044.pdf

1.43 MB
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Extraction Summary

16
People
5
Organizations
7
Locations
2
Events
4
Relationships
5
Quotes

Document Information

Type: Legal filing (letter motion and supplemental interrogatory responses)
File Size: 1.43 MB
Summary

This document is a legal filing from May 2020 in the case of Teresa Helm v. The Estate of Jeffrey Epstein. It contains a letter from the Plaintiff's counsel arguing that the Estate Executors are obstructing discovery by limiting it to a narrow time window in 2002 and refusing to answer questions fully. The attached Exhibit A contains the Defendants' supplemental responses to interrogatories, in which they identify specific staff members (including Ghislaine Maxwell, Sarah Kellen, and Lesley Groff) who worked at Epstein's New York home during late 2002, list various email accounts and phone numbers associated with Epstein, and identify Shoppers Travel, Inc. as his travel agency. No specific flight logs or aircraft manifests are included in the document.

People (16)

Name Role Context
Teresa Helm Plaintiff
Victim bringing suit against the Epstein Estate for battery and intentional infliction of emotional distress.
Darren K. Indyke Defendant/Co-Executor
Co-executor of the Estate of Jeffrey Edward Epstein.
Richard D. Kahn Defendant/Co-Executor
Co-executor of the Estate of Jeffrey Edward Epstein.
Jeffrey Epstein Decedent
Deceased; alleged to have committed battery and emotional distress against Plaintiff; accused of sex trafficking cons...
Sigrid S. McCawley Attorney
Attorney for Plaintiff Teresa Helm; Boies Schiller Flexner LLP.
Bennet Moskowitz Attorney
Attorney for Defendants Indyke and Kahn; Troutman Sanders LLP.
Debra Freeman Judge
The Honorable Debra Freeman, United States Courthouse.
Ghislaine Maxwell Associate
Identified in Plaintiff's complaint; Co-Executors confirm she worked at Decedent's NY home during the Relevant Time P...
Sarah Kellen Assistant
Identified as an assistant to Epstein during the Relevant Time Period; stayed at 301 East 66th Street.
Luciano Fontanilla Staff
Worked at Decedent's home in New York during the Relevant Time Period (2002).
Rosalyn Fontanilla Staff
Worked at Decedent's home in New York during the Relevant Time Period (2002); stayed at 301 East 66th Street.
Richard Barnett Staff
Worked at Decedent's home in New York during the Relevant Time Period (2002).
Adam Perry Lang Staff
Worked at Decedent's home in New York during the Relevant Time Period (2002).
Lesley Groff Assistant
Identified as an assistant to Epstein during a portion of the Relevant Time Period.
Susan Hamblin Associate/Staff
Identified as having stayed at 301 East 66th Street for some period of time.
Mark Lundberg IT Contractor
Believed to have performed information technology work in some or all of Decedent's homes during the Relevant Time Pe...

Organizations (5)

Name Type Context
Boies Schiller Flexner LLP
Law firm representing Plaintiff Teresa Helm.
Troutman Sanders LLP
Law firm representing Defendants (Epstein Estate).
Estate of Jeffrey Edward Epstein
The legal entity being sued, managed by Co-Executors Indyke and Kahn.
Shoppers Travel, Inc.
Travel agency identified by Co-Executors as providing travel-related services to Decedent.
United States District Court Southern District of New York
The court where the case is being heard.

Timeline (2 events)

2002-06-01 to 2002-12-31
The 'Relevant Time Period' defined by Defendants for discovery, during which Plaintiff alleges she encountered Decedent.
New York, NY
2020-05-14
Plaintiff Teresa Helm files a reply letter motion regarding discovery disputes.
New York, NY
Sigrid S. McCawley Judge Debra Freeman

Locations (7)

Location Context
Epstein's residence; location where Plaintiff alleges encounters; location where Roslyn Fontanilla, Susan Hamblin, an...
General reference to the location where staff (Fontanillas, Barnett, Maxwell, Lang) worked in 2002.
Mentioned in Interrogatory No. 4 as a location of Epstein's homes.
Mentioned in Interrogatory No. 4 as a location of Epstein's homes.
Mentioned in Interrogatory No. 4 as a location of Epstein's homes.
Mentioned in Interrogatory No. 4 as a location of Epstein's homes.
Mentioned in Interrogatory No. 4 as a location of Epstein's homes.

Relationships (4)

Jeffrey Epstein Employer/Employee or Associate Ghislaine Maxwell
Co-Executors identify her as an individual believed to have worked at Decedent's home in New York during the Relevant Time Period.
Jeffrey Epstein Assistant Sarah Kellen
Identified as Decedent's assistant during a portion of the Relevant Time Period.
Jeffrey Epstein Assistant Lesley Groff
Identified as Decedent's assistant during a portion of the Relevant Time Period.
Jeffrey Epstein Contractor Mark Lundberg
Believed to have performed information technology work in some or all of Decedent's homes.

Key Quotes (5)

"Defendants refuse to engage in discovery for more than a narrow, less than one-year period in 2002."
Source
044.pdf
Quote #1
"Defendants deride Plaintiff’s allegations as a 'sex trafficking scheme–which,' according to Defendants, 'is based on unproven allegations in the S.D.N.Y.’s 2019 indictment of Mr. Epstein.'"
Source
044.pdf
Quote #2
"Co-Executors identify the following individuals, believed to have worked at Decedent’s home in New York...: Luciano Fontanilla, Rosalyn Fontanilla, Richard Barnett, Ghislaine Maxwell and Adam Perry Lang."
Source
044.pdf
Quote #3
"Subject to and without waiving the foregoing objections, Co-Executors identify Lesley Groff and Sarah Kellen, who were Decedent’s assistants during a portion of the Relevant Time Period."
Source
044.pdf
Quote #4
"Subject to and without waiving the foregoing objections, Co-Executors identify Shoppers Travel, Inc., which is a travel agency that provided travel-related services to Decedent at certain times"
Source
044.pdf
Quote #5

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