046.pdf
2.27 MB
Extraction Summary
19
People
11
Organizations
8
Locations
3
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal filing / discovery correspondence
File Size:
2.27 MB
Summary
This document is a legal filing from Plaintiff Jane Doe 1000's counsel requesting a pre-motion conference to compel Defendants (Epstein's executors Indyke and Kahn) to produce discovery documents and answer interrogatories. The filing includes exhibits of the discovery requests, which seek detailed information on Epstein's flight logs, financial transactions, communications with high-profile individuals (Prince Andrew, Bill Clinton, Alan Dershowitz), and the structure of his alleged sex-trafficking operation. The Defendants have objected to almost all requests, claiming they are overbroad or that they lack knowledge because Epstein is deceased, prompting the Plaintiff to seek court intervention. Note: While flight logs are requested, no actual flight data is contained in this document.
People (19)
| Name | Role | Context |
|---|---|---|
| Jane Doe 1000 | Plaintiff |
Victim/Survivor suing Epstein's estate
|
| Darren K. Indyke | Defendant / Co-Executor |
Epstein's longtime lawyer and co-executor of his estate
|
| Richard D. Kahn | Defendant / Co-Executor |
Epstein's longtime accountant and co-executor of his estate
|
| Jeffrey Epstein | Deceased / Alleged Trafficker |
The central figure in the sex-trafficking scheme allegations
|
| Sigrid S. McCawley | Plaintiff's Attorney |
Partner at Boies Schiller Flexner LLP
|
| Bennet J. Moskowitz | Defendants' Attorney |
Attorney at Troutman Sanders LLP
|
| Ghislaine Maxwell | Alleged Co-Conspirator |
Mentioned in discovery requests and as a recipient of payments/loans
|
| Sarah Kellen | Alleged Co-Conspirator / Employee |
Mentioned in discovery requests regarding recruitment and scheduling
|
| Andrew Albert Christian Edward (Duke of York / Prince Andrew) | Person of Interest |
Subject of Interrogatory No. 9 and RFP No. 70 regarding his presence at Epstein's residences
|
| Alan Dershowitz | Person of Interest |
Subject of Interrogatory No. 10 and RFPs 54-58 regarding his presence at Epstein's residences and communications
|
| William 'Bill' J. Clinton | Person of Interest |
Subject of Interrogatory No. 11 and RFP No. 62 regarding his presence at Epstein's residences/planes
|
| Leslie Wexner | Person of Interest |
Subject of RFPs 64-66 regarding business transactions and relationships
|
| Abigail Wexner | Person of Interest |
Subject of RFPs 64-65
|
| Lesley Groff | Employee/Associate |
Mentioned in RFP No. 20 regarding payments
|
| Nadia Marcinkova | Employee/Associate |
Mentioned in RFP No. 20 regarding payments
|
| Adriana Ross | Employee/Associate |
Mentioned in RFP No. 20 regarding payments
|
| Cecilia Steen | Employee/Associate |
Mentioned in RFP No. 23 regarding employment
|
| Jean-Luc Brunel | Associate |
Mentioned in RFP No. 23 and 61 regarding modeling
|
| Alexander Acosta | Government Official |
Mentioned in RFP No. 74 regarding communications with US Attorney's Office
|
Organizations (11)
Timeline (3 events)
April 27, 2020
Meet and confer telephone call regarding discovery deficiencies
Telephone
Locations (8)
Relationships (3)
Described as Epstein's longtime lawyer and co-executor of his estate
Described as Epstein's longtime accountant and co-executor of his estate
Mentioned as co-conspirator and subject of discovery requests regarding recruitment
Key Quotes (4)
"Yet by failing to comply with their clear and unequivocal discovery obligations, including not producing a single document to date, Defendants are attempting to grant themselves a de facto stay of discovery."Source
046.pdf
Quote #1
"Plaintiff alleges that Jeffrey Epstein and his co-conspirators operated a decades-long sex-trafficking scheme by which they recruited young women for sexual abuse."Source
046.pdf
Quote #2
"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
046.pdf
Quote #3
"Defendants stated that they do not have responsive information because Epstein is dead and Defendants do not know where to look for responsive information."Source
046.pdf
Quote #4
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