054.pdf
24.5 KB
Extraction Summary
6
People
7
Organizations
3
Locations
3
Events
4
Relationships
3
Quotes
Document Information
Type:
Legal filing (joint proposed discovery schedule)
File Size:
24.5 KB
Summary
This document is a Joint Proposed Discovery Schedule filed on February 6, 2020, in the case of VE v. Indyke et al. It outlines the agreed-upon timeline for the exchange of evidence, including initial disclosures, medical records, and expert reports. The filing identifies the key subjects of discovery as Epstein's alleged torts against the plaintiff, the liability of the corporate defendants, and the plaintiff's damages.
People (6)
| Name | Role | Context |
|---|---|---|
| VE | Plaintiff |
Plaintiff in the civil suit against the Epstein Estate.
|
| Darren K. Indyke | Defendant |
Joint Personal Representative/Co-Executor of the Estate of Jeffrey E. Epstein.
|
| Richard D. Kahn | Defendant |
Joint Personal Representative/Co-Executor of the Estate of Jeffrey E. Epstein.
|
| Jeffrey E. Epstein | Deceased |
Mentioned regarding his estate and alleged torts committed against the Plaintiff.
|
| Brad Edwards | Attorney |
Attorney for Plaintiff, Edwards Pottinger LLC.
|
| Bennet J. Moskowitz | Attorney |
Attorney for Defendants, Troutman Sanders LLP.
|
Timeline (3 events)
2020-01-23
Plaintiff and Co-Executors served initial disclosures
New York
Plaintiff
Co-Executors
2020-02-06
Locations (3)
| Location | Context |
|---|---|
|
Jurisdiction
|
|
|
Address for Edwards Pottinger LLC
|
|
|
Address for Troutman Sanders LLP
|
Relationships (4)
Reference to 'Mr. Epstein’s alleged torts committed against Plaintiff'
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Signed as 'Attorney for Plaintiff'
Key Quotes (3)
"discovery may be needed on the following subjects: (1) Mr. Epstein’s alleged torts committed against Plaintiff; (2) the alleged liability of any Corporate Defendant for the alleged acts of Mr. Epstein; and (3) Plaintiff’s alleged damages."Source
054.pdf
Quote #1
"Plaintiff shall provide HIPAA-compliant medical records release authorizations to Defendants"Source
054.pdf
Quote #2
"Defendants will provide Plaintiff with a standard, proposed electronically stored information (“ESI”) protocol"Source
054.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (4,107 characters)
Case 1:19-cv-07625-AJN-DCF Document 54 Filed 02/06/20 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X
VE,
SOUTHERN DISTRICT OF NEW YORK
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X
VE,
Plaintiff,
v.
DARREN K. INDYKE AND RICHARD D.
KAHN, AS JOINT PERSONAL
REPRESENTATIVES OF THE ESTATE OF
JEFFREY E. EPSTEIN, NINE EAST 71st
STREET, CORPORATION, FINANCIAL
TRUST COMPANY, INC., NES, LLC,
KAHN, AS JOINT PERSONAL
REPRESENTATIVES OF THE ESTATE OF
JEFFREY E. EPSTEIN, NINE EAST 71st
STREET, CORPORATION, FINANCIAL
TRUST COMPANY, INC., NES, LLC,
Defendants.
:
:
:
:
:
:
:
:
:
:
:
:
:
:
Index No. 1:19-cv-07625-AJN-DCF
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X
:
:
:
:
:
:
:
:
:
:
:
:
:
Index No. 1:19-cv-07625-AJN-DCF
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X
JOINT PROPOSED DISCOVERY SCHEDULE
Pursuant to the Court’s Order dated January 14, 2020 and Rule 26(f)(3) of the Federal
Rule of Civil Procedure, Plaintiff VE and Defendants Darren K. Indyke and Richard D. Kahn,
Co-Executors of the Estate of Jeffrey E. Epstein (together, the “Co-Executors”), Nine East 71st
Street, Corporation, Financial Trust Company, Inc, and NES, LLC (together the “Corporate
Defendants”, and together with the Co-Executors, the “Defendants”; and the Defendants together
with the Plaintiff, the “Parties”) hereby jointly submit the following proposed discovery
schedule:
Rule of Civil Procedure, Plaintiff VE and Defendants Darren K. Indyke and Richard D. Kahn,
Co-Executors of the Estate of Jeffrey E. Epstein (together, the “Co-Executors”), Nine East 71st
Street, Corporation, Financial Trust Company, Inc, and NES, LLC (together the “Corporate
Defendants”, and together with the Co-Executors, the “Defendants”; and the Defendants together
with the Plaintiff, the “Parties”) hereby jointly submit the following proposed discovery
schedule:
1. The Corporate Defendants¹ shall serve their initial disclosures pursuant to Rule
26(a)(1) no later than February 13, 2020;
26(a)(1) no later than February 13, 2020;
2. Plaintiff shall provide HIPAA-compliant medical records release authorizations to
Defendants no later than 14 days from the request therefor;
Defendants no later than 14 days from the request therefor;
3. The Parties shall serve initial document requests and interrogatories no later than 30
days from the Court’s entry of the discovery schedule;
days from the Court’s entry of the discovery schedule;
___________________
¹ Plaintiff and the Co-Executors served their initial disclosures on January 23, 2020.
1
¹ Plaintiff and the Co-Executors served their initial disclosures on January 23, 2020.
1
41355874v2
Case 1:19-cv-07625-AJN-DCF Document 54 Filed 02/06/20 Page 2 of 3
4. Any motion for joinder of other parties or amendment of the pleadings shall be made
no later than 45 days from the Court’s entry of the discovery schedule;
no later than 45 days from the Court’s entry of the discovery schedule;
5. Fact discovery shall be completed no later than 140 days from the Court’s entry of
the discovery schedule;
the discovery schedule;
6. Expert disclosures and expert discovery shall be completed no later than 200 days
from the Court’s entry of the discovery schedule; and
from the Court’s entry of the discovery schedule; and
7. The Parties shall have 30 days from the service of an expert’s initial report to serve a
rebuttal report.
rebuttal report.
At this time, the Parties anticipate that discovery may be needed on the following
subjects: (1) Mr. Epstein’s alleged torts committed against Plaintiff; (2) the alleged liability of
any Corporate Defendant for the alleged acts of Mr. Epstein; and (3) Plaintiff’s alleged damages.
subjects: (1) Mr. Epstein’s alleged torts committed against Plaintiff; (2) the alleged liability of
any Corporate Defendant for the alleged acts of Mr. Epstein; and (3) Plaintiff’s alleged damages.
Within 14 days from the Court’s entry of the discovery schedule, Defendants will provide
Plaintiff with a standard, proposed electronically stored information (“ESI”) protocol in order to
address any issues about disclosure, discovery, or preservation of ESI, including the form or
forms in which it should be produced.
Plaintiff with a standard, proposed electronically stored information (“ESI”) protocol in order to
address any issues about disclosure, discovery, or preservation of ESI, including the form or
forms in which it should be produced.
Within 14 days from the Court’s entry of the discovery schedule, Defendants will provide
Plaintiff with a proposed protective order, with standard clawback provisions, to address any
issues about claims of privilege or of protection as trial-preparation materials.
Plaintiff with a proposed protective order, with standard clawback provisions, to address any
issues about claims of privilege or of protection as trial-preparation materials.
At this time, the Parties have no proposed changes to the limitations on discovery
imposed by the Federal Rules of Civil Procedure or by the Local Rules of the United States
District Court for the Southern District of New York.
imposed by the Federal Rules of Civil Procedure or by the Local Rules of the United States
District Court for the Southern District of New York.
With the exception of the protective order mentioned above, the Parties are not currently
aware of any other orders that the Court should issue under Rule 26(c) or under Rule 16(b)
and (c).
aware of any other orders that the Court should issue under Rule 26(c) or under Rule 16(b)
and (c).
2
41355874v2
Case 1:19-cv-07625-AJN-DCF Document 54 Filed 02/06/20 Page 3 of 3
The Parties respectfully request that the Court enter this joint proposed discovery
schedule in this matter.
schedule in this matter.
Dated: New York, New York
February 6, 2020
February 6, 2020
By: /s/ Brad Edwards
Brad Edwards
EDWARDS POTTINGER LLC
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Brad Edwards
EDWARDS POTTINGER LLC
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Attorney for Plaintiff
By: /s/ Bennet J. Moskowitz
Bennet J. Moskowitz
TROUTMAN SANDERS LLP
875 Third Avenue
New York, New York 10022
Bennet J. Moskowitz
TROUTMAN SANDERS LLP
875 Third Avenue
New York, New York 10022
Attorney for Defendants
3
41355874v2
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document