DOJ-OGR-00030547.jpg
435 KB
Extraction Summary
5
People
0
Organizations
1
Locations
1
Events
7
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
435 KB
Summary
This document is page 7 of a legal complaint, specifically Count IV, filed by Plaintiff Jane Doe against defendants Epstein, Robson, and Kellen. The count alleges that the defendants engaged in a pattern of criminal activity in violation of Florida statutes related to prostitution. The specific allegations include procuring minors for prostitution, soliciting, recruiting, and coercing individuals into prostitution.
People (5)
| Name | Role | Context |
|---|---|---|
| Jane Doe | Plaintiff |
Mentioned as the plaintiff in the civil complaint, represented by her mother.
|
| Jane Doe's Mother | Parent and natural guardian |
Represents the plaintiff, Jane Doe, in the legal proceedings.
|
| Epstein | Defendant |
Named as a defendant against whom the civil remedy for violation of Florida Statute is sought.
|
| Robson | Defendant |
Named as a defendant against whom the civil remedy for violation of Florida Statute is sought.
|
| Kellen | Defendant |
Named as a defendant against whom the civil remedy for violation of Florida Statute is sought.
|
Timeline (1 events)
Defendants allegedly participated in an enterprise and a pattern of criminal activity, including procuring for prostitution, soliciting, recruiting, and forcing individuals into prostitution, in violation of multiple Florida Statutes. These activities are alleged to have occurred within a 5-year period.
Florida
Locations (1)
| Location | Context |
|---|---|
|
The legal action is based on violations of Florida Law and Florida Statutes.
|
Relationships (7)
The document states 'Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian...'
Jane Doe is the plaintiff filing a complaint against Epstein, who is a defendant.
Jane Doe is the plaintiff filing a complaint against Robson, who is a defendant.
Jane Doe is the plaintiff filing a complaint against Kellen, who is a defendant.
They are listed together as defendants who allegedly 'participated in an enterprise, or conspired'.
They are listed together as defendants who allegedly 'participated in an enterprise, or conspired'.
Key Quotes (2)
"Civil Remedy for Violation of Florida Statute Section 772.103 against Defendants Epstein, Robson and Kellen"Source
— Document
(The title of Count IV of the complaint.)
DOJ-OGR-00030547.jpg
Quote #1
"Defendants participated in an enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statute section 772.103(3)-(4)."Source
— Document (Plaintiff's allegation)
(Paragraph 31, outlining the core allegation of the count.)
DOJ-OGR-00030547.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,681 characters)
reserves the right to amend this Complaint to add a claim for punitive damages pursuant to Florida Law.
COUNT IV
Civil Remedy for Violation of Florida Statute Section 772.103 against
Defendants Epstein, Robson and Kellen
Civil Remedy for Violation of Florida Statute Section 772.103 against
Defendants Epstein, Robson and Kellen
30. Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, repeats and realleges paragraphs 1 through 16 above.
31. Defendants participated in an enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statute section 772.103(3)-(4).
32. Defendants engaged in this pattern of criminal activity by engaging in at least two of the following incidents of criminal activity with the same or similar intents, results, accomplices, victims, and methods of commission within a 5 year period:
a. Procuring for prostitution, or causing to be prostituted, any person who is under the age of 18 years in violation of Florida Statute section 796.03.
b. Soliciting, inducing, enticing, or procuring another to commit prostitution, lewdness, or assignation in violation of Florida Statute section 796.07(2)(f), or aiding, abetting or participating in such acts in violation of Florida Statute section 796.07(2)(h);
c. Knowingly recruiting, enticing, harboring, transporting, providing, or obtaining by any means a person, knowing that force, fraud, or coercion will be used to cause that person to engage in prostitution in violation of Florida Statute section 796.045; or
d. Forcing, compelling, or coercing another to become a prostitute in violation of Florida Statute section 796.04.
Page 7 of 9
07/26/17
Page 80 of 131
Public Records Request No.: 17-295
DOJ-OGR-00030547
Page 80 of 131
Public Records Request No.: 17-295
DOJ-OGR-00030547
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