mirror-epstein-docs/results/IMAGES011/DOJ-OGR-00030437.json

{
  "document_metadata": {
    "page_number": "5",
    "document_number": "17-295",
    "date": "07/26/17",
    "document_type": "Legal Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "COUNT II\nIntentional Infliction of Emotional Distress\n21. Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother, individually, repeat and reallege paragraphs 1 through 16 above.\n22. Epstein's conduct was intentional or reckless.\n23. Epstein's conduct was outrageous, going beyond all bounds of decency.\n24. Epstein's conduct caused severe emotional distress not only to Jane Doe, but also to her parents, Jane Doe's Father and Jane Doe's Stepmother. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe's parents.\n25. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe mental anguish and pain.\nWHEREFORE, Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother demand judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper.\nCOUNT III\nLoss of Parental Consortium\n26. Plaintiff Jane Doe's Father repeats and realleges paragraphs 1 through 16 above.\n27. Epstein's tortious conduct is the direct and proximate cause of damages to Jane Doe's Father, consisting of parental loss of comfort, companionship and society and healthcare costs\nHerman & Mermelstein, P.A.\nwww.hermanlaw.com\n- 5 -\nPage 84 of 114\nPublic Records Request No.: 17-295\n07/26/17\nDOJ-OGR-00030437",
  "text_blocks": [
    {
      "type": "printed",
      "content": "COUNT II\nIntentional Infliction of Emotional Distress",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "21. Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother, individually, repeat and reallege paragraphs 1 through 16 above.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "WHEREFORE, Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother demand judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "COUNT III\nLoss of Parental Consortium",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Herman & Mermelstein, P.A.\nwww.hermanlaw.com",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "- 5 -\nPage 84 of 114\nPublic Records Request No.: 17-295\n07/26/17\nDOJ-OGR-00030437",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jane Doe",
      "Jane Doe's Father",
      "Jane Doe's Stepmother",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "Herman & Mermelstein, P.A."
    ],
    "locations": [],
    "dates": [
      "07/26/17"
    ],
    "reference_numbers": [
      "17-295",
      "DOJ-OGR-00030437"
    ]
  },
  "additional_notes": "The document appears to be a legal filing related to a case involving Jeffrey Epstein and Jane Doe. The text is mostly printed, with no visible handwriting or stamps. The document is page 84 of 114 and is part of a public records request."
}