SOUTHERN DISTRICT OF NEW YORK
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067.pdf
A court order from the Southern District of New York dated June 19, 2020, in the case of VE v. Nine East 71st Street, Corporation, et al. Judge Alison J. Nathan administratively denied the Defendants' motion to dismiss the First Amended Complaint without prejudice, citing a stay entered by Judge Freeman in a related matter.
057.pdf
A Notice of Filing of Official Transcript filed on February 13, 2020, in the civil forfeiture case USA v. Nine East 71st Street (Case No. 19-cv-07625). The notice alerts parties that the transcript for a scheduling conference held on February 11, 2020, has been filed by Court Reporter Carole Ludwig.
055.pdf
Scheduling Order issued by U.S. Magistrate Judge Debra Freeman on February 11, 2020, coordinating deadlines for multiple civil lawsuits against the Epstein Estate (Indyke et al.) and Nine East 71st Street. The order establishes deadlines for initial disclosures, document requests, fact discovery (June 10, 2020), and expert discovery (July 31, 2020), and notes ongoing settlement discussions with a status report due by April 30, 2020. The document lists 13 separate civil actions being managed together under this order.
054.pdf
This document is a Joint Proposed Discovery Schedule filed on February 6, 2020, in the case of VE v. Indyke et al. It outlines the agreed-upon timeline for the exchange of evidence, including initial disclosures, medical records, and expert reports. The filing identifies the key subjects of discovery as Epstein's alleged torts against the plaintiff, the liability of the corporate defendants, and the plaintiff's damages.
039-01.pdf
This document is a blank Non-Disclosure Agreement form filed on December 4, 2019, in the United States District Court for the Southern District of New York regarding Case No. 1:19-cv-07625-AJN (VE v. Indyke et al.). The agreement requires signatories to maintain the confidentiality of the Plaintiff's identity ('VE') in connection with the litigation against the Estate of Jeffrey Epstein and associated entities. It stipulates that willful violation of the agreement may result in punishment for contempt of court.
037.pdf
This document is a legal declaration filed on November 29, 2019, by Bennet J. Moskowitz, an attorney for the defendants in the case of VE v. Darren K. Indyke, et al. Moskowitz declares his representation of the Co-Executors of the Jeffrey Epstein Estate and associated corporate entities. The declaration serves to submit a copy of the Plaintiff's First Amended Complaint as an exhibit to support the Defendants' Motion to Dismiss.
035.pdf
A court order from the Southern District of New York dated November 27, 2019, in the case of VE v. Nine East 71st Street, Corporation (an entity associated with Jeffrey Epstein). District Judge Alison J. Nathan adjourns the initial pre-trial conference scheduled for December 6, 2019, indefinitely (sine die) due to a general pre-trial referral to Judge Freeman.
031.pdf
This document is an Order of Reference from the U.S. District Court (SDNY) filed on November 18, 2019. Judge Alison J. Nathan refers the civil case (1:19-cv-07625) between plaintiff 'VE' and defendant 'Nine East 71st Street, Corporation' (Epstein's property entity) to a Magistrate Judge for general pretrial proceedings, including scheduling, discovery, and settlement.
030.pdf
This document is a Memorandum of Law filed on November 15, 2019, in the US District Court (SDNY) by the Co-Executors of Jeffrey Epstein's estate (Indyke and Kahn) and associated entities. The defendants state they do not object to the Plaintiff 'VE' proceeding anonymously but request the court enter a specific 'Proposed Order' to ensure they can adequately defend themselves and conduct discovery while maintaining her confidentiality from the general public. The filing argues that while anonymity is acceptable, it must not prejudice the defense's ability to investigate the allegations.
030-01.pdf
This document is a Court Order from the Southern District of New York filed on November 15, 2019, in the case of VE v. Darren K. Indyke and Richard D. Kahn (Epstein Estate representatives). Judge Alison J. Nathan ordered strict protocols to protect the anonymity of the plaintiff 'VE,' requiring filings identifying the plaintiff to be sealed and limiting disclosure of their identity strictly to the defense team for legal necessity.
023.pdf
This document is a civil summons filed on September 26, 2019, in the Southern District of New York for Case 1:19-cv-07625-AJN. The plaintiff, identified as 'VE', is suing several entities including Nine East 71st Street Corporation and Financial Trust Company, Inc., as well as Darren K. Indyke and Richard D. Kahn in their capacities as Co-Executors of the Estate of Jeffrey E. Epstein. The document requires the defendants to serve an answer to the complaint within 21 days to the plaintiff's attorney, J. Stanley Pottinger.
022.pdf
This document is a Summons in a Civil Action filed on September 25, 2019, in the Southern District of New York. The plaintiff, identified as 'VE', is suing several entities including Nine East 71st Street Corporation, Financial Trust Company, Inc., NES, LLC, and the executors of Jeffrey Epstein's estate (Darren K. Indyke and Richard D. Kahn). The summons instructs the defendants to respond to the complaint within 21 days.
017.pdf
This document is a Summons in a Civil Action issued on September 10, 2019, by the US District Court for the Southern District of New York. The plaintiff, identified as 'VE', is suing several entities and individuals associated with the Epstein estate, including Nine East 71st Street Corp, Financial Trust Company Inc., NES LLC, Darren K. Indyke, and Richard D. Kahn. This specific summons is addressed to Financial Trust Company, Inc. in the US Virgin Islands.
012.pdf
This document is a Summons in a Civil Action filed on September 6, 2019, in the Southern District of New York. The plaintiff, identified only as 'VE', is suing three Epstein-related corporate entities: Nine East 71st Street Corporation, Financial Trust Company, Inc., and NES, LLC. The summons is directed to Darren K. Indyke, a known lawyer for Jeffrey Epstein, acting as the agent for these corporations.
007.pdf
This document is a 'Notice of Initial Pretrial Conference' issued by Judge Alison J. Nathan on August 28, 2019, in the civil case of VE v. Nine East 71st Street Corporation, Financial Trust Company, Inc., and NES, LLC. The order schedules a mandatory pretrial conference for December 6, 2019, at the Thurgood Marshall U.S. Courthouse in New York. It instructs counsel to confer regarding settlement and discovery, and to submit a joint letter and Proposed Civil Case Management Plan seven days prior to the conference.
006.pdf
This document is a Motion for Admission Pro Hac Vice filed on August 27, 2019, in the Southern District of New York. Attorney Brittany N. Henderson of Edwards Pottinger, LLC requests permission to represent Plaintiff 'VE' in a civil case against the Estate of Jeffrey E. Epstein and associated entities (Nine East 71st Street Corp, Financial Trust Company, NES LLC). Henderson certifies her good standing with the Florida bar.
066-01.pdf
This is a Property Release Order from the United States District Court for the Southern District of New York in the case of United States of America v. Tova Noel. The order, signed by Judge Analisa Torres, mandates the New York City Police Department to immediately return a firearm and other surrendered property to the defendant, Tova Noel, following an application by her attorney, Jason E. Foy.
065.pdf
This document is a Nolle Prosequi filed in the United States District Court for the Southern District of New York regarding the case against Tova Noel and Michael Thomas, the correctional officers on duty when Jeffrey Epstein died. The filing indicates that both defendants successfully completed the terms of their deferred prosecution agreements (DPAs) entered into on May 20, 2021, including community service and good behavior. Consequently, the Government recommended, and Judge Analisa Torres ordered on January 3, 2022, that the charges against them be dismissed.
064.pdf
This document is a 'Nolle Prosequi' filed in the Southern District of New York, formally dismissing criminal charges against Tova Noel and Michael Thomas. The defendants, who were the guards on duty when Jeffrey Epstein died, had previously entered into a deferred prosecution agreement on May 20, 2021. Following their successful completion of community service and good behavior over a six-month period ending November 20, 2021, the U.S. Attorney's Office moved to drop the case.
059.pdf
This document is a Deferred Prosecution Agreement (DPA) between the United States and Tova Noel, a Bureau of Prisons employee charged in connection with the events surrounding Jeffrey Epstein's death. Noel admits to knowingly falsifying count and round slips at the Metropolitan Correctional Center (MCC) on August 9 and 10, 2019. The agreement defers prosecution for six months pending her good behavior, 100 hours of community service, and cooperation with investigators (FBI, DOJ-OIG), after which the indictment will be dismissed if conditions are met.
058.pdf
A court document filed on May 25, 2021, in the Southern District of New York for case 1:19-cr-00830 (United States v. Michael Thomas). The document is a 'Consent to Proceed by Videoconference' where defendant Michael Thomas agrees to participate in a Status and/or Scheduling Conference via video technology. It is signed by Michael Thomas and his attorney, Montell Figgins.
057.pdf
A legal consent form filed on May 25, 2021, in the Southern District of New York (Case 1:19-cr-00830-AT). Defendant Tova Noel, represented by Jason E. Foy, voluntarily consented to participate in a Status and/or Scheduling Conference via videoconference.
056.pdf
This document is a Deferred Prosecution Agreement for Michael Thomas, a Bureau of Prisons employee charged in connection with the events surrounding Jeffrey Epstein's death. Thomas admits to willfully falsifying count and round slips at the Metropolitan Correctional Center (MCC) on August 9 and 10, 2019. In exchange for this admission and compliance with conditions including 100 hours of community service and supervision, prosecution is deferred for six months, after which the indictment will be dismissed if successful.
040.pdf
A 'Consent to Proceed by Videoconference' form filed in the Southern District of New York on September 10, 2020, for Case 1:19-cr-00830-AT. Defendant Michael Thomas (implicated in the falsification of records regarding Jeffrey Epstein's detention) and his attorney Montell Figgins signed the document on September 8, 2020, consenting to have a 'Status and/or Scheduling Conference' conducted via video. The document was approved by District Judge Analisa Torres.
038.pdf
This document is a court order from the Southern District of New York dated September 2, 2020, in the case against Tova Noel and Michael Thomas (the guards on duty during Jeffrey Epstein's death). Judge Analisa Torres adjourns a status conference to September 10, 2020, and mandates it be held remotely due to the COVID-19 pandemic, providing dial-in instructions for the public and press.
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