045.pdf
357 KB
Extraction Summary
7
People
6
Organizations
3
Locations
3
Events
4
Relationships
5
Quotes
Document Information
Type:
Plaintiff's memorandum of law in opposition to defendants' motions to dismiss
File Size:
357 KB
Summary
This document is a Plaintiff's Memorandum of Law opposing a Motion to Dismiss in the case of VE v. Indyke et al. The plaintiff, a victim of Jeffrey Epstein's sexual abuse beginning in 2001 at age 16, argues that the corporate defendants (Nine East 71st Street Corp, Financial Trust Company, and NES LLC) are liable for negligence, negligent security, and negligent supervision. The memorandum asserts these entities were integral to Epstein's sex trafficking enterprise, with employees facilitating the recruitment and scheduling of victims, and argues that claims are valid under the New York Child Victims Act.
People (7)
| Name | Role | Context |
|---|---|---|
| VE | Plaintiff |
Victim of sexual abuse by Jeffrey Epstein beginning in 2001 when she was 16 years old.
|
| Jeffrey Epstein | Perpetrator/Deceased |
Accused of sexually abusing the plaintiff; owner/officer of defendant corporations; engaged in sex trafficking conspi...
|
| Darren K. Indyke | Defendant |
Joint Personal Representative of the Estate of Jeffrey E. Epstein.
|
| Richard D. Kahn | Defendant |
Joint Personal Representative of the Estate of Jeffrey E. Epstein.
|
| Bradley J. Edwards | Attorney |
Counsel for Plaintiff VE, Edwards Pottinger, LLC.
|
| Brittany N. Henderson | Attorney |
Counsel for Plaintiff VE, Edwards Pottinger, LLC.
|
| Stanley J. Pottinger | Attorney |
Counsel for Plaintiff VE, Edwards Pottinger, LLC.
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| Estate of Jeffrey E. Epstein |
Sued for battery and negligence.
|
|
| Nine East 71st Street, Corporation |
Owner of the mansion in Manhattan where abuse occurred; accused of negligent security.
|
|
| Financial Trust Company, Inc. |
Employer of Jeffrey Epstein; accused of negligent supervision/retention.
|
|
| NES, LLC |
Staffing/logistics entity; employees allegedly procured victims and managed Epstein's massage schedule.
|
|
| United States District Court Southern District of New York |
Venue of the legal filing.
|
|
| Edwards Pottinger, LLC |
Representing the plaintiff.
|
Timeline (3 events)
2001
Plaintiff VE was sexually abused by Jeffrey Epstein at age sixteen.
Nine East 71st Street, Manhattan, New York
2019-07-02
US Attorney's Office filed a Sealed Two Count Indictment against Jeffrey Epstein for Sex Trafficking.
Southern District of New York
Jeffrey Epstein
US Attorney's Office
2019-08-27
Locations (3)
| Location | Context |
|---|---|
|
Epstein's mansion where the plaintiff was recruited to provide massages and was sexually abused.
|
|
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Domicile of the Estate of Jeffrey Epstein.
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|
|
Address of Plaintiff's counsel.
|
Relationships (4)
Complaint alleges VE was sexually abused by Epstein starting at age 16.
Document states Financial Trust Company employed Jeffrey Epstein.
Epstein used the mansion owned by Nine East for his trafficking operation.
NES employees operated at the direction of Epstein to fulfill his daily massage schedule and procure victims.
Key Quotes (5)
"In 2001, Plaintiff was sexually abused by Jeffrey Epstein when she was only sixteen years old."Source
045.pdf
Quote #1
"Defendant Financial Trust operated in part to satisfy the personal needs of Jeffrey Epstein, which included daily massages which Epstein requires to be sexual in nature."Source
045.pdf
Quote #2
"Jeffrey Epstein was notorious for converting each massage into a sexually exploitive activity in violation of New York Penal Law Section 130..."Source
045.pdf
Quote #3
"Plaintiff observed the opulence of the mansion owned by Defendant, Nine East, and the organization of Defendant, NES, Inc., which collectively facilitated her further cooperation with Jeffrey Epstein..."Source
045.pdf
Quote #4
"Employees of Defendants who worked at the residences where he committed sexual violations as well as others who assisted him in committing such violations, were employed through, or worked for, the corporate entities named herein..."Source
045.pdf
Quote #5
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