFTA02820612.md new file mode 100644 index 0000000000000000000000000000000000000000..9b67c0b9aa99b360632474e854794507fb72d8e1 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820612/EFTA02820612.md @@ -0,0 +1,21 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, + +v. + +JEFFREY EPSTEIN GHISLAINE MAXWELL LESLEY GROFF and NATALYA + +Defendants. + +No. 17-Civ-00616 (J6K) + +## AGREED FINAL ORDER OF DISMISSAL WITH PREJUDICE + +THIS CAUSE came before the Court upon the Stipulation of Dismissal With Prejudice entered into by and among Plaintiff, and Defendants, Jeffrey Epstein, Ghislaine Maxwell, and Lesley Groff. [D.E \_1 The Court, having reviewed the Stipulation, hereby + +ORDERS AND ADJUDGES that each and every issue, claim, including all claims for all forms of damages, prejudgment interest, and costs, is hereby dismissed with prejudice, each party to bear its own attorneys' fees and costs. + +DONE AND ORDERED in at New York, New York, this day of 2018. + +United States District Judge \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820612/EFTA02820612.metadata.json b/marker2/court-jane-doe-43/EFTA02820612/EFTA02820612.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2f41f6a3e9cf3ee6f78514a88776ce01f7d9af1d --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820612/EFTA02820612.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-jane-doe-43/EFTA02820612.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 792, + "elapsed_seconds": 0.64, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 293.59381103515625, + 71.28 + ], + [ + 293.59381103515625, + 100.10302734375 + ], + [ + 68.544, + 100.10302734375 + ] + ] + }, + { + "title": "AGREED FINAL ORDER OF DISMISSAL WITH PREJUDICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 135.864, + 320.76 + ], + [ + 476.6815185546875, + 320.76 + ], + [ + 476.6815185546875, + 335.60302734375 + ], + [ + 135.864, + 335.60302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 22 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02820612" + } +} \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820613/EFTA02820613.md b/marker2/court-jane-doe-43/EFTA02820613/EFTA02820613.md new file mode 100644 index 0000000000000000000000000000000000000000..aec5e9397ac87efe94f18e25307941cd209e2177 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820613/EFTA02820613.md @@ -0,0 +1,21 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, + +v. + +JEFFREY EPSTEIN GHISLAINE MAXWELL, LESLEY GROFF and NATALYA + +Defendants. + +Plaintiff, pursuant to Federal Rule of Civil Procedure 41 (a)(1), hereby files this Notice of Voluntary Dismissal of her claims against Defendant Natalya Defendant has not filed an answer nor made any appearance in this matter. On December 20, 2018, Plaintiff and Defendants Jeffrey Epstein, Ghislaine Maxwell, and Leslie Groff filed a Stipulation of Dismissal with Prejudice. Accordingly, Plaintiff hereby provides her Notice of Voluntary Dismissal as to Defendant Natalya to Federal Rule of Civil Procedure 41(a)(1). pursuant + +No. 17-Civ-00616 (JGK) + +## NOTICE OF VOLUNTARY DISMISSAL + +DATED: December 20, 2018 BOLES SCHILLER FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 smccawley@bsflIp.com mschultz@bsflIp.com + +By: /Sigrid S. 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[D.E. 18/8] The Court, having reviewed the Stipulation, hereby + +ORDERS AND ADJUDGES that each and every issue, claim, including all claims for all forms of damages, prejudgment interest, and costs, is hereby dismissed with prejudice, each party to bear its own attorneys' fees and costs. + +DONE AND ORDERED in [REDACTED] at New York, New York, this 20 day of December, 2018. + +![]()*The Clerk is directed outer +judgment and to close this case. The +Clerk is also directed to close all +gending motions. 50 ordered* + +*12/20/18 4 S.D.S.* + +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, v. JEFFREY EPSTEIN H I A • MAXWEL Y GROFF and Defendants. + +No. 17•Civ-00616 (MK) + +## STIPULATION OF DISMISSAL WITH PREJUDICE + +IT IS HEREBY STIPULATED AND AGREED, by and among Plaintiff, and Defendants, Jeffrey Epstein, Ghislaine Maxwell, and Lesley Groff, pursuant to Federal Rule of Civil Procedure 41, that each and every issue, claim, including all claims for all forms of damages, prejudgment interest, and costs be dismissed with prejudice, each party to bear its own attorneys' fees, costs, and expenses. The parties hereby request the Court to enter the attached Agreed Final Order of Dismissal With Prejudice. + +DATED: December 20, 2018 + +LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Blvd., Suitt 930 West Palm Beach, FL 33401 (561)847.4408 + +scott@linIcrocklaw.c By: COTT J. LINK, pro hac Ice /SI Defendants effiey Epstein, and Lesley + +DATED: December 20, 2018 + +BOIES SCHILLER FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 • smccawley@bsfIlp.com mschultz(gbsfIlp.com + +By: SIGRID MC MEREDITH Counsel for ro hoc vice + +DATED: December 20, 2018 + +HADDON, [REDACTED] & [REDACTED] P.C. +150 East 10th Avenue +Denver, CO 80203 +lmenninger@hmflaw.com +jpagliuca@hmflaw.com + +![]()LAURA A. 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JEFFREY !EPSTEIN GHISLAINE MAXWELL, LESLEY GROFF and NATALYA Defendants. + +USOC SONY DGCUMENT ELECTRONICALLY FILED DOC# DATE FILED: + +No. 17-Civ-00616 (JGK) + +## NOTICE OF VOLUNTARY DISMISSAL + +Plaintiff, , pursuant to Federal Rule of Civil Procedure 41 (a)( 1 ), hereby files this Notice of Voluntary Dismissal of her claims against Defendant Natalya Defendant has not filed an answer nor made any appearance in this matter. On December 20, 2018, Plaintiff and Defendants Jeffrey Epstein, Ghislaine Maxwell, and Leslie Groff filed a Stipulation of Dismissal with Prejudice. Accordingly, Plaintiff hereby provides her Notice of Voluntary Dismissal as to Defendant Natalya pursuant to Federal Rule of Civil Procedure 41(a)(1). + +DATED: December 20, 2018 + +SO ORDERED: 676 , .S.D.J. + +BOLES SCHILLER FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 smecawley@bsillp.com mschultz@bsillp.com + +By: /SiRrid S. 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Krajick Clerk of Court + +Dear Litigant + +Enclosed is a copy of the judgment entered in your case. If you disagree with a judgment or final order of the district court, you may appeal to the United States Court of Appeals for the Second Circuit. To start this process, file a "Notice of Appeal" with this Court's Pro Se Intake Unit. + +You must file your notice of appeal in this Court within 30 days after the judgment or order that you wish to appeal is entered on the Court's docket, or, if the United States or its officer or agency is a party, within 60 days after entry of the judgment or order. If you are unable to file your notice of appeal within the required time, you may make a motion for extension of time, but you must do so within 60 days from the date of entry of the judgment, or within 90 days if the United States or its officer or agency is a party, and you must show excusable neglect or good cause for your inability to file the notice of appeal by the deadline. + +Please note that the notice of appeal is a one-page document containing your name, a description of the final order or judgment (or part thereof) being appealed, and the name of the court to which the appeal is taken (the Second Circuit) - it does not include your reasons or grounds for the appeal. Once your appeal is processed by the district court, your notice of appeal will be sent to the Court of Appeals and a Court of Appeals docket number will be assigned to your case. At that point, all further questions regarding your appeal must be directed to that court. + +The filing fee for a notice of appeal is \$505 payable in cash, by bank check, certified check, or money order, to "Clerk of Court, S.D.N.Y." No personal checks are accepted. If you are unable to pay the \$505 filing fee, complete the "Motion to Proceed in Forma Pauperis on Appeal" form and submit it with your notice of appeal to the Pro Se Intake Unit. If the district court denies your motion to proceed in foram pauperis on appeal, or has certified under 28 U.S.C. §1915(a)(3) that an appeal would not be taken in good faith, you may file a motion in the Court of Appeals for leave to appeal in forma pauperis, but you must do so within 30 days after service of the district court order that stated that you could not proceed in forma pauperis on appeal. + +For additional issues regarding the time for filing a notice of appeal, see Federal Rule of Appellate Procedure 4(a). There are many other steps to beginning and proceeding with your appeal, but they are governed by the rules of the Second Circuit Court of Appeals and the Federal Rules of Appellate Procedure. For more information, visit the Second Circuit Court of Appeals website at http://www.ca2.uscourts.gov/. + +THE DANIEL MOYNIHAN UNITED STATES COURTHOUSE SOO PEARL STREET New YORK. NY 10007.1312 + +THE CHARLES L. BRIEANT, JR. UNITED STATES COURTHOUSE 300 QUARROPAS STREET PLAINS, NY 10601.4150 + +# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +(List the full name(s) of the plaintiff(s)/petitioner(s).) CV + +-against- + +(List the full name(s) of the defendant(s)/respondent(s).) + +Notice is hereby given that the following parties: + +)( ) + +### NOTICE OF APPEAL + +(list the names of all parties who are filing an appeal) + +in the above-named case appeal to the United States Court of Appeals for the Second Circuit + +from the ❑ judgment ❑ order entered on: + +that: + +(date that judgment or order was entered on docket) + +(If the appeal is from an order, provide a brief description above of the decision in the order.) + +Dated Signature. + +Name (Last, First, MI) + +Address City State Zip Code + +Telephone Number E-mail Address (if available) + +Each party filing the appeal must date and sign the Notice of Appeal and provide his or her mailing address and telephone number, EXCEPT that a signer of a pro se notice of appeal may sign for his or her spouse and minor children if they are parties to the case. Fed. R. App. P. 3(c)(2). Attach additional sheets of paper as necessary. + +**UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK** + +\_\_\_\_\_ +(List the full name(s) of the plaintiff(s)/petitioner(s).) + +\_\_\_\_\_ CV\_\_\_\_\_ ( ) ( ) + +-against- + +**MOTION FOR EXTENSION +OF TIME TO FILE NOTICE +OF APPEAL** + +\_\_\_\_\_ +(List the full name(s) of the defendant(s)/respondent(s).) + +I move under Rule 4(a)(5) of the Federal Rules of Appellate Procedure for an extension of time to file a notice of appeal in this action. I would like to appeal the judgment entered in this action on \_\_\_\_\_ but did not file a notice of appeal within the required time period because: \_\_\_\_\_ date + +\_\_\_\_\_ +\_\_\_\_\_ +\_\_\_\_\_ + +(Explain here the excusable neglect or good cause that led to your failure to file a timely notice of appeal.) + +| _____
Dated: | ██████████
Signature | +|----------------------------------------|-------------------------------------------------------------------------------------------------| +| _____
Name (Last, First, MI) | | +| _____
Address | | +| _____
Telephone Number | | +| _____
E-mail Address (if available) | | + +# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +CV ( )( ) + +(list the full name(s) of the plaintiff(s)/petitioner(s).) + +-against- + +(List the full name(s) of the defendant(s)/respondent(s).) + +### MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS ON APPEAL + +I move under Federal Rule of Appellate Procedure 24(a)(1) for leave to proceed in forma pauperis on appeal. This motion is supported by the attached affidavit. + +Dated Signature + +Name (Last, First, MI) + +Address City State Tip Code + +Telephone Number E-mail Address (if available) + +### Application to Appeal In Forma Pauperis + +v. Appeal No. + +District Court or Agency No. + +|

Affidavit in Support of Motion

I swear or affirm under penalty of perjury that, because of my poverty, I cannot prepay the docket fees of my appeal or post a bond for them. I believe I am entitled to redress. I swear or affirm under penalty of perjury under United States laws that my answers on this form are true and correct. (28 U.S.C. § 1746; 18 U.S.C. § 1621.)

|

Instructions

Complete all questions in this application and then sign it. Do not leave any blanks: if the answer to a question is "0," "none," or "not applicable (N/A)," write that response. If you need more space to answer a question or to explain your answer, attach a separate sheet of paper identified with your name, your case's docket number, and the question number.

| +|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +|

Signed: _____

|

Date: _____

| + +My issues on appeal are: (required): + +- 1. For both you and your spouse estimate the average amount of money received from each of the following sources during the past 12 months. Adjust any amount that was received weekly, biweekly, quarterly, semiannually, or annually to show the monthly rate. Use gross amounts, that is, amounts before any deductions for taxes or otherwise. + +| Income source | Average monthly amount during the past 12 months | | Amount expected next month | | +|---------------------------------------------------|--------------------------------------------------|--------|----------------------------|--------| +| | You | Spouse | You | Spouse | +| Employment | \$ | \$ | \$ | \$ | +| Self-employment | \$ | \$ | \$ | \$ | +| Income from real property (such as rental income) | \$ | \$ | \$ | \$ | + +| Interest and dividends | S | S | \$ | \$ | +|-------------------------------------|------|------|------|------| +| Gifts | S | S | S | S | +| Alimony | S | S | S | S | +| Child support | S | S | S | S | +| | \$ | S | \$ | S | +| | \$ | S | \$ | s | +| Unemployment payments | S | S | 5 | s | +| Public-assistance (such as welfare) | \$ | S | s | s | +| Other (specify): | \$ | \$ | 5 | S | +| Total monthly income: | \$ 0 | \$ 0 | \$ 0 | \$ 0 | + +2. li st your employment history for the past two years, most recent employer first (Gross monthly pay is before taxes or other deductions.) + +| Employer | Address | Dates of employment | Gross monthly pay | +|----------|---------|---------------------|-------------------| +| | | | \$ | +| | | | \$ | +| | | | \$ | + +3. List your spouse's employment history for the past two years, most recent employer first. (Gross monthly pay is before taxes or other deductions.) + +| Employer | Address | Dates of employment | Gross monthly pay | +|----------|---------|---------------------|-------------------| +| | | | \$ | +| | | | \$ | +| | | | \$ | + +4. How much cash do you and your spouse have? \$ + +Below, state any money you or your spouse have in bank accounts or in any other financial institution. + +| Financial Institution Type of Account Amount you have | Amount your | +|-------------------------------------------------------|-------------| +| S | \$ | +| \$ | \$ | +| \$ | \$ | + +If you are a prisoner seeking to appeal a judgment in a civil action or proceeding, you must attach a statement certified by the appropriate institutional officer showing all receipts, expenditures, and balances during the last six months in your institutional accounts. If you have multiple accounts, perhaps because you have been in multiple institutions, attach one certified statement of each account. + +5. List the assets, and their values, which you own or your spouse owns. Do not list clothing and ordinary household furnishings. + +| Home | Other real estate | Motor vehicle #1 | +|------------|-------------------|------------------| +| (Value) \$ | (Value) \$ | (Value) \$ | +| | | Make and year: | +| | | Model: | +| | | Registration #: | + +| Motor vehicle #2 | Other assets | Other assets | +|------------------|--------------|--------------| +| (Value) \$ | (Value) \$ | (Value) \$ | +| Make and year: | | | +| Model: | | | +| Registration #: | | | + +- 6. State every person, business, or organization owing you or your spouse money, and the amount owed. + +| Amount owed to you | Amount owed to your | +|--------------------|---------------------| +| S | \$ | +| S | \$ | +| S | \$ | +| \$ | \$ | + +- 7. State the persons who rely on you or your spouse for support. + +| Name [or, if a minor (i.e., underage), initials only] | Relationship | Age | +|-------------------------------------------------------|--------------|-----| +| | | | +| | | | +| | | | + +- 8. Estimate the average monthly expenses of you and your family. Show separately the amounts paid by your spouse. Adjust any payments that are made weekly, biweekly, quarterly, semiannually, or annually to show the monthly rate. + +| | You Your Spouse | +|--------------------------------------------------------------------|-----------------| +| lot rented for | \$ \$ | +| Yes No | | +| Utilities (electricity, heating fuel, water, sewer, and telephone) | \$ \$ | +| Home maintenance (repairs and upkeep) | \$ \$ | +| Food | \$ \$ | +| Clothing | \$ \$ | +| Laundry and dry-cleaning | \$ \$ | +| Medical and dental expenses | \$ \$ | + +| Transportation (not including motor vehicle payments) | \$ | S | +|--------------------------------------------------------|------|------| +| Recreation, entertainment, newspapers, magazines, etc. | \$ | \$ | +| | \$ | \$ | +| | \$ | \$ | +| | \$ | \$ | +| | \$ | \$ | +| | \$ | \$ | +| | \$ | \$ | +| | \$ | \$ | +| | S | S | +| | \$ | \$ | +| Alimony, maintenance, and support paid to others | \$ | \$ | +| | \$ | \$ | +| Other (specify): | S | S | +| Total monthly expenses: | \$ 0 | \$ 0 | + +- 9. 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LESLEY GROFF and +NATALYA [REDACTED], + +Defendant. + +-----X + +DOCUMENT +ELECTRONIC +DOC# +DATE FILED: 12/26/2018 + +17 CIVIL 616 (JGK) + +**JUDGMENT** + +It is hereby **ORDERED, ADJUDGED AND DECREED:** That for the reasons stated in the Court's Order dated December 20, 2018, that each and every issue, claim, including all claims for all forms of damages, prejudgment interest, and costs, is hereby dismissed with prejudice, each party to bear its of attorneys' fees and costs; accordingly, this case is closed + +**Dated:** New York, New York +December 26, 2018 + +![]()THIS DOCUMENT WAS ENTERED +ON THE DOCKET ON 12/27/2018 \ No newline at end of file diff --git a/marker2/court-jane-doe-43/EFTA02820628/EFTA02820628.metadata.json b/marker2/court-jane-doe-43/EFTA02820628/EFTA02820628.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d7f7166eb5a59fd58ea7c88383068752ef819a62 --- /dev/null +++ b/marker2/court-jane-doe-43/EFTA02820628/EFTA02820628.metadata.json 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