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073.pdf
This document is a status report letter filed on November 2, 2020, by attorney Bennet J. Moskowitz of Troutman Pepper on behalf of the Estate of Jeffrey Epstein and the Plaintiff 'VE'. It informs Judge Debra C. Freeman that the Plaintiff has submitted a claim to the Epstein Victims' Compensation Program which is currently under review. Consequently, both parties jointly request that the ongoing litigation (Case No. 1:19-cv-07625-AJN-DF) remain stayed to preserve resources and judicial economy.
060.pdf
A letter from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Alison J. Nathan regarding the case VE v. Nine East 71st Street, et al. The letter serves to supplement a pending motion to dismiss by submitting a recent Opinion & Order from Judge Paul A. Engelmayer in a related case (Mary Doe v. Indyke et al.), which dismissed punitive damages claims against the Estate of Jeffrey Epstein's executors. The defense argues this precedent supports dismissing punitive damages in the current action.
050.pdf
This document is a letter filed on January 2, 2020, by attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Alison J. Nathan. The letter pertains to the case 'VE v. Nine East 71st Street, et al.' and requests oral argument on the Defendants' Motion to Dismiss the Plaintiff's Amended Complaint. Moskowitz represents the Co-Executors of the Estate of Jeffrey Epstein (Darren K. Indyke and Richard D. Kahn) and associated entities.
025.pdf
This document is a letter dated October 29, 2019, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Alison J. Nathan. The letter represents the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) and associated corporate entities in the case VE v. Nine East 71st Street, et al. It serves to clarify the record regarding an ex parte order issued in a related case (Katlyn Doe) and requests an extension until November 15, 2019, to respond to the Plaintiff's Motion to Proceed Anonymously.
042.pdf
This document is a legal letter dated May 11, 2020, from attorney Sigrid S. McCawley (representing Plaintiff Teresa Helm) to Judge Debra Freeman. The letter requests a court conference to address the Defendants' (Indyke and Kahn, executors of the Epstein estate) alleged failure to participate in discovery, specifically their refusal to produce documents related to Jeffrey Epstein's sex-trafficking conspiracy and to answer interrogatories regarding email accounts used by Epstein. McCawley argues that the Defendants are engaging in obstructionist delay tactics.
049.pdf
This document is a legal letter dated September 10, 2021, filed by attorney Bennet J. Moskowitz of Troutman Pepper on behalf of the Executors of the Estate of Jeffrey E. Epstein (Darren K. Indyke and Richard D. Kahn). The letter is addressed to Judge Debra C. Freeman regarding the case 'Jane Doe v. Darren K. Indyke and Richard D. Kahn' (Case 1:20-cv-02365). The defense informs the court that they are working jointly with the Plaintiff to settle the matter out of court and requests a sixty-day stay of proceedings until November 9, 2021.
026.pdf
A letter dated June 30, 2021, from attorney Bennet J. Moskowitz of Troutman Pepper to Judge Debra C. Freeman regarding the case Jane Doe v. Darren K. Indyke and Richard D. Kahn (Executors of the Estate of Jeffrey E. Epstein). The letter informs the court that the Plaintiff wishes to lift the stay on the action and outlines agreed-upon deadlines for the Defendants to respond to the complaint and for the Plaintiff to file a motion regarding anonymity.
023.pdf
A status report filed on April 1, 2021, by attorney Bennet J. Moskowitz representing the Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in a civil suit brought by a Jane Doe. The letter informs Judge Freeman that the Plaintiff has submitted a claim to the Epstein Victims' Compensation Program. The parties request that the civil case remain stayed while the compensation claim is considered, noting that a resolution through the Program would lead to the discontinuation of the lawsuit.
018.pdf
This document is a legal status report filed on December 1, 2020, by attorney Bennet J. Moskowitz regarding the civil case of Jane Doe v. the Executors of the Estate of Jeffrey E. Epstein. The letter informs Judge Debra C. Freeman that the Plaintiff intends to submit a claim to the Epstein Victims' Compensation Program and requests that the current litigation remain stayed to preserve resources pending the outcome of that administrative claim.
017.pdf
A legal status report filed on November 2, 2020, by attorney Bennet J. Moskowitz on behalf of the Co-Executors of the Jeffrey Epstein Estate (Indyke and Kahn). The letter informs Judge Freeman that the Plaintiff (Jane Doe) intends to submit a claim to the Epstein Victims' Compensation Program. Consequently, both parties request that the lawsuit remain stayed to allow for potential resolution through the Program outside of court.
037.pdf
A letter dated April 13, 2020, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Debra C. Freeman. The letter represents the Co-Executors of the Estate of Jeffrey E. Epstein (Indyke and Kahn) in lawsuits brought by Jane Doe 15, Mary Doe, and Teala Davies. It requests a 30-day extension for various discovery and filing deadlines due to the COVID-19 pandemic, noting that the Plaintiffs have consented to this request.
024.pdf
Legal correspondence from Troutman Sanders LLP to Judge Debra C. Freeman dated February 26, 2020, regarding the case Teala Davies v. Indyke et al. The letter requests approval for a briefing schedule concerning a Motion to Dismiss filed by the Co-Executors of the Estate of Jeffrey E. Epstein. It references prior settlement discussions held during a court conference on February 11, 2020.
028.pdf
Legal correspondence dated May 8, 2020, from Matthew J. Aaronson (Troutman Sanders LLP) to Judge Debra C. Freeman. The letter represents the Co-Executors of the Jeffrey Epstein Estate (Indyke and Kahn) and objects to the Plaintiffs' request for a pre-motion conference regarding discovery disputes. The defense argues the request is premature as the parties were still in the 'meet-and-confer' process, and requests either a denial of the conference or permission to respond by May 13, 2020.
DOJ-OGR-00001866.jpg
This legal letter, sent by attorney Bobbi C. Sternheim on behalf of her client Ghislaine Maxwell to Judge Alison J. Nathan, formally complains about Maxwell's harsh and restrictive conditions at the Metropolitan Detention Center (MDC). The letter refutes a previous communication from MDC staff, detailing issues such as significant weight loss, isolation, constant surveillance, and a recent quarantine that hindered her defense preparation. Sternheim renews the request for the MDC Warden, Heriberto Tellez, to respond directly to the Court and justify these conditions.
DOJ-OGR-00002156.jpg
This document is a character reference letter dated December 7, 2020, written by an anonymous individual to Judge Alison J. Nathan concerning the criminal case against Ghislaine Maxwell. The author, who claims a long-standing personal relationship with Maxwell, provides a positive portrayal of her character, citing her as an inspiration who taught them about generosity and resilience. The letter explicitly requests that the judge consider granting bail to Maxwell.
DOJ-OGR-00019317.jpg
This is a legal letter from attorney David Boies representing plaintiff Annie Farmer, addressed to Judge Debra C. Freeman on May 18, 2020. The letter argues against Defendant Ghislaine Maxwell's request to stay discovery in the civil case pending a criminal investigation, citing case law that characterizes such stays as extraordinary remedies when no indictment has yet been issued. Boies asserts that Maxwell's motion is an unjustified attempt to delay litigation.
DOJ-OGR-00010507.jpg
This document is a letter of support dated April 24, 2022, from Catherine Vaughan-Edwards to Judge Alison J. Nathan regarding the sentencing of Ghislaine Maxwell. Vaughan-Edwards describes her long-standing relationship with Maxwell, which began when Maxwell employed her in 1988 and evolved into a close, personal friendship. The letter aims to provide a positive character reference for Maxwell by highlighting their enduring bond, including Maxwell's role as godmother to one of Vaughan-Edwards' sons, to be considered by the court during sentencing.
DOJ-OGR-00010501.jpg
This is a letter of support from Ian Maxwell to Judge Alison J. Nathan, written on April 29, 2022, regarding his sister, Ghislaine, who has been found guilty of unspecified charges. Maxwell attests to his sister's good character over their 60+ year relationship, highlighting her generosity through donations, paying for family members' education, and providing financial and housing support to friends and family, including himself. He also notes her personal achievements and courage during her incarceration, appealing to the judge to consider these positive aspects of her character.
DOJ-OGR-00010486.jpg
This is a joint letter dated May 3, 2022, from Ghislaine Maxwell's siblings, Anne Holve and Dr. Philip Maxwell, to Judge Alison J. Nathan. The authors express concern that the legal process may not fully account for Ghislaine's traumatic background, specifically citing a 1961 car accident that left their brother Michael in a coma for seven years, an event which occurred when Ghislaine was three days old and deeply impacted the family.
DOJ-OGR-00010414.jpg
This document is a letter from the United States Attorney to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. The letter concerns the government's motion for the exclusion of time for Counts Seven and Eight under the Speedy Trial Act until June 28, 2022, the scheduled date of sentencing.
DOJ-OGR-00009614.jpg
This legal document is a letter dated March 1, 2022, from attorney Todd A. Spodek of Spodek Law Group to District Judge Alison J. Nathan. The letter concerns the case of United States v. Ghislaine Maxwell in the Southern District of New York. Spodek informs the court that his client, identified only as Juror 50, will invoke their Fifth Amendment privilege against self-incrimination at a court-ordered hearing scheduled for March 8, 2022.
DOJ-OGR-00009540.jpg
This legal document is a letter dated February 24, 2022, from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. The letter serves as a response to a court order issued the same day, proposing that the defense will make limited redactions to an attached Opinion and Order that was filed under a temporary seal.
DOJ-OGR-00002907.jpg
This is a letter dated April 7, 2021, from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. The letter strongly objects to the conditions of Ms. Maxwell's pretrial detention at the MDC, describing them as a form of "'pay-it-forward' punishment." It details a recent incident involving a pervasive sewage stench in her unit and argues that the government's portrayal of her confinement as superior is inaccurate and misses the point of her overly restrictive and unwarranted detention.
DOJ-OGR-00005241.jpg
This is a letter from Ghislaine Maxwell's attorney, Bobbi C. Sternheim, to Judge Alison J. Nathan, dated October 15, 2021. Sternheim complains that the government's explanation for the severely delayed delivery of Maxwell's legal mail at the Metropolitan Detention Center (MDC) is inadequate and hinders Maxwell's ability to prepare for trial. The letter argues that the MDC is capable of timely delivery, citing the extensive resources used to monitor Maxwell, and criticizes the government's refusal to facilitate special delivery for evidence.
DOJ-OGR-00008822.jpg
This is a legal letter dated January 19, 2022, from attorney Bobbi C. Sternheim to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. The letter serves to inform the court that Maxwell's counsel has filed a Motion for a New Trial and requests that all materials concerning Juror No. 50 be kept under seal until the court rules on the motion.
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