Extraction Summary

9
People
3
Organizations
2
Locations
3
Events
3
Relationships
3
Quotes

Document Information

Type: Legal correspondence / court filing
File Size: 54.4 KB
Summary

A letter from attorney Bennet J. Moskowitz to Judge Lorna G. Schofield dated January 2, 2020, regarding the case of Jane Doe 1000 v. the Estate of Jeffrey Epstein. The letter requests the referral of the case to Magistrate Judge Debra C. Freeman for general pretrial proceedings, noting that the plaintiff consents and that similar cases (specifically citing Teresa Helm and Juliette Bryant) have already been referred to her.

People (9)

Name Role Context
Bennet J. Moskowitz Attorney
Author of the letter, representing Defendants (Indyke and Kahn) from Troutman Sanders LLP.
Lorna G. Schofield Judge
Recipient of the letter, Honorable Judge at the US District Court SDNY.
Jane Doe 1000 Plaintiff
Plaintiff in the referenced case (Case No. 19-cv-10577-LGS).
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
His estate is the subject of the lawsuit.
Debra C. Freeman Magistrate Judge
Judge requested to handle General Pretrial matters.
Teresa Helm Plaintiff
Plaintiff in a related case (19-cv-10476) mentioned in footnote.
Juliette Bryant Plaintiff
Plaintiff in a related case (19-cv-10479) mentioned in footnote.

Organizations (3)

Name Type Context
Troutman Sanders LLP
Law firm representing the Defendants.
United States District Court, Southern District of New York
Court where the cases are filed (implied by address and SDNY citations).
Estate of Jeffrey Edward Epstein
Legal entity being sued.

Timeline (3 events)

2019-11-21
Status conference held by Magistrate Freeman.
Southern District of New York
Magistrate Freeman Counsel of record
2020-01-02
Scheduled submission of Joint Letters and Civil Case Management Plans (guidance requested on whether to proceed).
Southern District of New York
Parties
2020-01-10
Deadline to submit status reports to Magistrate Freeman.
Southern District of New York
Parties in referred matters

Locations (2)

Relationships (3)

Darren K. Indyke Co-Executors Richard D. Kahn
Co-Executors of the Estate of Jeffrey E. Epstein
Bennet J. Moskowitz Legal Representation Darren K. Indyke
We represent Darren K. Indyke...
Bennet J. Moskowitz Legal Representation Richard D. Kahn
We represent... Richard D. Kahn...

Key Quotes (3)

"Defendants respectfully request that the Court refer this action to Magistrate Judge Debra C. Freeman for General Pretrial"
Source
015.pdf
Quote #1
"Plaintiff consents to this request."
Source
015.pdf
Quote #2
"several other Judges in this District have collectively referred to Magistrate Freeman for General Pretrial numerous actions against Defendants in their capacities as Co-Executors of the Estate of Jeffrey E. Epstein"
Source
015.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (2,466 characters)

Case 1:19-cv-10577-LJL-DCF Document 15 Filed 01/02/20 Page 1 of 2
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutman.com
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
January 2, 2020
ECF
Hon. Lorna G. Schofield
Thurgood Marshall
United States Courthouse
40 Foley Square
New York, NY 10007
Re: Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn in their capacities as the executors of the Estate of Jeffrey Edward Epstein, Case No. 19-cv-10577-LGS
Dear Judge Schofield:
We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, "Defendants") in the referenced action. Defendants respectfully request that the Court refer this action to Magistrate Judge Debra C. Freeman for General Pretrial (including scheduling, discovery, non-dispositive pretrial motions, and settlement). Plaintiff consents to this request.
As a matter of context, several other Judges in this District have collectively referred to Magistrate Freeman for General Pretrial numerous actions against Defendants in their capacities as Co-Executors of the Estate of Jeffrey E. Epstein, including two actions in which the parties are represented by the respective counsel of record in this action.1 Magistrate Freeman held a status conference on November 21, 2019, which counsel of record for the parties to this action attended. Magistrate Freeman requested the parties in the matters referred to Her Honor to submit status reports on January 10, 2020.
1See Teresa Helm v. Darren K. Indyke and Richard D. Kahn, in their capacities as the executors of the Estate of Jeffrey Edward Epstein, Case No. 19-cv-10476-PGG-DCF, Order of Reference (ECF Doc. 6) (S.D.N.Y. Nov. 21, 2019); Juliette Bryant v. Darren K. Indyke and Richard D. Kahn, in their capacities as the executors of the Estate of Jeffrey Edward Epstein, Case No. 19-cv-10479-ALC-DCF, Order of Reference (ECF Doc. 8) (S.D.N.Y. Dec. 26, 2019).
troutman sanders
Case 1:19-cv-10577-LJL-DCF Document 15 Filed 01/02/20 Page 2 of 2
January 2, 2020
Page 2
The parties are aware that this Court had planned for the parties to submit Joint Letters and Civil Case Management Plans and Scheduling Orders today. However, in light of this request for referral to Magistrate Judge Freeman, the parties request the Court's guidance on whether these documents should be submitted.
Respectfully submitted,
s/Bennet J. Moskowitz
Bennet J. Moskowitz
troutman sanders

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