Daniel Patrick Moynihan United States Courthouse
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042.pdf
A letter filed on April 15, 2020, by attorney Bennet J. Moskowitz of Troutman Sanders LLP to Magistrate Judge Debra C. Freeman. The letter requests a 30-day extension on various discovery and filing deadlines in three cases involving the Estate of Jeffrey Epstein (Plaintiffs Jane Doe 1000, Teresa Helm, and Juliette Bryant) due to the COVID-19 pandemic. The Judge signed and ordered the request on the same day.
033.pdf
This document is a Notice of Motion to Dismiss filed on February 28, 2020, in the Southern District of New York (Case 1:19-cv-10577). The defendants, Darren K. Indyke and Richard D. Kahn (Executors of the Estate of Jeffrey Epstein), represented by Troutman Sanders LLP, are moving to dismiss the complaint of Plaintiff Jane Doe 1000 with prejudice pursuant to Rule 12(b)(6).
040.pdf
This document is a legal letter dated April 30, 2020, filed by attorney Bennet J. Moskowitz of Troutman Sanders LLP on behalf of the Co-Executors of Jeffrey Epstein's estate (Darren K. Indyke and Richard D. Kahn). The letter is addressed to Magistrate Judge Debra Freeman in the case of Teala Davies v. Estate of Jeffrey Epstein. It serves to supplement a pending motion to dismiss by submitting a recent Opinion & Order from a related case (Jane Doe 15), in which Judge Paul A. Engelmayer dismissed a similar claim for punitive damages against the executors.
039.pdf
A letter dated April 28, 2020, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Debra Freeman regarding the case of Teala Davies v. the Estate of Jeffrey Epstein. The letter supplements 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 Co-Executors.
026.pdf
This document is a 'Notice of Defendants' Motion to Dismiss' filed on February 28, 2020, in the US District Court for the Southern District of New York (Case No. 1:19-cv-10788). The defendants, Darren K. Indyke and Richard D. Kahn (executors of Jeffrey Epstein's estate), represented by Bennet J. Moskowitz of Troutman Sanders LLP, are moving to dismiss the complaint filed by plaintiff Teala Davies with prejudice.
010.pdf
A letter from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Gregory H. Woods regarding the case 'Teala Davies v. Darren K. Indyke and Richard D. Kahn'. The letter requests a deadline extension to January 20, 2020, for the defendants (executors of Jeffrey Epstein's estate) to respond to the complaint and notes a scheduled Rule 26(f) conference for January 7, 2020.
026.pdf
A letter dated April 15, 2020, from attorney Bennet J. Moskowitz to Judge Debra C. Freeman requesting a 30-day extension for various deadlines in lawsuits filed by Jane Doe 1000, Teresa Helm, and Juliette Bryant against the Estate of Jeffrey Epstein. The request cites the ongoing pandemic as the reason for the delay and notes the consent of the plaintiffs. The document is signed 'SO ORDERED' by Judge Freeman on the same date.
025.pdf
This document is a letter from attorney Bennet J. Moskowitz to Judge Debra C. Freeman dated April 15, 2020. It requests a 30-day extension for various discovery and filing deadlines in civil cases brought by Jane Doe 1000, Teresa Helm, and Juliette Bryant against the Estate of Jeffrey Epstein, citing delays caused by the COVID-19 pandemic.
EFTA00037104.pdf
This document is a legal letter dated October 19, 2023, from a coalition of 17 State Attorneys General (led by New Mexico AG Raúl Torrez) to Judge Jed S. Rakoff regarding the case Doe v. JPMorgan Chase Bank, N.A. The Attorneys General object to Section 1.25 of the proposed settlement, which attempts to release 'sovereign or government' claims. They argue this language improperly interferes with their authority to bring parens patriae actions under the Trafficking Victims Protection Act (TVPA) on behalf of trafficking victims, contrasting this with the Deutsche Bank settlement which did not contain such a release.
EFTA00035425.pdf
This document is an official letter from the Warden of the Metropolitan Correctional Center (MCC) in New York to Judges Colleen McMahon and Richard Berman, dated August 10, 2019. It notifies the court of Jeffrey Epstein's death earlier that morning following an 'apparent suicide' in the Special Housing Unit. The letter confirms he was transported to New York Presbyterian-Lower Manhattan Hospital where he was pronounced dead, and notes that the FBI is investigating and an autopsy is pending.
EFTA00034372.pdf
This document is a letter dated August 12, 2019, from MCC Warden Lamine N'Diaye to District Judge Richard M. Berman. The Warden confirms that an internal investigation into a July 23, 2019 incident involving Jeffrey Epstein was completed, but details cannot be shared because the incident is now part of active FBI and OIG investigations.
EFTA00034341.pdf
This document is an official letter dated August 10, 2019, from the Warden of the Metropolitan Correctional Center (MCC) New York to Judges Colleen McMahon and Richard M. Berman. It formally notifies the court of the death of Jeffrey Epstein earlier that morning at 7:37 a.m. following an apparent suicide in his cell. The letter notes that the FBI is investigating and an autopsy is pending.
EFTA00031397.pdf
This document is an internal DOJ email chain from October 30, 2019, coordinating a response to an urgent request from the Office of the Deputy Attorney General (ODAG). ODAG required statistics regarding victim attendance and notification at the August 27, 2019, Epstein hearing to respond to a mandamus petition filed in the 11th Circuit Court of Appeals under the Crime Victims' Rights Act (CVRA). USANYS officials discussed the number of victims present (17 present, 7 statements read by others) and the statements made by attorney Brad Edwards regarding clients who could not attend.
EFTA00028158.pdf
This document is an email chain from July 2019 between staff at the US Attorney's Office for the Southern District of New York regarding updates to the 'Victim Witness' website for the case United States v. Jeffrey Epstein. The emails finalize the text for a public update announcing that on July 18, 2019, the court ruled Epstein would remain incarcerated pending trial, and scheduling the next pretrial conference for July 31, 2019.
EFTA00020947.pdf
This document is an email thread from July 19, 2019, between staff at the US Attorney's Office for the Southern District of New York (USANYS). They are drafting a 'VW Update' (likely Victim/Witness update) to notify interested parties about the court's July 18 ruling that Jeffrey Epstein would remain incarcerated pending trial. The emails also provide details for the next scheduled conference on July 31, 2019, before Judge Richard M. Berman.
EFTA00016286.pdf
This document is an opposition letter filed by Plaintiff Jane Doe's counsel against Ghislaine Maxwell's motion to stay civil proceedings in the case Doe v. Indyke. The Plaintiff argues that Maxwell has been actively participating in the litigation from jail (filing answers, issuing discovery requests) despite claiming it is a burden, and that a stay is not required for Plaintiff to participate in the Epstein Claims Resolution Program. The letter asserts that the public interest is best served by allowing the civil case to proceed to expose the criminal enterprise of Epstein and Maxwell.
DOJ-OGR-00015103.jpg
This is a legal letter dated August 5, 2025, from attorney Sigrid McCawley of Boies Schiller Flexner LLP to U.S. District Judges Berman and Engelmayer. The letter is written on behalf of victim Annie Farmer regarding the unsealing of grand jury transcripts for Jeffrey Epstein and Ghislaine Maxwell. The letter heavily criticizes the Department of Justice for failing to pursue further criminal investigations and notes that Maxwell is attempting to negotiate a pardon.
DOJ-OGR-00000771.jpg
A legal letter dated August 5, 2025 (Document 73), from the Edwards Henderson law firm to Judge Richard M. Berman regarding United States of America v. Jeffrey Epstein. The firm, representing numerous Epstein survivors, writes to address the DOJ's request to unseal grand jury materials, urging the court to protect victims' rights and privacy under the Crime Victims’ Rights Act (CVRA). The document is 'Memo Endorsed' and signed by Judge Berman.
DOJ-OGR-00000766.jpg
This is a memo dated August 5, 2025, from the law firm Boies Schiller Flexner LLP to federal judges Richard M. Berman and Paul A. Engelmayer. The firm, writing on behalf of victim Annie Farmer, responds to a notice about the potential unsealing of grand jury transcripts for Jeffrey Epstein and Ghislaine Maxwell. The memo strongly criticizes the U.S. Government for not pursuing further criminal investigations, despite admitting there were over a thousand victims, calling this inaction a 'cowardly abdication' of its duties.
DOJ-OGR-00000765.jpg
A legal letter dated August 5, 2025, from Hughes Hubbard & Reed LLP (representing the Estate of Jeffrey Epstein) to Judge Richard M. Berman. The letter states that the Epstein Estate takes no position regarding the Government's motion to unseal grand jury transcripts, provided that victim identities are protected via redaction.
DOJ-OGR-00000626.jpg
In a letter dated August 12, 2019, Lamine N'Diaye, the Warden of the Metropolitan Correctional Center (MCC), responds to an inquiry from Judge Richard M. Berman. The Warden confirms that the ongoing FBI and OIG investigations into the August 10, 2019 incident involving inmate Jeffrey Epstein will also encompass a prior incident that occurred on July 23, 2019. Due to the active investigations, the Warden states he is unable to release any information about the internal investigation that had already been completed regarding the July incident.
DOJ-OGR-00000623.jpg
This letter, dated August 10, 2019, is a formal notification from the Warden's Office at the Metropolitan Correctional Center to Chief Judge Colleen McMahon and Judge Richard M. Berman. It reports the death of inmate Jeffrey Epstein, who was found unresponsive in his cell that morning from an apparent suicide and later pronounced dead at a local hospital. The letter states that investigations by the FBI and the Department of Justice Office of the Inspector General are underway.
DOJ-OGR-00022140.jpg
A formal letter filed on July 29, 2021, to Judge Analisa Torres regarding the case United States v. Tova Noel et al. (related to the guards on duty during Jeffrey Epstein's suicide). Assistant U.S. Attorney Jessica Lonergan informs the court she is leaving the U.S. Attorney's Office for other employment and requests to be withdrawn as counsel of record.
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-00025265.jpg
In a letter dated August 12, 2019, Lamine N'Diaye, the Warden of the Metropolitan Correctional Center (MCC) in New York, responds to an inquiry from District Judge Richard M. Berman. The Warden confirms that the ongoing FBI and OIG investigations into an August 10, 2019 incident involving inmate Jeffrey Epstein will also encompass a prior incident from July 23, 2019. Due to the active investigations, the Warden states he is unable to release any information regarding the previously completed internal inquiry into the July incident.
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