SOUTHERN DISTRICT OF NEW YORK
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003.pdf
This document is a 'Related Case Statement' filed on May 9, 2023, in the Southern District of New York. It formally links a new shareholder derivative lawsuit filed by the Operating Engineers Pension Fund against JPMorgan's board of directors (Case 1:23-cv-03903) with two existing cases filed by Jane Doe 1 and the US Virgin Islands against JPMorgan (Cases 22-cv-10019 and 22-cv-10904). The filing argues that all cases share a common factual basis regarding JPMorgan's relationship with Jeffrey Epstein, specifically alleging that the bank facilitated his abuse and that the board failed in its oversight duties.
20250728111721067_24-1073ReplyInSupportOfPetitionForWritO...
This document is a legal reply brief filed in the Supreme Court on behalf of Ghislaine Maxwell (Petitioner) against the United States, dated July 28, 2025. The brief argues that the Non-Prosecution Agreement (NPA) signed by Jeffrey Epstein in the Southern District of Florida, which promised not to prosecute 'potential co-conspirators' in 'the United States,' should legally bind other districts like the Southern District of New York. The filing highlights a circuit split on whether US Attorneys can bind other districts and contends that the Second Circuit's decision allowing Maxwell's prosecution violates contract law and the plain text of the agreement.
20250714161434468_24-1073_Maxwell_Opp.pdf
This document is a legal brief filed by the United States Solicitor General in July 2025 opposing Ghislaine Maxwell's petition for a writ of certiorari to the Supreme Court. The government argues that the 2007 Non-Prosecution Agreement (NPA) signed by Jeffrey Epstein in Florida does not bar the Southern District of New York from prosecuting Maxwell, as the agreement was contractually limited to the Florida district and Maxwell was not a party to it. The brief details the history of the Epstein investigation, the terms of the NPA, and relevant legal precedents regarding the scope of plea agreements binding different US Attorney's Offices.
20250117133905126_22-1426.pdf
This document is a formal legal opinion from the United States Court of Appeals for the Second Circuit affirming the conviction and 240-month prison sentence of Ghislaine Maxwell for sex trafficking and related offenses. The court rejected Maxwell's appeal on five grounds, including arguments regarding a non-prosecution agreement, statute of limitations, juror misconduct, jury instructions, and sentencing reasonableness. The document also includes a subsequent order from November 2024 denying Maxwell's petition for panel rehearing or rehearing en banc.
2022.08.02%20Memorandum%20Of%20Law.pdf
This document is a Supplemental Brief filed on August 1, 2022, by the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in the Superior Court of the Virgin Islands. The brief supports a Motion to Dismiss Ghislaine Maxwell's complaint seeking indemnification from the Estate. The Co-Executors argue that because Maxwell was convicted of intentional criminal acts (sex trafficking and conspiracy) in the Southern District of New York on June 29, 2022, public policy prohibits enforcing any contract or equitable doctrine that would indemnify her for the financial consequences of her crimes.
2020.09.28%20Response%20to%20Opposition.pdf
This is a Reply Brief filed by the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in response to a lawsuit by Ghislaine Maxwell. Maxwell is suing the Estate and NES, LLC for indemnification (payment of her legal fees) related to her criminal and civil cases in New York. The Co-Executors argue the case should be dismissed because: 1) The claim is 'unripe' as her underlying guilt or innocence hasn't been established; 2) Public policy forbids indemnifying criminal conduct; 3) The NES Operating Agreement explicitly allows the company to decline indemnification; and 4) The Statute of Frauds bars claims based on alleged oral promises.
018.pdf
This document is a court order from the Southern District of New York dated February 14, 2020, in the case of Teresa Helm v. the Estate of Jeffrey Epstein. Judge Debra Freeman granted a motion for Mary 'Molly' S. DiRago of Troutman Sanders LLP to be admitted Pro Hac Vice as counsel for the defendants, Darren K. Indyke and Richard D. Kahn (executors of Epstein's estate).
016.pdf
This document is a Scheduling Order from the US District Court (SDNY) dated February 11, 2020, issued by Magistrate Judge Debra Freeman. It consolidates deadlines for discovery, expert reports, and status updates for thirteen related civil cases involving plaintiffs suing the Epstein estate executors (Indyke) and related entities. The order sets a fact discovery deadline of June 10, 2020, and mentions ongoing settlement discussions.
011.pdf
This document is a court order filed on January 14, 2020, by Magistrate Judge Debra Freeman in the Southern District of New York. It coordinates the discovery schedules for multiple civil cases filed against the Jeffrey Epstein estate (represented by Indyke et al.) by various plaintiffs claiming sexual abuse. The order mandates the submission of discovery plans by February 6, 2020, and sets a joint pretrial conference for February 11, 2020.
009.pdf
A Waiver of the Service of Summons filed in the US District Court for the Southern District of New York on November 27, 2019, in the case of Teresa Helm v. Darren K. Indyke et al. Attorney Bennet Moskowitz of Troutman Sanders LLP signed the waiver on November 25, 2019, on behalf of defendants Darren K. Indyke and Richard D. Kahn, acknowledging receipt of the complaint from plaintiff's attorney David Boies.
008.pdf
This document is a court order from the U.S. District Court for the Southern District of New York, dated November 25, 2019. It grants the motion for attorney Sigrid S. McCawley of Boies Schiller Flexner LLP to appear Pro Hac Vice as counsel for plaintiff Teresa Helm in her case against the executors of Jeffrey Epstein's estate. The order is signed by Magistrate Judge Debra Freeman.
001.pdf
This document is a legal complaint filed by Teresa Helm against the executors of Jeffrey Epstein's estate, Darren K. Indyke and Richard D. Kahn, alleging sexual abuse and trafficking by Epstein and his co-conspirators. The complaint details Epstein's extensive sex trafficking network, previous legal proceedings, and his personal statements regarding his actions, seeking damages for battery and intentional infliction of emotional distress.
032.pdf
A legal stipulation filed on April 1, 2021, in the Southern District of New York, dismissing Maria Farmer's lawsuit against the executors of Jeffrey Epstein's estate (Indyke and Kahn). The dismissal is with prejudice and results from Farmer accepting an offer of compensation from the Epstein Victims’ Compensation Program.
026.pdf
This document is the formal Answer and Affirmative Defenses filed by the Co-Executors of the Jeffrey Epstein Estate (Darren K. Indyke and Richard D. Kahn) in response to a civil complaint by Annie Farmer. The executors generally deny knowledge of the specific allegations of abuse but admit to certain procedural facts, such as Epstein's arrest date (July 6, 2019), death date (August 10, 2019), and property ownership in NY, NM, USVI, FL, and France. They assert ten affirmative defenses, including failure to state a claim, contributory negligence, assumption of risk, and statute of limitations arguments challenging the New York Child Victims' Act.
022.pdf
This is an amended complaint filed by Maria Farmer against the executors of Jeffrey Edward Epstein's estate. Farmer alleges that Epstein sexually assaulted and trafficked her, and that his actions were part of a larger sex trafficking network. The complaint details Epstein's history of sexual abuse, his lenient 2008 plea deal, and the intimidation tactics used to silence victims.
022-01.pdf
This document is an indictment (19 Cr. 490) filed in the SDNY charging Jeffrey Epstein with sex trafficking conspiracy and sex trafficking of minors between 2002 and 2005. It details how Epstein used a network of employees and victim-recruiters to source minors for sexual abuse at his residences in New York and Palm Beach, paying them in cash. The document also includes forfeiture allegations for his property at 9 East 71st Street, New York, owned by Maple, Inc.
008.pdf
This document is a Waiver of the Service of Summons filed on November 27, 2019, in the case of Maria Farmer v. Darren K. Indyke et al (Case No. 1:19-cv-10474-NRB) in the Southern District of New York. Attorney Bennet Moskowitz of Troutman Sanders LLP signed the waiver on November 25, 2019, on behalf of defendants Darren K. Indyke and Richard D. Kahn, agreeing to waive formal service and respond to the complaint within 60 days. The waiver is addressed to plaintiff's attorney David Boies.
007.pdf
A court order from the Southern District of New York dated November 25, 2019, in the case of Maria Farmer v. Darren K. Indyke and Richard D. Kahn (Executors of the Estate of Jeffrey Edward Epstein). The order grants attorney Sigrid S. McCawley of Boies Schiller Flexner LLP admission to practice Pro Hac Vice to represent the plaintiff, Maria Farmer.
038.pdf
This document is a court order from the U.S. District Court for the Southern District of New York, dated June 5, 2017, and filed on June 6, 2017. Judge Robert W. Sweet orders the termination of the case (17 Mc. 25) between Bradley J. Edwards and Ghislaine Maxwell following the resolution of a motion to quash a subpoena via a sealed opinion dated April 4, 2017.
033.pdf
This document is a Reply Memorandum filed by attorney Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell. Edwards argues that Maxwell's requests for his communications with 'prospective witnesses' are overbroad, unduly burdensome, and seek protected attorney work-product. The filing notably alleges that Maxwell has failed to explain her presence on 23 flights with a teenaged Virginia Giuffre or the message pads documenting underage girls calling Epstein's mansion for 'massages'.
031.pdf
A court order filed on March 3, 2017, by Judge Robert W. Sweet in the case of Virginia L. Giuffre v. Ghislaine Maxwell. The document sets a schedule for hearing various motions throughout March 2017 and establishes a deadline for objections to deposition designations in April 2017. It also references a related motion to quash in the case of Bradley v. Maxwell.
030.pdf
This document is a Civil Docket Report for Case No. 0:16-mc-61262-JG, filed in the U.S. District Court for the Southern District of Florida on June 13, 2016. The case involves Plaintiff Bradley J. Edwards filing a motion to quash a subpoena against Defendant Ghislaine Maxwell. The docket records various motions, including requests to seal exhibits and appear Pro Hac Vice, culminating in an order on December 22, 2016, to transfer the motion to the Southern District of New York to be handled as part of the case Giuffre v. Maxwell (1:15-cv-07433-RWS). The case was terminated in the Florida court on December 23, 2016.
023.pdf
This document is a formal notice filed on December 16, 2016, in the Southern District of Florida, by attorneys for Ghislaine Maxwell. It informs the court and opposing counsel (specifically Bradley J. Edwards' attorney Jack Scarola) that 'Exhibit B' related to a subpoena status notice has been filed under seal. The underlying case referenced is Virginia L. Giuffre v. Ghislaine Maxwell in the Southern District of New York.
022.pdf
This document is a motion filed on December 16, 2016, by Ghislaine Maxwell's attorneys in the Southern District of Florida. The motion requests permission to file 'Exhibit B' under seal, noting that the exhibit is a sealed order from the Southern District of New York in the underlying 'Giuffre v. Maxwell' case. The document lists legal counsel for Maxwell and for Bradley J. Edwards, who is the subject of a subpoena in this miscellaneous action.
015.pdf
This document is a Motion to Seal filed on July 7, 2016, by attorney Jack Scarola on behalf of Bradley J. Edwards in the U.S. District Court for the Southern District of Florida. Edwards seeks to seal exhibits attached to his Motion to Quash a subpoena, specifically referencing confidential depositions of Ghislaine Maxwell and Rinaldo Rizzo, as well as documents related to Alan Dershowitz, which are already under seal in the Southern District of New York. The motion argues that sealing is necessary to comply with protective orders from the underlying case.
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