027.pdf
46.7 KB
Extraction Summary
6
People
12
Organizations
2
Locations
4
Events
5
Relationships
3
Quotes
Document Information
Type:
Legal correspondence / letter motion
File Size:
46.7 KB
Summary
A letter from defense attorney Bennet J. Moskowitz to Judge Paul A. Engelmayer in the case of Jane Doe 17 v. Estate of Jeffrey Epstein. The defense requests the court vacate a recent order granting the plaintiff anonymity, not to oppose the anonymity itself, but to ensure they have the opportunity to respond regarding the specific terms of that anonymity to protect their defense rights, citing a previous deadline of December 21, 2019.
People (6)
| Name | Role | Context |
|---|---|---|
| Bennet J. Moskowitz | Attorney |
Counsel for Defendants (Troutman Sanders LLP), author of the letter.
|
| Paul A. Engelmayer | Judge |
Addressee of the letter, presiding over the case.
|
| Jane Doe 17 | Plaintiff |
Plaintiff in the lawsuit against the Epstein Estate.
|
| Darren K. Indyke | Defendant / Co-Executor |
Co-Executor of the Estate of Jeffrey E. Epstein.
|
| Richard D. Kahn | Defendant / Co-Executor |
Co-Executor of the Estate of Jeffrey E. Epstein.
|
| Jeffrey E. Epstein | Deceased |
Mentioned as the deceased whose estate is being sued.
|
Organizations (12)
| Name | Type | Context |
|---|---|---|
| Troutman Sanders LLP |
Law firm representing the Defendants.
|
|
| United States District Court, SDNY |
Implied by 'United States Courthouse' and case details.
|
|
| Nine East 71st Street, Corporation |
Defendant entity.
|
|
| Financial Trust Company, Inc. |
Defendant entity.
|
|
| NES, LLC |
Defendant entity.
|
|
| Laurel, Inc. |
Defendant entity.
|
|
| Maple, Inc. |
Defendant entity.
|
|
| LSJE, LLC |
Defendant entity.
|
|
| HBRK Associates, Inc. |
Defendant entity.
|
|
| Nautilus, Inc. |
Defendant entity.
|
|
| Cypress, Inc. |
Defendant entity.
|
|
| JEGE, Inc. |
Defendant entity.
|
Timeline (4 events)
2019-11-05
Court Order (ECF #21) providing Defendants until Dec 21, 2019 to respond to Plaintiff's Motion.
New York, NY
2019-11-08
Court Order (ECF #25) granting Plaintiff's Motion to Proceed Anonymously.
New York, NY
2019-11-20
Letter filed by Bennet J. Moskowitz requesting the court vacate a previous order.
New York, NY
Locations (2)
| Location | Context |
|---|---|
|
Address of the United States Courthouse.
|
|
|
Address of Troutman Sanders LLP.
|
Relationships (5)
We represent Defendants Darren K. Indyke...
We represent Defendants... Richard D. Kahn...
Co-Executors of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
Jane Doe 17 v. ... Estate of Jeffrey E. Epstein
Key Quotes (3)
"Defendants do not object to Plaintiff proceeding anonymously to prevent the disclosure of her identity to the general public."Source
027.pdf
Quote #1
"Defendants seek the opportunity to be heard so the relief granted on Plaintiff’s Motion ensures Plaintiff may protect her anonymity without jeopardizing Defendants’ fundamental right to fully and fairly defend against this action."Source
027.pdf
Quote #2
"Plaintiffs’ counsel does not consent to this request."Source
027.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (2,031 characters)
Case 1:19-cv-09610-PAE-DCF Document 27 Filed 11/20/19 Page 1 of 2
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutman.com
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutman.com
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
bennet.moskowitz@troutman.com
November 20, 2019
ECF
Hon. Paul A. Engelmayer
Thurgood Marshall
United States Courthouse
40 Foley Square
New York, NY 10007
Thurgood Marshall
United States Courthouse
40 Foley Square
New York, NY 10007
Re: Jane Doe 17 v. Darren K. Indyke and Richard D. Kahn as Joint Personal Representatives of the Estate of Jeffrey E. Epstein, et al., 1:19-cv-09610 (PAE)
Dear Judge Engelmayer:
We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (named herein as “Joint Personal Representative[s] of the Estate of Jeffrey E. Epstein”), Nine East 71st Street, Corporation, Financial Trust Company, Inc., NES, LLC, Laurel, Inc., Maple, Inc., LSJE, LLC, HBRK Associates, Inc., Nautilus, Inc., Cypress, Inc., and JEGE, Inc. (together, “Defendants”) in the referenced action. We write to respectfully request that the Court vacate its Order dated November 8, 2019 (ECF #25) granting Plaintiff’s Motion to Proceed Anonymously (the “Motion”) (ECF #24) filed earlier that day. The basis for this request is that Your Honor’s Order dated November 5, 2019 (ECF #21) provides Defendants through December 21, 2019 to respond to Plaintiff’s Motion.
Defendants did not have an opportunity to respond to Plaintiff’s Motion. Defendants do not object to Plaintiff proceeding anonymously to prevent the disclosure of her identity to the general public. However, Defendants seek the opportunity to be heard so the relief granted on Plaintiff’s Motion ensures Plaintiff may protect her anonymity without jeopardizing Defendants’ fundamental right to fully and fairly defend against this action.
Plaintiffs’ counsel does not consent to this request.
Thank you for your attention to this matter.
Case 1:19-cv-09610-PAE-DCF Document 27 Filed 11/20/19 Page 2 of 2
November 20, 2019
Page 2
November 20, 2019
Page 2
Respectfully submitted,
s/Bennet J. Moskowitz
Bennet J. Moskowitz
Bennet J. Moskowitz
40665813v1
troutman
sanders
troutman
sanders
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