015.pdf
76.8 KB
Extraction Summary
9
People
3
Organizations
1
Locations
2
Events
3
Relationships
5
Quotes
Document Information
Type:
Legal filing (discovery plan and proposed scheduling order)
File Size:
76.8 KB
Summary
This document is a Discovery Plan and Proposed Scheduling Order filed on February 6, 2020, in the case of Teresa Helm v. The Estate of Jeffrey Epstein. The plaintiff outlines broad discovery requests, including Epstein's flight logs, helicopter logs, financial records, Amazon order history, and communications with government officials and co-conspirators. The Co-Executors attempt to limit the scope of discovery strictly to the alleged abuse of the plaintiff and her damages, and the document outlines conflicting proposed deadlines for the discovery process.
People (9)
| Name | Role | Context |
|---|---|---|
| Teresa Helm | Plaintiff |
Victim suing the Epstein Estate
|
| 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 |
Subject of the estate and allegations of sex trafficking
|
| 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
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of New York |
Court where case is filed
|
|
| Estate of Jeffrey Edward Epstein |
Defendant entity
|
|
| Amazon.com |
Entity for which account details and order history are requested
|
Timeline (2 events)
2020-04-13
Deadline to confer and stipulate protocol for document exchange
N/A
Plaintiff
Defendants
Locations (1)
| Location | Context |
|---|---|
|
Location of the Court
|
Relationships (3)
Plaintiff suing Estate regarding 'Mr. Epstein's alleged abuse of Plaintiff'
Executor of the Estate of Jeffrey Edward Epstein
Executor of the Estate of Jeffrey Edward Epstein
Key Quotes (5)
"Plaintiff seeks discovery as to Jeffrey Epstein’s documents concerning... c. Visitors and/or passengers at any of Mr. Epstein’s multiple residences or aircraft where the sex trafficking occurred"Source
015.pdf
Quote #1
"Plaintiff seeks discovery as to... g. Mr. Epstein’s flight logs and helicopter logs"Source
015.pdf
Quote #2
"Plaintiff seeks discovery as to... h. Video tapes and photographs taken at Mr. Epstein’s properties or on his planes"Source
015.pdf
Quote #3
"Plaintiff seeks discovery as to... k. Amazon.com account details, including order history."Source
015.pdf
Quote #4
"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
015.pdf
Quote #5
Full Extracted Text
Complete text extracted from the document (5,118 characters)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
SOUTHERN DISTRICT OF NEW YORK
TERESA HELM,
Plaintiff,
CASE NO: 19-cv-10476-PGG-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. 11), 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-10476-PGG-DCF Document 15 Filed 02/06/20 Page 1 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-10476-PGG-DCF Document 15 Filed 02/06/20 Page 2 of 5
EXHIBIT A
Case 1:19-cv-10476-PGG-DCF Document 15 Filed 02/06/20 Page 3 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
SOUTHERN DISTRICT OF NEW YORK
TERESA HELM,
Plaintiff,
CASE NO: 19-cv-10476-PGG-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-10476-PGG-DCF Document 15 Filed 02/06/20 Page 4 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)
Case 1:19-cv-10476-PGG-DCF Document 15 Filed 02/06/20 Page 5 of 5
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