010.pdf
221 KB
Extraction Summary
13
People
5
Organizations
3
Locations
6
Events
4
Relationships
3
Quotes
Document Information
Type:
Legal correspondence / court filing
File Size:
221 KB
Summary
A joint letter dated January 10, 2020, from legal counsel representing plaintiffs (victims) and defendants (Epstein Estate executors) to Judge Debra Freeman. The letter provides a status update on discovery schedules and settlement discussions, specifically noting the development of a Victims' Compensation Program awaiting approval in the US Virgin Islands. The parties request a court conference in early February 2020.
People (13)
| Name | Role | Context |
|---|---|---|
| Debra Freeman | Judge |
Recipient of the letter, United States Magistrate Judge.
|
| Juliette Bryant | Plaintiff |
Plaintiff in case 19-10479 against the Epstein Estate.
|
| 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.
|
| Jeffrey Edward Epstein | Deceased / Estate |
Estate is the defendant in multiple lawsuits.
|
| Jane Doe 1000 | Plaintiff |
Plaintiff in case 19-10577 against the Epstein Estate.
|
| Annie Farmer | Plaintiff |
Plaintiff in case 19-10475 against the Epstein Estate and Ghislaine Maxwell.
|
| Ghislaine Maxwell | Defendant |
Named defendant in case 19-10475 alongside the Estate.
|
| Teresa Helm | Plaintiff |
Plaintiff in case 19-10476 against the Epstein Estate.
|
| Joshua I. Schiller | Attorney |
Signatory, Boies Schiller Flexner LLP, representing Plaintiffs.
|
| David Boies | Attorney |
Boies Schiller Flexner LLP, representing Plaintiffs.
|
| Sigrid S. McCawley | Attorney |
Boies Schiller Flexner LLP, representing Plaintiffs.
|
| Bennet J. Moskowitz | Attorney |
Signatory, Troutman Sanders LLP, representing Defendants (Estate).
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Boies Schiller Flexner LLP |
Law firm representing the Plaintiffs.
|
|
| Troutman Sanders LLP |
Law firm representing the Defendants (Epstein Estate).
|
|
| United States District Court Southern District of New York |
Court where the letter is filed.
|
|
| Superior Court of the United States Virgin Islands |
Court hearing the motion to approve the Victims' Compensation Program.
|
|
| Estate of Jeffrey Edward Epstein |
Defendant entity.
|
Timeline (6 events)
2020-02-04
Hearing to approve the establishment of the Victims' Compensation Program
United States Virgin Islands
Estate Executors
Superior Court of the USVI
2020-02-06
Proposed Conference with the Court (Option 1)
New York, NY
Plaintiffs
Defendants
Judge Freeman
2020-02-07
Proposed Conference with the Court (Option 2)
New York, NY
Plaintiffs
Defendants
Judge Freeman
Locations (3)
| Location | Context |
|---|---|
|
Location of the courthouse and law firm.
|
|
|
Jurisdiction reviewing the Victims' Compensation Program.
|
|
|
Address of United States Courthouse.
|
Relationships (4)
Described as 'Co-Executors of the Estate of Jeffrey Edward Epstein'
Described as 'Co-Executors of the Estate of Jeffrey Edward Epstein'
Signatory for Plaintiffs (implied by context of Boies Schiller representing victims in listed cases)
Signatory for Defendants (Troutman Sanders LLP)
Key Quotes (3)
"Defendants have arranged for a Victims’ Compensation Program that will be available to Plaintiffs."Source
010.pdf
Quote #1
"The motion for the Superior Court of the United States Virgin Islands to approve the establishment of the Program will be heard on February 4, 2020."Source
010.pdf
Quote #2
"The parties have thus far engaged in two productive conferences pursuant to Rule 26(f) of the Federal Rules of Civil Procedure."Source
010.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (2,691 characters)
Case 1:19-cv-10479-ALC-DCF Document 10 Filed 01/10/20 Page 1 of 2
BSF BOIES
SCHILLER
FLEXNER
BSF BOIES
SCHILLER
FLEXNER
January 10, 2020
VIA ECF
The Honorable Debra Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re: Juliette Bryant v. Darren K. Indyke and Richard D. Kahn, in their capacities as
executors of the Estate of Jeffrey Edward Epstein, 19-10479
Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn, in their capacities as
executors of the Estate of Jeffrey Edward Epstein, 19-10577
Annie Farmer v. Darren K. Indyke and Richard D. Kahn, in their capacities as
executors of the Estate of Jeffrey Edward Epstein, and Ghislaine Maxwell, 19-
10475
Teresa Helm v. Darren K. Indyke and Richard D. Kahn, in their capacities as
executors of the Estate of Jeffrey Edward Epstein, 19-10476
executors of the Estate of Jeffrey Edward Epstein, 19-10479
Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn, in their capacities as
executors of the Estate of Jeffrey Edward Epstein, 19-10577
Annie Farmer v. Darren K. Indyke and Richard D. Kahn, in their capacities as
executors of the Estate of Jeffrey Edward Epstein, and Ghislaine Maxwell, 19-
10475
Teresa Helm v. Darren K. Indyke and Richard D. Kahn, in their capacities as
executors of the Estate of Jeffrey Edward Epstein, 19-10476
Dear Judge Freeman:
Pursuant to the Court’s request at the November 21, 2019, Case Management Conference,
Plaintiffs and Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of
Jeffrey E. Epstein, jointly submit this letter to provide the Court with an update as to the progress
of discussions regarding both discovery and settlement.
Plaintiffs and Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of
Jeffrey E. Epstein, jointly submit this letter to provide the Court with an update as to the progress
of discussions regarding both discovery and settlement.
The parties have thus far engaged in two productive conferences pursuant to Rule 26(f) of
the Federal Rules of Civil Procedure. During those conferences, the parties agreed to exchange
initial disclosures by January 23, 2020, and to exchange discovery plans one week thereafter, on
January 30, 2020.
the Federal Rules of Civil Procedure. During those conferences, the parties agreed to exchange
initial disclosures by January 23, 2020, and to exchange discovery plans one week thereafter, on
January 30, 2020.
As the Court is aware, Defendants have arranged for a Victims’ Compensation Program
that will be available to Plaintiffs. Plaintiffs’ counsel has conferred with the Program’s designers
and administrators, the Program’s administrators provided Plaintiffs with a proposed protocol for
the Program, and Plaintiffs have provided some feedback to the administrators. The motion for
the Superior Court of the United States Virgin Islands to approve the establishment of the Program
will be heard on February 4, 2020.
that will be available to Plaintiffs. Plaintiffs’ counsel has conferred with the Program’s designers
and administrators, the Program’s administrators provided Plaintiffs with a proposed protocol for
the Program, and Plaintiffs have provided some feedback to the administrators. The motion for
the Superior Court of the United States Virgin Islands to approve the establishment of the Program
will be heard on February 4, 2020.
The parties request a conference with the Court on February 6 or 7, 2020, to resolve any
potential disagreements as to how these matters should proceed. The parties will provide the Court
with their proposed discovery plan(s) 48 hours before any such conference.
potential disagreements as to how these matters should proceed. The parties will provide the Court
with their proposed discovery plan(s) 48 hours before any such conference.
BOIES SCHILLER FLEXNER LLP
55 Hudson Yards, New York, NY 10001 | (t) 212.446.2300 | (f) 212.446.2350 | www.bsfllp.com
55 Hudson Yards, New York, NY 10001 | (t) 212.446.2300 | (f) 212.446.2350 | www.bsfllp.com
Case 1:19-cv-10479-ALC-DCF Document 10 Filed 01/10/20 Page 2 of 2
BSF
BSF
Respectfully submitted,
/s/ Joshua I. Schiller
David Boies, Esq.
Joshua I. Schiller, Esq.
Sigrid S. McCawley, Esq.
Boies Schiller Flexner LLP
David Boies, Esq.
Joshua I. Schiller, Esq.
Sigrid S. McCawley, Esq.
Boies Schiller Flexner LLP
/s/ Bennet J. Moskowitz
Bennet J. Moskowitz, Esq.
Troutman Sanders LLP
Bennet J. Moskowitz, Esq.
Troutman Sanders LLP
cc: Counsel of Record (via ECF)
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