U.S. Virgin Islands
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Epstein_Part_17_(Redacted).pdf
This document contains several newspaper clippings from The Palm Beach Post in late July and early August 2006, detailing Jeffrey Epstein's arrest and indictment for soliciting prostitution. The articles cover his booking, release on bond, his attorney Jack Goldberger's claims of a 'distorted view' from police, and background information on Epstein's properties, social connections, and past legal troubles. The clippings also mention the involvement of State Attorney Barry Krischer and Palm Beach Police Chief Michael Reiter in the case.
038.pdf
This document is a Memorandum of Law filed on November 29, 2019, by the defendants (Estate of Jeffrey Epstein and associated corporate entities) in the case VE v. Indyke et al. The defendants move to dismiss several counts of the plaintiff's complaint, arguing that the battery claim is time-barred and not revived by the Child Victims Act because it is distinct from claims under NY Penal Law § 130. Furthermore, they argue that negligence claims against the corporate defendants (Nine East, FTC, and NES) are based on vague, conclusory allegations that fail to establish a duty of care, breach, or proximate cause, and that punitive damages are legally barred against an estate.
011.pdf
This document is a letter from the U.S. Attorney's Office to Judge Richard Berman arguing for the pretrial detention of Jeffrey Epstein. The Government outlines Epstein's extreme flight risk due to his wealth (over $500 million), international ties (Paris, US Virgin Islands), and access to private aircraft (noting over 20 international flights since 2018). It also details the danger he poses to the community, citing the recent discovery of lewd photos of minors in his home and a history of witness intimidation, including specific wire transfers made to potential witnesses following negative press coverage in late 2018.
025.pdf
This document is a Memorandum of Law in Support of Defendants' Motion to Dismiss, filed in the United States District Court for the Southern District of New York in the derivative litigation against JP Morgan Chase & Co. It outlines arguments regarding pleading standards, demand futility, and failure to state claims against the defendants, including specific points related to JPMorgan's termination of Epstein as a client and the oversight of internal controls by the board of directors. The document includes a table of authorities citing numerous legal cases.
2022.02.22%20Order%20Scheduling%20Hearing.pdf
A court order from the Superior Court of the Virgin Islands dated February 22, 2022, in the case of Ghislaine Maxwell v. Estate of Jeffrey E. Epstein et al. (Case No. ST-2020-CV-00155). Judge Harold W.L. Willocks ordered a status conference to be held via Zoom on March 9, 2022. The defendants include Epstein's estate, his executors Darren Indyke and Richard Kahn, and NES, LLC.
044.pdf
This document is a legal filing from May 2020 in the case of Teresa Helm v. The Estate of Jeffrey Epstein. It contains a letter from the Plaintiff's counsel arguing that the Estate Executors are obstructing discovery by limiting it to a narrow time window in 2002 and refusing to answer questions fully. The attached Exhibit A contains the Defendants' supplemental responses to interrogatories, in which they identify specific staff members (including Ghislaine Maxwell, Sarah Kellen, and Lesley Groff) who worked at Epstein's New York home during late 2002, list various email accounts and phone numbers associated with Epstein, and identify Shoppers Travel, Inc. as his travel agency. No specific flight logs or aircraft manifests are included in the document.
002.pdf
This document is a Civil Cover Sheet filed on November 11, 2019, in the Southern District of New York for a lawsuit brought by Teresa Helm against the Estate of Jeffrey Epstein. The defendants named are Darren K. Indyke and Richard D. Kahn in their capacities as executors of Epstein's estate. The nature of the suit is classified as 'Other Personal Injury' under Torts, and the plaintiff demands a jury trial.
002.pdf
This document is a Civil Cover Sheet filed on November 12, 2019, in the Southern District of New York for a lawsuit initiated by Maria Farmer against Darren K. Indyke and Richard D. Kahn in their capacities as executors of the Estate of Jeffrey Edward Epstein. The nature of the suit is categorized as 'Other Personal Injury' under diversity jurisdiction, as the plaintiff resides in Arkansas and the defendants are deemed citizens of the U.S. Virgin Islands (Epstein's domicile). The plaintiff demands a jury trial.
026.pdf
This document is an October 2008 court order granting a motion to remand the civil case 'Jane Doe v. Jeffrey Epstein, Haley Robson, and Sarah Kellen' back to state court. The federal judge ruled that the plaintiff had valid state-law claims (civil conspiracy, etc.) against defendant Haley Robson, a Florida resident, meaning her inclusion in the lawsuit was not 'fraudulent joinder' intended solely to defeat federal diversity jurisdiction. The order details the plaintiff's allegations that Robson recruited her at age 14 from Loxahatchee, Kellen managed the encounter, and Epstein sexually abused her at his Palm Beach mansion.
001.pdf
This document is a Notice of Removal filed by defendants Jeffrey Epstein, Sarah Kellen, and Haley Robson, seeking to move a civil lawsuit filed by Jane Doe from the Circuit Court of the Fifteenth Judicial Circuit in Palm Beach County, Florida, to the United States District Court for the Southern District of Florida. The defendants argue that the non-diverse defendant, Haley Robson, was fraudulently joined solely to defeat diversity jurisdiction and prevent removal. Attached as Exhibit A is a deposition transcript of Jane Doe (whose name is redacted) taken on February 20, 2008, in a related criminal case, where she is questioned about her age, MySpace profiles, inconsistencies in her statements to police regarding sexual contact with Epstein, and her interactions with various attorneys and law enforcement officials.
016.pdf
This document is a Motion for an Order for the Preservation of Evidence filed by Plaintiffs Jane Doe No. 101 and 102 against Jeffrey Epstein in May 2009. The motion requests the court to order Epstein to preserve evidence related to allegations of sexual abuse, specifically citing evidence seized during a 2005 police search and other electronic/physical records located across his six international properties. The document lists numerous attorneys involved in related cases and references Epstein's previous guilty plea in 2008.
028.pdf
This document is a motion filed on May 26, 2009, by Plaintiffs Jane Doe No. 101 and 102 requesting a court order to compel Jeffrey Epstein to preserve all evidence, including electronic data, documents, and physical items located at his six international properties. The plaintiffs argue that given Epstein's status as a sex offender and his previous attempts to reclaim seized property (which may include child pornography), there is a high risk he will destroy incriminating evidence, including flight logs ('records of domestic and international travel') and computer files. The document lists the specific types of digital and physical evidence sought and notes that Epstein's counsel had failed to respond to a previous preservation letter.
053.pdf
This document is a legal filing in the civil case Jane Doe 1000 v. Indyke & Kahn. It includes a letter from Plaintiff's counsel arguing that the Epstein Estate executors are improperly limiting discovery to a 4-year period and refusing to produce documents regarding Epstein's broader sex-trafficking conspiracy. Attached as Exhibit A are the Defendants' supplemental responses to interrogatories, which list specific employees (including Ghislaine Maxwell, Sarah Kellen, and pilots like Larry Visoski), email accounts used by Epstein (specifically noting 'jeevacation@gmail.com' and 'jeeproject@yahoo.com'), and numerous phone numbers associated with his properties in New York, Palm Beach, New Mexico, and the Virgin Islands.
046.pdf
This document is a legal filing from Plaintiff Jane Doe 1000's counsel requesting a pre-motion conference to compel Defendants (Epstein's executors Indyke and Kahn) to produce discovery documents and answer interrogatories. The filing includes exhibits of the discovery requests, which seek detailed information on Epstein's flight logs, financial transactions, communications with high-profile individuals (Prince Andrew, Bill Clinton, Alan Dershowitz), and the structure of his alleged sex-trafficking operation. The Defendants have objected to almost all requests, claiming they are overbroad or that they lack knowledge because Epstein is deceased, prompting the Plaintiff to seek court intervention. Note: While flight logs are requested, no actual flight data is contained in this document.
002.pdf
Civil Cover Sheet filed on November 14, 2019, in the Southern District of New York for a lawsuit brought by Jane Doe 1000 against Darren K. Indyke and Richard D. Kahn as executors of the Estate of Jeffrey Epstein. The suit is categorized under 'Other Personal Injury' and claims diversity jurisdiction, noting Epstein's domicile as the U.S. Virgin Islands. The plaintiff demands a jury trial.
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.
012.pdf
This document is a letter from Bennet J. Moskowitz of Troutman Sanders LLP to Judge Andrew L. Carter Jr., dated January 24, 2020. It serves as a pre-motion letter outlining the Estate of Jeffrey Epstein's intent to move for dismissal of a lawsuit filed by Juliette Bryant. The Estate argues that Bryant's claims regarding alleged sexual abuse between 2002 and 2004 are time-barred by the statutes of limitations in New York, USVI, Florida, and New Mexico, and that she cannot rely on the Child Victims Act or tolling because she was an adult (age 20-22) at the time of the alleged incidents. Additionally, the letter argues that punitive damages cannot be recovered from a decedent's estate under the relevant laws.
002.pdf
Civil Cover Sheet (Form JS 44) filed on November 14, 2019, in the Southern District of New York. Plaintiff Juliette Bryant, a resident of South Africa, is suing Darren K. Indyke and Richard D. Kahn in their capacities as executors of the Estate of Jeffrey Epstein. The nature of the suit is classified as 'Other Personal Injury' tort, with jurisdiction based on diversity (foreign citizen vs citizens of another state/USVI).
EFTA00039019.pdf
An April 2023 email chain between Daniel Ruzumna (attorney for the Epstein Estate) and an FBI Special Agent regarding the discovery of potential Child Sexual Abuse Material (CSAM). During a legal review of approximately 1,100 videos from Epstein's files, co-counsel discovered a video shared with Epstein by a convicted sex offender that potentially depicted minors. The Estate halted the review and reported the finding to the FBI for guidance.
EFTA00039017.pdf
This document contains an email chain from April 19, 2023, between Daniel Ruzumna (attorney for the Epstein Estate) and an FBI Special Agent regarding the discovery of potential Child Sexual Abuse Material (CSAM). Attorneys reviewing approximately 1,100 videos from Epstein's files for civil litigation discovered a video depicting topless women, reportedly shared with Epstein by a convicted sex offender. The attorneys halted their review and contacted the FBI for guidance on how to proceed.
EFTA00039011.pdf
This document is an email chain from April 19, 2023, between Daniel Ruzumna (attorney for the Epstein Estate) and an FBI Special Agent from the Child Exploitation/Human Trafficking division. 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 (CSAM) depicting topless women, which had been shared with Epstein by a convicted sex offender. The emails coordinate a phone call between the attorneys and the FBI to discuss the discovery and next steps.
EFTA00039004.pdf
This document is a chain of emails from April 2023 between lawyers representing the Estate of Jeffrey Epstein (Patterson Belknap and Hughes Hubbard) and the FBI Child Exploitation/Human Trafficking unit. The lawyers report finding a video potentially containing Child Sexual Abuse Material (CSAM) among 1,100 videos extracted from Epstein's files during a document review. They arrange a meeting at the Hughes Hubbard offices in New York to discuss the finding and hand over information to the FBI.
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.
EFTA00037900.pdf
This document is an Interim Report of Investigation from Ben Nivens of Hope for Justice, dated August 1, 2019. It details allegations from a victim who claims she was trafficked at age 5 in Florida and at age 17 in the U.S. Virgin Islands, describing severe abuse including being kept in a crawl space and abused in a room resembling a horse stall. The investigator concludes that the allegations should be forwarded to the FBI's New York Field Office for inclusion in their investigative file on a redacted individual (contextually likely Jeffrey Epstein).
EFTA00037378.pdf
This document is a post-indictment (circa July 2019) investigative summary by federal authorities detailing the history of investigations into Jeffrey Epstein from 2005 to 2019. It outlines his sexual abuse of minors in New York, Florida, and other locations, specifically noting that victims were as young as 14 and were paid $200-$300 per encounter. The text mentions cooperating witnesses (Victim-1, 2, and 3), the role of redacted co-conspirators in recruiting minors, and the prosecution's intent to pursue these co-conspirators following Epstein's indictment.
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