016.pdf
23.8 KB
Extraction Summary
6
People
4
Organizations
3
Locations
2
Events
3
Relationships
2
Quotes
Document Information
Type:
Legal filing (joint proposed discovery schedule)
File Size:
23.8 KB
Summary
This document is a Joint Proposed Discovery Schedule filed on February 6, 2020, in the Southern District of New York case 'Anastasia Doe v. Darren K. Indyke and Richard D. Kahn'. It outlines the timeline and procedural rules for the discovery phase of the lawsuit against the Estate of Jeffrey Epstein, including deadlines for initial disclosures, document requests, and expert discovery.
People (6)
| Name | Role | Context |
|---|---|---|
| Anastasia Doe | Plaintiff |
Plaintiff in the civil case 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.
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| Jeffrey E. Epstein | Deceased |
Estate mentioned as the defendant party.
|
| Brad Edwards | Attorney |
Attorney for Plaintiff (Anastasia Doe).
|
| Bennet J. Moskowitz | Attorney |
Attorney for Defendants (Indyke and Kahn).
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of New York |
Court where the case is filed.
|
|
| Estate of Jeffrey E. Epstein |
The legal entity being sued.
|
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| Edwards Pottinger LLC |
Law firm representing the Plaintiff.
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| Troutman Sanders LLP |
Law firm representing the Defendants.
|
Timeline (2 events)
2020-02-06
Locations (3)
| Location | Context |
|---|---|
|
Jurisdiction of the court.
|
|
|
Location of the court and Troutman Sanders LLP office.
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|
|
Location of Edwards Pottinger LLC office.
|
Relationships (3)
Listed as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Signed as 'Attorney for Plaintiff'
Signed as 'Attorney for Defendants'
Key Quotes (2)
"The Parties anticipate that discovery may be needed on the following subjects: (1) Mr. Epstein’s alleged torts committed against Plaintiff and (2) Plaintiff’s alleged damages."Source
016.pdf
Quote #1
"Plaintiff shall provide HIPAA-compliant medical records release authorizations to the Co-Executors no later than 14 days from the request therefor"Source
016.pdf
Quote #2
Full Extracted Text
Complete text extracted from the document (3,630 characters)
Case 1:19-cv-11869-MKV-DCF Document 16 Filed 02/06/20 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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ANASTASIA DOE,
Plaintiff,
v.
DARREN K. INDYKE AND RICHARD D.
KAHN, AS CO-EXECUTORS OF THE
ESTATE OF JEFFREY E. EPSTEIN,
Defendants.
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Index No. 1:19-cv-11869-MKV-DCF
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SOUTHERN DISTRICT OF NEW YORK
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ANASTASIA DOE,
Plaintiff,
v.
DARREN K. INDYKE AND RICHARD D.
KAHN, AS CO-EXECUTORS OF THE
ESTATE OF JEFFREY E. EPSTEIN,
Defendants.
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Index No. 1:19-cv-11869-MKV-DCF
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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 Anastasia Doe and Defendants Darren K. Indyke and Richard
D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the “Co-Executors”, and
together with Plaintiff, the “Parties”) hereby jointly submit the following proposed discovery
schedule:
Rule of Civil Procedure, Plaintiff Anastasia Doe and Defendants Darren K. Indyke and Richard
D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the “Co-Executors”, and
together with Plaintiff, the “Parties”) hereby jointly submit the following proposed discovery
schedule:
1. The Parties shall serve their initial disclosures pursuant to Rule 26(a)(1) no later than
February 7, 2020;
February 7, 2020;
2. Plaintiff shall provide HIPAA-compliant medical records release authorizations to
the Co-Executors no later than 14 days from the request therefor;
the Co-Executors 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;
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
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Case 1:19-cv-11869-MKV-DCF Document 16 Filed 02/06/20 Page 2 of 3
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 and (2) Plaintiff’s alleged
damages.
subjects: (1) Mr. Epstein’s alleged torts committed against Plaintiff and (2) Plaintiff’s alleged
damages.
Within 14 days from the Court’s entry of the discovery schedule, the Co-Executors 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.
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.
Within 14 days from the Court’s entry of the discovery schedule, the Co-Executors 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.
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.
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).
The Parties respectfully request that the Court enter this joint proposed discovery
schedule in this matter.
schedule in this matter.
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Case 1:19-cv-11869-MKV-DCF Document 16 Filed 02/06/20 Page 3 of 3
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
Attorney for Plaintiff
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
Attorney for Defendants
Bennet J. Moskowitz
TROUTMAN SANDERS LLP
875 Third Avenue
New York, New York 10022
Attorney for Defendants
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