026.pdf
75.8 KB
Extraction Summary
9
People
3
Organizations
1
Locations
3
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal filing (discovery plan and proposed scheduling order)
File Size:
75.8 KB
Summary
This document is a Discovery Plan and Proposed Scheduling Order filed on February 6, 2020, in the case of Jane Doe 1000 v. The Estate of Jeffrey Epstein. The Plaintiff requests broad discovery including flight logs, financial records, Amazon history, and communications with government officials and co-conspirators, while the Co-Executors attempt to limit the scope strictly to the Plaintiff's alleged abuse. The document outlines proposed deadlines for document requests, HIPAA releases, and expert discovery, noting significant disagreements between the parties on the timing of these phases.
People (9)
| Name | Role | Context |
|---|---|---|
| Jane Doe 1000 | Plaintiff |
Bringing suit against the Estate of Jeffrey Epstein.
|
| Darren K. Indyke | Defendant |
Executor of the Estate of Jeffrey Edward Epstein.
|
| Richard D. Kahn | Defendant |
Executor of the Estate of Jeffrey Edward Epstein.
|
| Jeffrey Edward Epstein | Deceased |
Subject of the estate; accused of sex-trafficking conspiracy.
|
| Sigrid S. McCawley | Attorney |
Counsel for Plaintiff.
|
| David Boies | Attorney |
Counsel for Plaintiff.
|
| Joshua I. Schiller | Attorney |
Counsel for Plaintiff.
|
| Bennet J. Moskowitz | Attorney |
Counsel for Defendants (Co-Executors).
|
| Debra Freeman | Judge |
United States Magistrate Judge presiding over the scheduling order.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of New York |
The court where the case is filed.
|
|
| Estate of Jeffrey Edward Epstein |
The legal entity being sued.
|
|
| Amazon.com |
Mentioned in discovery requests regarding account details and order history.
|
Timeline (3 events)
2020-01-14
Court Order issued (Dkt. 21) which the current report addresses.
SDNY
The Court
Parties
2020-03-27
Deadline for motions to amend pleadings or join additional parties.
N/A
Plaintiff
Defendants
2020-04-13
Deadline for parties to confer and stipulate protocol for document exchange.
N/A
Plaintiff
Defendants
Locations (1)
| Location | Context |
|---|---|
|
Location of the court and signing of the order.
|
Relationships (3)
Plaintiff suing Estate regarding 'alleged abuse of Plaintiff'.
Listed as executor of the Estate of Jeffrey Edward Epstein.
Listed as executor of the Estate of Jeffrey Edward Epstein.
Key Quotes (4)
"Plaintiff seeks discovery as to Jeffrey Epstein’s documents concerning... Mr. Epstein’s sex-trafficking conspiracy"Source
026.pdf
Quote #1
"Visitors and/or passengers at any of Mr. Epstein’s multiple residences or aircraft where the sex trafficking occurred"Source
026.pdf
Quote #2
"The Co-Executors’ position is that the general subjects of discovery in this action are: (1) Mr. Epstein’s alleged abuse of Plaintiff; and (2) Plaintiff’s alleged damages."Source
026.pdf
Quote #3
"Communications between Mr. Epstein and any government official regardless of country"Source
026.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (5,116 characters)
Case 1:19-cv-10577-LJL-DCF Document 26 Filed 02/06/20 Page 1 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
SOUTHERN DISTRICT OF NEW YORK
JANE DOE 1000,
Plaintiff,
CASE NO: 19-cv-10577-LL-DCF
DISCOVERY PLAN
v.
DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
Defendants.
_____________________________________
_____________________________________
Pursuant to the Court’s January 14, 2020, order (Dkt. 21), the parties submit the
following report addressing the required topics under Rule 26(f)(3) of the Federal Rules of Civil
Procedure:
following report addressing the required topics under Rule 26(f)(3) of the Federal Rules of Civil
Procedure:
(A)The parties have already exchanged initial disclosures.
(B) Plaintiff seeks discovery as to Jeffrey Epstein’s documents concerning
a. The Plaintiffs;
b. Mr. Epstein’s sex-trafficking conspiracy;
c. Visitors and/or passengers at any of Mr. Epstein’s multiple residences or aircraft
where the sex trafficking occurred;
where the sex trafficking occurred;
d. Communications between Mr. Epstein and his co-conspirators;
e. Communications between Mr. Epstein and his employees;
f. Communications between Mr. Epstein and any government official regardless of
country;
country;
Case 1:19-cv-10577-LJL-DCF Document 26 Filed 02/06/20 Page 2 of 5
g. Mr. Epstein’s flight logs and helicopter logs;
h. Video tapes and photographs taken at Mr. Epstein’s properties or on his planes;
i. Financial records;
j. Mr. Epstein’s message pads and any phone call logs or phone/contact directories;
and
and
k. Amazon.com account details, including order history.
The Co-Executors preserve all of their discovery rights including the right to object to Plaintiff’s
discovery requests. The Co-Executors’ position is that the general subjects of discovery in this
action are: (1) Mr. Epstein’s alleged abuse of Plaintiff; and (2) Plaintiff’s alleged damages.
discovery requests. The Co-Executors’ position is that the general subjects of discovery in this
action are: (1) Mr. Epstein’s alleged abuse of Plaintiff; and (2) Plaintiff’s alleged damages.
There is no need to conduct discovery in phases, or otherwise limit discovery to particular issues.
(C) The parties shall confer and stipulate as to a protocol for the exchange of documents
including the production of electronically stored information, no later than April 13,
2020.
including the production of electronically stored information, no later than April 13,
2020.
(D)– (F) There are no further issues requiring the Court’s attention at this time.
A proposed scheduling order is attached hereto as Exhibit A. Where the parties are in
disagreement regarding a particular deadline, their respective positions are noted.
disagreement regarding a particular deadline, their respective positions are noted.
Respectfully submitted,
/s/ Sigrid S. McCawley
David Boies, Esq.
Joshua I. Schiller, Esq.
Sigrid S. McCawley, Esq.
David Boies, Esq.
Joshua I. Schiller, Esq.
Sigrid S. McCawley, Esq.
/s/ Bennet J. Moskowitz
Bennet J. Moskowitz, Esq.
Bennet J. Moskowitz, Esq.
cc: Counsel of Record (via ECF)
Case 1:19-cv-10577-LJL-DCF Document 26 Filed 02/06/20 Page 3 of 5
EXHIBIT A
Case 1:19-cv-10577-LJL-DCF Document 26 Filed 02/06/20 Page 4 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
SOUTHERN DISTRICT OF NEW YORK
JANE DOE 1000,
Plaintiff,
CASE NO: 19-cv-10577-LL-DCF
[PROPOSED] SCHEDULING ORDER
v.
DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
Defendants.
_____________________________________
_____________________________________
DEBRA FREEMAN, United States Magistrate Judge:
It is hereby ORDERED that:
1. Plaintiff’s proposal: The parties shall serve their initial document requests and
interrogatories no later than March 12, 2020. The Co-Executors’ proposal: 30 days from the
Court’s entry of this Order.
interrogatories no later than March 12, 2020. The Co-Executors’ proposal: 30 days from the
Court’s entry of this Order.
2. The Co-Executors’ proposal: Plaintiffs shall provide HIPAA-compliant medical records
release authorizations to the Defendants no later than 14 days from Defendants’ request.
Plaintiff’s position: Any request for HIPAA releases shall be by motion if the parties are unable
to reach agreement without Court intervention, after discovery requests are served.
release authorizations to the Defendants no later than 14 days from Defendants’ request.
Plaintiff’s position: Any request for HIPAA releases shall be by motion if the parties are unable
to reach agreement without Court intervention, after discovery requests are served.
3. Any motions to amend the pleadings or to join any additional parties shall be filed no
later than March 27, 2020.
later than March 27, 2020.
4. The parties shall confer and stipulate as to a protocol regarding the production of
documents and electronically stored information no later than April 13, 2020.
documents and electronically stored information no later than April 13, 2020.
Case 1:19-cv-10577-LJL-DCF Document 26 Filed 02/06/20 Page 5 of 5
5. Plaintiff’s proposal: All fact discovery shall be completed no later than June 10, 2020.
The Co-Executors’ proposal: 160 days from the Court’s entry of this Order.
The Co-Executors’ proposal: 160 days from the Court’s entry of this Order.
6. Expert discovery shall be conducted on the following schedule:
a. Plaintiff’s proposal: Each party bearing the affirmative burden of proof on a claim
or defense shall serve its expert report(s) with respect to that claim or defense no
later than May 27, 2020. The Co-Executors’ proposal: 190 days from the Court’s
entry of this Order (i.e., 30 days after the close of fact discovery).
or defense shall serve its expert report(s) with respect to that claim or defense no
later than May 27, 2020. The Co-Executors’ proposal: 190 days from the Court’s
entry of this Order (i.e., 30 days after the close of fact discovery).
b. Rebuttal reports shall be served no later than June 26, 2020. The Co-Executors’
proposal: 220 days from the Court’s entry of this Order (i.e., 60 days after the
close of fact discovery).
proposal: 220 days from the Court’s entry of this Order (i.e., 60 days after the
close of fact discovery).
c. Expert discovery shall be completed no later than July 27, 2020. The Co-
Executors’ proposal: 240 days from the Court’s entry of this Order.
Executors’ proposal: 240 days from the Court’s entry of this Order.
7. The parties may stipulate to modify interim deadlines in this Scheduling Order, without
seeking prior leave of Court.
seeking prior leave of Court.
Dated: New York, New York
February ____, 2020
February ____, 2020
SO ORDERED
DEBRA FREEMAN
United States Magistrate Judge
United States Magistrate Judge
Copies to:
All counsel (via ECF)
All counsel (via ECF)
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