037.pdf
2.3 MB
Extraction Summary
10
People
3
Organizations
3
Locations
6
Events
6
Relationships
3
Quotes
Document Information
Type:
Legal correspondence / motion to compel
File Size:
2.3 MB
Summary
This document is a letter from Sigrid S. McCawley, representing Plaintiff Teresa Helm, to Judge Debra Freeman, requesting a pre-motion conference to compel Defendants Darren K. Indyke and Richard D. Kahn (Epstein's lawyer and accountant) to produce discovery documents and respond to interrogatories. The letter details Defendants' failure to comply with discovery obligations, including not producing any documents and improperly limiting the relevant time period for discovery, despite allegations that Jeffrey Epstein operated a decades-long sex-trafficking scheme and sexually assaulted the Plaintiff in 2002.
People (10)
| Name | Role | Context |
|---|---|---|
| Sigrid S. McCawley | Attorney |
Author of the letter, representing Teresa Helm
|
| Debra Freeman | Honorable Judge |
Recipient of the letter
|
| Teresa Helm | Plaintiff |
The case plaintiff, alleging sex trafficking and assault by Jeffrey Epstein
|
| Darren K. Indyke | Defendant / Epstein's longtime lawyer |
Defendant in the case, also described as Epstein's longtime lawyer and co-conspirator
|
| Richard D. Kahn | Defendant / Epstein's longtime accountant |
Defendant in the case, also described as Epstein's longtime accountant
|
| Jeffrey Epstein | Perpetrator |
Alleged operator of a sex-trafficking scheme, accused of sexually assaulting Teresa Helm
|
| B. Moskowitz | Attorney |
Sent a letter to S. McCawley on Feb 3, 2020, representing Defendants
|
| Ghislaine Maxwell | Associate of Epstein |
Mentioned in public records as having received help from Indyke
|
| Leslie Wexner | Associate of Epstein |
Mentioned in public records as having properties over which Indyke held power of attorney
|
| Lesley Croff | Executive Assistant |
Employed by Indyke's law practice
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| BOIES SCHILLER FLEXNER LLP |
Law firm representing Teresa Helm
|
|
| Daniel Patrick Moynihan United States Courthouse |
Location where the letter is sent
|
|
| Yahoo Finance |
Source of public record information about Epstein's lawyers
|
Timeline (6 events)
2002
Epstein sexually assaulted Teresa Helm during a massage in New York.
New York
2019-11-12
Plaintiff filed a complaint against Defendants.
Daniel Patrick Moynihan United States Courthouse
2020-01-23
Parties exchanged initial Rule 26 disclosures.
2020-03-10
Plaintiff served 68 Requests for Production and 14 Interrogatories on Defendants.
2020-04-16
Defendants served responses and objections to Plaintiff's discovery requests.
Locations (3)
| Location | Context |
|---|---|
|
Address of Boies Schiller Flexner LLP
|
|
|
Location of Daniel Patrick Moynihan United States Courthouse, where Teresa Helm was sexually assaulted
|
|
|
Origin of Teresa Helm for trafficking
|
Relationships (6)
Plaintiff alleges that Jeffrey Epstein ... sexually assaulted her during a massage in New York.
Darren Indyke—Epstein’s longtime lawyer who has ties to Epstein’s co-conspirators
Richard Kahn—Epstein’s longtime accountant who assisted him for years with both personal and professional accounting work
Indyke for example, helped Ghislaine Maxwell buy her townhouse
held a power of attorney over one of Leslie Wexner’s properties
employed Lesley Croff as an executive assistant for his law practice
Key Quotes (3)
"Defendants have improperly objected to the Relevant Period that Plaintiff defined in her discovery requests as January 1, 2002 to the present. Without providing any legal basis for their position, Defendants contend that the relevant time period should be limited to the year of Plaintiff’s sexual assault as alleged in the Complaint."Source
037.pdf
Quote #1
"Defendants have refused, without providing any legal basis for doing so, to produce any document that does not directly reference Plaintiff, regardless of the year."Source
037.pdf
Quote #2
"This is despite the fact that Defendant Kahn was Epstein’s longtime accountant and likely knows who was on Epstein’s payroll. This total failure to answer even basic questions about the location of documents and potential witnesses is egregious."Source
037.pdf
Quote #3
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