054.pdf
365 KB
Extraction Summary
6
People
4
Organizations
2
Locations
1
Events
4
Relationships
3
Quotes
Document Information
Type:
Legal document (stipulated confidentiality agreement and protective order)
File Size:
365 KB
Summary
This document is a Stipulated Confidentiality Agreement and Protective Order filed on May 21, 2020, in the case of Jane Doe 1000 v. The Estate of Jeffrey Epstein. It establishes strict protocols for handling confidential discovery materials, including medical records, financial data, and the identities of minor victims, to protect privacy during litigation. The order outlines procedures for designating information as confidential, limits who may view such materials, and provides a Non-Disclosure Agreement form (Exhibit A) for third parties.
People (6)
| Name | Role | Context |
|---|---|---|
| Jane Doe 1000 | Plaintiff |
Plaintiff in the civil case against the Epstein Estate.
|
| Darren K. Indyke | Defendant |
Co-Executor of the Estate of Jeffrey Edward Epstein.
|
| Richard D. Kahn | Defendant |
Co-Executor of the Estate of Jeffrey Edward Epstein.
|
| Jeffrey Edward Epstein | Deceased/Subject |
The estate being sued; subject of the records.
|
| Bennet J. Moskowitz | Attorney |
Counsel for Defendants (Indyke and Kahn) from Troutman Sanders LLP.
|
| Sigrid McCawley | Attorney |
Counsel for Plaintiff (Jane Doe 1000) from Boies Schiller Flexner LLP.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States District Court For The Southern District Of New York |
Jurisdiction where the case is filed.
|
|
| Estate of Jeffrey Edward Epstein |
The legal entity representing the deceased defendant.
|
|
| Troutman Sanders LLP |
Legal counsel for the Defendants.
|
|
| Boies Schiller Flexner LLP |
Legal counsel for the Plaintiff.
|
Timeline (1 events)
2020-05-21
Stipulated Confidentiality Agreement and Protective Order filed and signed by counsel for both parties.
New York, New York
Locations (2)
| Location | Context |
|---|---|
|
Location of the Court and Troutman Sanders LLP office.
|
|
|
Location of Boies Schiller Flexner LLP office.
|
Relationships (4)
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Signed as 'Counsel for Defendants Darren K. Indyke and Richard D. Kahn'
Signed as 'Counsel for Plaintiff Jane Doe 1000'
Key Quotes (3)
"IT IS HEREBY ORDERED that the Parties to this action, their respective agents, employees, and attorneys, any other person in active concert or participation with any of the foregoing, and all other persons with actual notice of this Order will adhere to the following terms, upon pain of contempt"Source
054.pdf
Quote #1
"The Producing Party may designate as Confidential only the portion of such material that it reasonably and in good faith believes consists of: (a) medical, mental health and/or other health care records; (b) information concerning Plaintiff’s real name or personal details that could result in the disclosure of Plaintiff’s identity; (c) Social Security numbers, personal telephone numbers, tax returns, and credit and banking information of any person; (d) names of alleged minor victims of sexual abuse"Source
054.pdf
Quote #2
"Nothing in this Order shall be construed as superseding or limiting the Order and/or Stipulation concerning Plaintiff’s Anonymity entered or to be entered in this case."Source
054.pdf
Quote #3
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