SOUTHERN DISTRICT OF NEW YORK
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065.pdf
A 'Notice of Change of Address' filed on July 9, 2020, in the Southern District of New York case Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn. Attorney Mary 'Molly' S. Dirago notifies the court that her firm name has changed from Troutman Sanders LLP to Troutman Pepper Hamilton Sanders LLP, while her physical address in Chicago remains the same.
028.pdf
This document is a court order from the United States District Court for the Southern District of New York, dated February 12, 2020, in the case of Jane Doe 1000 v. Indyke, et al. Judge Lewis J. Liman denied a request for a pre-motion conference as moot, allowing the Defendant to proceed directly with filing a motion to dismiss.
027.pdf
Scheduling Order issued by Magistrate Judge Debra Freeman on February 11, 2020, for multiple consolidated cases against the Epstein estate (Indyke et al.). The order sets deadlines for initial disclosures, discovery requests, motions to amend, fact discovery completion (June 10, 2020), and expert reports.
011.pdf
This document is a Waiver of the Service of Summons filed on November 27, 2019, in the Southern District of New York for Case 1:19-cv-10577-LGS (Jane Doe 1000 v. Darren K. Indyke et al). Attorney Bennet Moskowitz of Troutman Sanders LLP signs on behalf of defendants Darren K. Indyke and Richard D. Kahn (executors of the Epstein estate), acknowledging receipt of the complaint and agreeing to waive formal service. The waiver is addressed to plaintiff's attorney David Boies.
010.pdf
This document is a legal filing dated November 21, 2019, containing a Motion for Admission Pro Hac Vice for attorney Sigrid S. McCawley of Boies Schiller Flexner LLP to represent Plaintiff Jane Doe 1000 in the case against the Estate of Jeffrey Epstein. The document includes McCawley's declaration of good standing, a supporting Certificate of Good Standing from the Supreme Court of Florida, and a proposed order for the judge to sign granting the admission. The defendants listed are Darren K. Indyke and Richard D. Kahn in their capacities as executors of Epstein's estate.
007.pdf
This document is a legal memorandum filed on November 20, 2019, in the Southern District of New York, supporting a motion for 'Jane Doe 1000' to proceed anonymously in her civil suit against the Estate of Jeffrey Epstein. The plaintiff alleges she was sexually trafficked and abused by Epstein and Ghislaine Maxwell, detailing forced sexual acts and the use of sex toys. The motion argues that anonymity is necessary to protect the plaintiff from severe emotional distress, public scrutiny, and potential retaliation from Maxwell, who was described as being 'at large' at the time of the filing.
022.pdf
This document is a Motion for Admission Pro Hac Vice filed on February 13, 2020, in the case of Teala Davies v. The Estate of Jeffrey Epstein. Attorney Mary 'Molly' S. DiRago of Troutman Sanders LLP requests permission to represent the defendants, Darren K. Indyke and Richard D. Kahn (executors of Epstein's estate), in the Southern District of New York. The attorney attests to her good standing in Illinois and lack of disciplinary history.
021.pdf
This document is a Scheduling Order issued on February 11, 2020, by U.S. Magistrate Judge Debra Freeman in the Southern District of New York. It consolidates deadlines for discovery, expert reports, and settlement discussions across thirteen related civil cases involving plaintiffs (many anonymous Does) suing 'Indyke et al.' (referring to the Epstein estate executors) and 'Nine East 71st Street'. The order establishes a timeline for fact discovery to conclude by June 2020 and expert discovery by July 2020.
008.pdf
This is a Notice of Appearance filed on November 22, 2019, in the United States District Court for the Southern District of New York (Case No. 19 Civ. 10788). Attorney Daniel Mullkoff of Cuti Hecker Wang LLP formally enters his appearance as counsel for the Plaintiff, Teala Davies, in her lawsuit against Darren K. Indyke and Richard D. Kahn, the executors of Jeffrey Epstein's estate.
005.pdf
This document is a Summons in a Civil Action filed on November 22, 2019, in the Southern District of New York (Case No. 19 Civ. 10788). The plaintiff, Teala Davies, is suing Darren K. Indyke and Richard D. Kahn in their capacity as Executors of the Estate of Jeffrey E. Epstein. The summons directs Indyke to respond to the complaint within 21 days and lists his attorney as Bennet J. Moskowitz of Troutman Sanders LLP.
003.pdf
This document is a 'Summons in a Civil Action' filed on November 21, 2019, in the Southern District of New York (Case 1:19-cv-10788). The plaintiff, Teala Davies, is suing Darren K. Indyke and Richard D. Kahn in their capacities as Executors of the Estate of Jeffrey E. Epstein. The summons is addressed to Indyke via his attorney Bennet J. Moskowitz and requires a response within 21 days.
024.pdf
This is a Memorandum of Law filed by the defendants (Executors of the Estate of Jeffrey Epstein) in support of their motion to dismiss the plaintiff's complaint. The defendants argue that the plaintiff's claims of sexual assault and battery are time-barred by the applicable statutes of limitations in multiple jurisdictions (USVI, NY, NM, FL, France) and that exceptions like CPLR 215(8)(a) or equitable tolling do not apply. Additionally, the defendants argue that punitive damages are not recoverable against a deceased tortfeasor's estate under the laws of any relevant jurisdiction.
022.pdf
A Notice of Change of Address filed on March 23, 2020, in the SDNY case Juliette Bryant v. Darren K. Indyke and Richard D. Kahn (Executors of the Estate of Jeffrey Epstein). Attorney Mary "Molly" S. DiRago of Troutman Sanders LLP notifies the court that her firm has moved from One North Wacker Drive to 227 W. Monroe Street in Chicago, IL. She confirms she will continue as counsel of record.
013.pdf
This document is a letter from plaintiff's counsel (Boies Schiller Flexner) to Judge Andrew L. Carter Jr. in the case *Bryant v. Indyke et al.*, dated January 29, 2020. The letter argues against the defendants' anticipated motion to dismiss, asserting that Juliette Bryant's claims are timely under New York statutes (CPLR § 215(8)(a) and § 213-c) and the doctrine of equitable estoppel due to Epstein's intimidation tactics. It details that Bryant was a resident of New York during the abuse (2002-2005 era) and was raped repeatedly by Epstein at his New York home.
011.pdf
A court order from the Southern District of New York dated January 14, 2020 (misdated 2019 in signature), by Magistrate Judge Debra Freeman. The order addresses thirteen separate civil cases brought by alleged victims of Jeffrey Epstein against his estate and associates (Indyke et al.). The judge sets deadlines for proposed discovery schedules (Feb 6, 2020) and schedules a joint pretrial conference for February 11, 2020, to coordinate supervision despite the cases not being formally consolidated.
006.pdf
This document is a Motion for Admission Pro Hac Vice filed on November 21, 2019, in the Southern District of New York. Attorney Sigrid S. McCawley of Boies Schiller Flexner LLP requests permission to represent plaintiff Juliette Bryant in her lawsuit against the executors of the Estate of Jeffrey Epstein (Indyke and Kahn). The filing includes a declaration of good standing and a certificate from the Supreme Court of Florida confirming McCawley's bar admission since 1997.
001.pdf
This document is a legal complaint filed by Juliette Bryant against the executors of Jeffrey Edward Epstein's estate. It details allegations of sexual abuse and trafficking by Epstein, beginning when Bryant was 20 years old, and describes Epstein's extensive sex trafficking network and his previous legal actions and statements regarding his conduct.
EFTA00039001.pdf
This document is an email from April 2023 sent by Daniel Ruzumna, an attorney for the Epstein Estate, to a federal agent. Ruzumna reports that during a court-ordered review of approximately 1,100 videos from Epstein's files, co-counsel discovered a video potentially containing child pornography, which had been sent to Epstein by a convicted sex offender. The review was immediately halted, and the Estate sought guidance from federal authorities.
EFTA00038972.pdf
This document is an email thread from October 2021 between an FBI Special Agent from the Child Exploitation/Human Trafficking unit and an Assistant US Attorney from the SDNY. They are discussing the location and retrieval of handwritten interview notes from August 2006 (likely related to the original Epstein investigation) for use as '3500 materials' (Jencks Act disclosures) in an upcoming legal deadline. The FBI agent confirms locating the notes in an evidence container labeled 'MM13' and a folder marked 'Flight Records FAA-AMOC'.
EFTA00038968.pdf
This document is an email chain from June 2022 between an Assistant U.S. Attorney (SDNY) and likely an FBI agent. The USANYS office was nominating the 'Epstein / Maxwell case' team for a DOJ Director's Award for Superior Performance by a Litigation Team. The emails discuss gathering personal information (DOB, SSN, GS scale) from law enforcement partners to include them in the nomination, noting that the submission was urgent as 'sentencing is done' (referring to Ghislaine Maxwell's sentencing around that time).
EFTA00038962.pdf
This document is an email forwarding a Notice of Electronic Filing from the U.S. District Court (SDNY) regarding the case USA v. Maxwell. On April 29, 2022, Judge Alison J. Nathan issued an Opinion & Order denying Ghislaine Maxwell's Rule 29 motion and confirming her conviction on Counts Three, Four, and Six, while dismissing other counts as multiplicitous. The order explicitly mentions Jeffrey Epstein as a co-conspirator in a scheme to abuse underage girls and confirms Maxwell's sentencing date for June 28, 2022.
EFTA00038957.pdf
An email chain from June 2022 in which an Assistant U.S. Attorney from the Southern District of New York contacts a law enforcement partner. The attorney is gathering personal information (DOB, SSN, GS scale) to include the partner in a nomination for a DOJ Director's Award for 'Superior Performance by a Litigation Team' regarding the Epstein / Maxwell case, specifically citing efforts with victims.
EFTA00038949.pdf
This document is an email chain from September 2021 regarding the transfer of evidence in the Ghislaine Maxwell case. An Assistant US Attorney from the SDNY requests 'Amazon returns' related to Maxwell, and a respondent confirms the upload of these files (both original and Bates-stamped versions SDNY_GM_00000966-976) to a USAfx folder.
EFTA00038936.pdf
An email dated October 23, 2021, from an Assistant United States Attorney (SDNY) to an FBI contact regarding the jury selection schedule for an upcoming trial (likely United States v. Ghislaine Maxwell, given the date and Judge Nathan's name). The email attaches a court order summarizing what Judge Nathan reviewed during a recent conference.
EFTA00038919.pdf
This document is an email chain forwarded on January 3, 2022. It contains an original email from attorney Jack Scarola dated December 29, 2021, issuing a statement on the conviction of Ghislaine Maxwell. Scarola expresses satisfaction with the verdict on behalf of his clients but notes that other co-conspirators in Epstein's enterprise have yet to be held accountable.
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