SOUTHERN DISTRICT OF NEW YORK
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013.pdf
This document is a reply filed by Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell in the case of Giuffre v. Maxwell. Edwards argues that the subpoena imposes an undue burden on him as a non-party and opposing counsel, seeking information that is already in Maxwell's possession, privileged, irrelevant, or available from other sources. The brief details the history of related litigation, including the CVRA case and a defamation suit against Alan Dershowitz, to support the argument that the subpoena is harassing and unnecessary.
012.pdf
This document is a motion filed on July 7, 2016, in the Southern District of Florida by attorney Jack Scarola on behalf of Bradley J. Edwards. Edwards requests permission to file a reply exceeding the standard page limit (up to 25 pages) in support of his motion to quash a subpoena served by Ghislaine Maxwell. The motion explains that the extra length is necessary to address allegations made by Maxwell regarding Edwards' prior filings and alleged discovery withholding by his client, Virginia Giuffre.
010-06.pdf
This document is Plaintiff Virginia Giuffre's second amended supplemental response to discovery requests from Defendant Ghislaine Maxwell, dated April 29, 2016. It details Giuffre's legal representation history from 2009 to 2016, listing specific attorneys and cases including actions against Jeffrey Epstein, the US Government, and Alan Dershowitz. The document also contains objections to requests for financial records regarding payments from Epstein or media organizations, asserting attorney-client privilege and irrelevance.
001-05.pdf
This document outlines Ghislaine Maxwell's formal objections and responses to Virginia Giuffre's second request for production of documents in the 2015 civil case. Maxwell's counsel objects to numerous requests on grounds of privilege, relevance, and burden, specifically refusing to produce financial documents (tax returns, bank statements, asset lists) pending a motion for a protective order. The document also addresses requests for Joint Defense Agreements with Jeffrey Epstein and Alan Dershowitz, communications regarding sexual abuse allegations, and funding sources for the TerraMar Project, including any from the Clinton Foundation.
001-01.pdf
Legal declaration by attorney Bradley J. Edwards filed on June 13, 2016, in support of a motion to quash a subpoena from Ghislaine Maxwell. Edwards details his representation of Virginia Giuffre and the undue burden of reviewing over 200,000 emails for communications with journalists. He explicitly states that Ghislaine Maxwell and Jeffrey Epstein share a joint defense agreement and mentions Giuffre's association with the organization 'Victims Refuse Silence, Inc.'
042.pdf
This document is a court order from the Southern District of New York dated August 26, 2021, in the civil case of Jane Doe v. Indyke and Kahn. The order grants a motion for attorney Mary 'Molly' S. DiRago of Troutman Pepper Hamilton Sanders LLP to appear pro hac vice as counsel for the executors of Jeffrey Epstein's estate. It is signed by Magistrate Judge Debra Freeman.
029.pdf
This document is a Notice of Motion filed on July 30, 2021, in the Southern District of New York (Case 1:20-cv-02365). Plaintiff Jane Doe is notifying the defendants (Executors of the Epstein Estate and various associated corporate entities) that she is moving the court for an order allowing her to proceed anonymously in the lawsuit.
003.pdf
This document is a civil summons filed on March 17, 2020, in the Southern District of New York (Case 1:20-cv-02365). Plaintiff Jane Doe is suing Darren K. Indyke and Richard D. Kahn in their capacities as executors of the Estate of Jeffrey E. Epstein. The summons is specifically addressed to Richard D. Kahn.
002.pdf
This document is a civil summons filed on March 17, 2020, in the Southern District of New York. It notifies Darren K. Indyke and Richard D. Kahn, as executors of Jeffrey Epstein's estate, that they are being sued by a plaintiff identified as Jane Doe. The document instructs the defendants to respond to the complaint within 21 days to the plaintiff's attorney, Daniel J. Kaiser.
040.pdf
A court filing from the Southern District of New York dated November 2, 2020, stipulating the dismissal of a case brought by 'Anastasia Doe' against the Estate of Jeffrey Epstein. The dismissal is with prejudice and results from the plaintiff resolving her claims through the Epstein Victims' Compensation Program. The document is signed by attorneys Bradley J. Edwards (Plaintiff) and Bennet J. Moskowitz (Defendants).
016.pdf
This document is a Joint Proposed Discovery Schedule filed on February 6, 2020, in the Southern District of New York case 'Anastasia Doe v. Darren K. Indyke and Richard D. Kahn'. It outlines the timeline and procedural rules for the discovery phase of the lawsuit against the Estate of Jeffrey Epstein, including deadlines for initial disclosures, document requests, and expert discovery.
011-01.pdf
This document is an affirmation filed on January 13, 2020, by attorney Brittany N. Henderson of Edwards Pottinger, LLC, in support of her application for admission pro hac vice in the case of Anastasia Doe v. The Estate of Jeffrey Epstein. Henderson declares she has no criminal record or disciplinary history and includes certificates of good standing from the Supreme Court of Florida (dated Dec 31, 2019) and The Florida Bar (dated Jan 10, 2020).
003.pdf
This document is a Motion for Admission Pro Hac Vice filed on December 27, 2019, in the Southern District of New York. Attorney Bradley J. Edwards seeks permission to represent Plaintiff Anastasia Doe in her lawsuit against Darren K. Indyke and Richard D. Kahan, the co-executors of the Estate of Jeffrey E. Epstein. Edwards attests to his good standing with the Florida and New York bars and lack of disciplinary history.
042.pdf
This document is a Court Order from the United States District Court Southern District of New York, dated March 6, 2020, in Case No. 1:19-cv-09610-PAE. The order, signed by Magistrate Judge Debra C. Freeman, officially relieves Andrew S. Buzin and Buzin Law, P.C. as counsel for the plaintiff, Jane Doe 17, in her lawsuit against the Estate of Jeffrey E. Epstein and various associated corporations.
041-01.pdf
A court order from the Southern District of New York dated March 6, 2020, in the case of Jane Doe 17 v. The Estate of Jeffrey Epstein and associated entities. Judge Debra C. Freeman orders that attorney Andrew S. Buzin and his firm are relieved and discharged from representing the plaintiff, Jane Doe 17. The document lists numerous corporate defendants associated with Epstein's estate.
025.pdf
A court order from the Southern District of New York dated November 8, 2019, signed by Judge Paul A. Engelmayer. The order grants the motion of Plaintiff 'Jane Doe 17' to proceed anonymously in her case against the executors of Jeffrey Epstein's estate (Indyke and Kahn) and various associated corporate entities.
024-02.pdf
A proposed court order from November 2019 in the Southern District of New York regarding case 1:19-cv-09610-PAE. The document grants Plaintiff Jane Doe 17's motion to proceed anonymously in a lawsuit against the Estate of Jeffrey Epstein (represented by Indyke and Kahn) and numerous associated corporate entities.
024-01.pdf
This document is a legal motion filed on November 8, 2019, in the Southern District of New York, requesting that Plaintiff 'Jane Doe 17' be allowed to proceed anonymously in her lawsuit against the Estate of Jeffrey Epstein and associated entities. The motion argues that the sensitive nature of the sexual assault allegations, the risk of retaliation due to Epstein's wealth and connections, and the lack of public interest in her specific identity outweigh the presumption of open proceedings. Attached as Exhibit A is a September 11, 2019 Order from Judge P. Kevin Castel in a similar case (Katlyn Doe v. Indyke), which granted anonymity under nearly identical circumstances.
022.pdf
This document is an Appearance of Counsel form filed on November 6, 2019, in the United States District Court for the Southern District of New York (Case No. 1:19-cv-09610-PAE). Attorney Alan Goldfarb of Miami, Florida, is entering his appearance to represent the Plaintiff, identified as Jane Doe 17, in a lawsuit against Darren K. Indyke and Richard D. Kahn (executors of the Epstein Estate).
019.pdf
This document is an Appearance of Counsel form filed on October 28, 2019, in the United States District Court for the Southern District of New York (Case 1:19-cv-09610-PAE). Attorney David H. Brodie enters his appearance as counsel for 'All plaintiffs' (identified as Jane Doe 17 in the caption) in the lawsuit against Darren K. Indyke and Richard D. Kahn.
018.pdf
This is an Appearance of Counsel form filed on October 28, 2019, in the United States District Court for the Southern District of New York. Attorney Laura J. Starr is entering her appearance to represent 'All plaintiffs' (specifically Jane Doe 17) in the case against Darren K. Indyke and Richard D. Kahn.
016.pdf
This document is a court order from the Southern District of New York filed on October 25, 2019, in the case of Jane Doe 17 v. The Estate of Jeffrey E. Epstein and various associated entities. Judge Paul A. Engelmayer granted the motion for attorney David H. Brodie to appear Pro Hac Vice on behalf of the plaintiff.
015.pdf
This document is a court order from the Southern District of New York dated October 25, 2019, in the case of Jane Doe 17 v. The Estate of Jeffrey Epstein and associated entities. Judge Paul A. Engelmayer signed the order granting attorney Alan Goldfarb's motion to appear *pro hac vice* on behalf of the plaintiff.
007.pdf
This document is a formal Summons in a Civil Action filed on October 22, 2019, in the Southern District of New York (Case 1:19-cv-09610). The plaintiff, identified as Jane Doe 17, is suing the Estate of Jeffrey E. Epstein (represented by Darren K. Indyke and Richard D. Kahn) and numerous associated corporate entities (Nine East 71st Street Corp, Laurel Inc, NES LLC, etc.). The summons instructs the defendants to respond within 21 days to avoid a default judgment and lists the plaintiff's legal representation.
070.pdf
A court order dated September 4, 2020, by Magistrate Judge Debra Freeman of the Southern District of New York. The order directs the docketing of stays in multiple lawsuits against Indyke et al. and Nine East 71st Street et al. to allow plaintiffs to pursue settlements through the Epstein Victims’ Compensation Program. Parties are required to submit status reports starting October 1, 2020.
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