053.pdf

1.44 MB
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Extraction Summary

21
People
5
Organizations
7
Locations
2
Events
6
Relationships
4
Quotes

Document Information

Type: Legal correspondence and interrogatory responses
File Size: 1.44 MB
Summary

This document is a legal filing in the civil case Jane Doe 1000 v. Indyke & Kahn. It includes a letter from Plaintiff's counsel arguing that the Epstein Estate executors are improperly limiting discovery to a 4-year period and refusing to produce documents regarding Epstein's broader sex-trafficking conspiracy. Attached as Exhibit A are the Defendants' supplemental responses to interrogatories, which list specific employees (including Ghislaine Maxwell, Sarah Kellen, and pilots like Larry Visoski), email accounts used by Epstein (specifically noting 'jeevacation@gmail.com' and 'jeeproject@yahoo.com'), and numerous phone numbers associated with his properties in New York, Palm Beach, New Mexico, and the Virgin Islands.

People (21)

Name Role Context
Jane Doe 1000 Plaintiff
Victim suing Epstein estate executors 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
Sigrid S. McCawley Attorney
Boies Schiller Flexner LLP, attorney for Plaintiff
Debra Freeman Judge
The Honorable Debra Freeman, US Magistrate Judge
Jeffrey Epstein Decedent
Deceased sex offender, estate is being sued
Ghislaine Maxwell Associate/Employee
Identified as working at Decedent's homes; Plaintiff alleges interaction with her
Luciano Fontanilla Employee
Worked at Decedent's homes in NY and Palm Beach (Relevant Time Period)
Rosalyn Fontanilla Employee
Worked at Decedent's homes in NY and Palm Beach; stayed at 301 E 66th St
Richard Barnett Employee
Worked at Decedent's homes in NY and Palm Beach
Juan Alessi Employee
Worked at Decedent's homes in NY and Palm Beach
Maria Alessi Employee
Worked at Decedent's homes in NY and Palm Beach
Adam Perry Lang Employee
Worked at Decedent's homes in NY and Palm Beach
Lesley Groff Assistant
Identified as Decedent's assistant during Relevant Time Period
Sarah Kellen Assistant
Identified as Decedent's assistant; stayed at 301 E 66th St
David Rodgers Pilot
Provided air transportation services to Decedent
Larry Visoski Pilot
Provided air transportation services to Decedent
Larry Morrison Pilot
Provided air transportation services to Decedent
Susan Hamblin Guest/Resident
Stayed at 301 East 66th Street, NY
Mark Lundberg IT Contractor
Performed information technology work in Decedent's homes
Bennet Moskowitz Attorney
Troutman Sanders LLP, attorney for Defendants

Timeline (2 events)

2020-05-13
Defendants served Supplemental Responses to Interrogatories
New York, NY
2020-05-14
Filing of Reply Letter by Plaintiff Jane Doe 1000 regarding discovery dispute
US District Court SDNY
Sigrid S. McCawley Judge Debra Freeman

Relationships (6)

Jeffrey Epstein Employer/Employee/Associate Ghislaine Maxwell
Listed as individual believed to have worked at Decedent's homes
Jeffrey Epstein Employer/Assistant Lesley Groff
Identified as Decedent's assistant
Jeffrey Epstein Employer/Assistant Sarah Kellen
Identified as Decedent's assistant
Jeffrey Epstein Employer/Pilot David Rodgers
Provided air transportation services
Jeffrey Epstein Employer/Pilot Larry Visoski
Provided air transportation services
Jeffrey Epstein Employer/Pilot Larry Morrison
Provided air transportation services

Key Quotes (4)

"Defendants refuse to engage in discovery for more than a narrow, four-year period. This is improper, as information concerning Epstein’s abuse of other girls and young women throughout the span of his sex-trafficking conspiracy is plainly relevant"
Source
053.pdf
Quote #1
"Defendants have not produced a single document—not one."
Source
053.pdf
Quote #2
"Defendants identify the following individuals... believed to have worked at Decedent’s homes...: Luciano Fontanilla, Rosalyn Fontanilla, Richard Barnett, Ghislaine Maxwell, Juan Alessi, Maria Alessi and Adam Perry Lang."
Source
053.pdf
Quote #3
"only jeevacation@gmail.com and jeeproject@yahoo.com were actively used by Decedent himself."
Source
053.pdf
Quote #4

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