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B. Moskowitz

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037.pdf

This document is a letter from Sigrid S. McCawley, representing Plaintiff Teresa Helm, to Judge Debra Freeman, requesting a pre-motion conference to compel Defendants Darren K. Indyke and Richard D. Kahn (Epstein's lawyer and accountant) to produce discovery documents and respond to interrogatories. The letter details Defendants' failure to comply with discovery obligations, including not producing any documents and improperly limiting the relevant time period for discovery, despite allegations that Jeffrey Epstein operated a decades-long sex-trafficking scheme and sexually assaulted the Plaintiff in 2002.

Legal correspondence / motion to compel
2025-12-26
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Deficiencies in responses and objections

From: S. McCawley
To: B. Moskowitz

Plaintiff's letter regarding clear deficiencies in Defendants' responses.

Letter
2020-04-20
Communication Source

Discovery obligations

From: B. Moskowitz
To: S. McCawley

Defendants stated they were abiding by discovery obligations.

Letter
2020-02-03
Communication Source

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