051.pdf
381 KB
Extraction Summary
6
People
2
Organizations
2
Locations
3
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal correspondence (letter motion reply)
File Size:
381 KB
Summary
This document is a legal letter filed on May 11, 2020, by attorney Sigrid S. McCawley on behalf of Plaintiff Jane Doe 1000 in her case against Epstein estate executors Darren K. Indyke and Richard D. Kahn. The letter requests a court conference to address the Defendants' alleged failure to participate in discovery, specifically noting their refusal to produce documents regarding Epstein's broader sex-trafficking conspiracy and failure to answer interrogatories regarding Epstein's email accounts. The Plaintiff argues that the Defendants are engaging in intentional delay tactics.
People (6)
| Name | Role | Context |
|---|---|---|
| Sigrid S. McCawley | Attorney |
Author of the letter, partner at Boies Schiller Flexner LLP representing Plaintiff.
|
| Debra Freeman | Judge |
Honorable Magistrate Judge addressed in the letter.
|
| Jane Doe 1000 | Plaintiff |
The party bringing the suit alleging abuse.
|
| Darren K. Indyke | Defendant |
Named defendant in the case caption (Executor of Epstein Estate).
|
| Richard D. Kahn | Defendant |
Named defendant in the case caption (Executor of Epstein Estate).
|
| Jeffrey Epstein | Subject |
Deceased; referenced regarding his 'sex-trafficking conspiracy' and email accounts.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Boies Schiller Flexner LLP |
Law firm representing the Plaintiff.
|
|
| United States District Court |
Southern District of New York (implied by address 500 Pearl St).
|
Timeline (3 events)
2020-04-27
Meet and confer where Defendants did not send attorneys involved in drafting objections
Unknown
Plaintiff's Counsel
Defendants' Counsel
2020-05-05
Meet and confer between parties
Unknown (likely telephonic)
Plaintiff's Counsel
Defendants' Counsel
Locations (2)
| Location | Context |
|---|---|
|
Address of the recipient court.
|
|
|
Address of Boies Schiller Flexner LLP.
|
Relationships (3)
We submit on behalf of Plaintiff Jane Doe 1000...
documents concerning Jeffrey Epstein’s sex-trafficking conspiracy... surrounding the specific dates on which she was abused.
Named Defendant in suit involving Epstein's estate/conspiracy.
Key Quotes (4)
"Defendants refuse to produce documents concerning Jeffrey Epstein’s sex-trafficking conspiracy."Source
051.pdf
Quote #1
"Instead, they offer to produce only documents that directly mention Plaintiff’s name, and documents only from limited time periods surrounding the specific dates on which she was abused."Source
051.pdf
Quote #2
"Identify all email accounts used by Epstein or any of his employees or agents on his behalf"Source
051.pdf
Quote #3
"Defendants claim that they 'expect' to be able to 'supplement' their interrogatory responses by May 13."Source
051.pdf
Quote #4
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