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074.pdf
A legal status report filed on December 1, 2020, by attorney Bennet J. Moskowitz regarding the case 'VE v. Darren Indyke and Richard D. Kahn'. The document informs Judge Debra C. Freeman that the plaintiff (VE) has submitted a claim to the Epstein Victims' Compensation Program and has received an award offer which she is considering. The parties request that the court case remain stayed while this settlement process concludes.
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.
072.pdf
A legal status report filed on October 1, 2020, by attorney Bennet J. Moskowitz on behalf of the Epstein Estate executors (Indyke and Kahn) and the Plaintiff 'VE'. The letter informs Judge Freeman that the Plaintiff has submitted a claim to the Epstein Victims’ Compensation Program which is under review, and consequently requests that the civil case remain stayed.
068.pdf
This is a Notice of Change of Address filed on July 8, 2020, in the Southern District of New York for case 1:19-cv-07625-AJN (VE v. Indyke et al.). Attorney Bennet J. Moskowitz notifies the court that his firm, Troutman Sanders LLP, has changed its name to Troutman Pepper Hamilton Sanders LLP. The physical address and contact numbers remain unchanged.
065.pdf
This document is a Joint Stipulation and Proposed Order filed on June 12, 2020, in the U.S. District Court for the Southern District of New York (Case No. 1:19-cv-07625). The plaintiff, identified as 'VE', and the defendants (Executors of the Epstein Estate and associated entities) agreed to stay the lawsuit to allow the plaintiff to participate in the 'Epstein Victims' Compensation Program', a non-adversarial alternative for resolving sexual abuse claims. The document is signed by attorneys Brad Edwards (for the plaintiff) and Bennet J. Moskowitz (for the defendants).
062.pdf
A Notice of Appearance filed on May 12, 2020, in the US District Court for the Southern District of New York. Attorney Charles L. Glover of Troutman Sanders LLP formally enters his appearance as counsel for the defendants, including the Estate of Jeffrey Epstein's executors (Indyke and Kahn) and associated corporate entities, in a case brought by plaintiff 'VE'.
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.
059.pdf
A legal letter from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Magistrate Judge Debra C. Freeman requesting a 30-day extension on various discovery and filing deadlines for multiple civil cases (including VE, Katlyn Doe, Priscilla Doe, etc.) due to the COVID-19 pandemic. The request was granted and 'So Ordered' by Judge Freeman on the same day, April 14, 2020.
054.pdf
This document is a Joint Proposed Discovery Schedule filed on February 6, 2020, in the case of VE v. Indyke et al. It outlines the agreed-upon timeline for the exchange of evidence, including initial disclosures, medical records, and expert reports. The filing identifies the key subjects of discovery as Epstein's alleged torts against the plaintiff, the liability of the corporate defendants, and the plaintiff's damages.
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.
047.pdf
This document is a letter dated December 26, 2019, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Alison J. Nathan. It requests a one-week extension (until January 2, 2020) for the defendants, including the Co-Executors of Jeffrey Epstein's estate (Indyke and Kahn) and related corporate entities, to file a reply supporting their Motion to Dismiss in the case VE v. Nine East 71st Street. The plaintiff consented to this extension request.
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.
030.pdf
This document is a Memorandum of Law filed on November 15, 2019, in the US District Court (SDNY) by the Co-Executors of Jeffrey Epstein's estate (Indyke and Kahn) and associated entities. The defendants state they do not object to the Plaintiff 'VE' proceeding anonymously but request the court enter a specific 'Proposed Order' to ensure they can adequately defend themselves and conduct discovery while maintaining her confidentiality from the general public. The filing argues that while anonymity is acceptable, it must not prejudice the defense's ability to investigate the allegations.
029.pdf
A letter from attorney Bennet J. Moskowitz to Judge Alison J. Nathan requesting a two-week extension for the Epstein Estate executors and associated entities to respond to a complaint in the case 'VE v. Nine East 71st Street'. The Judge granted the request on November 14, 2019, extending the deadline to November 29, 2019, but handwritten notes explicitly state 'No further extensions'.
027.pdf
A letter from attorney Bennet J. Moskowitz to Judge Alison J. Nathan dated November 12, 2019, requesting a two-week extension for the Defendants (Executors of Epstein's Estate and related entities) to respond to the Plaintiff's complaint in the case VE v. Nine East 71st Street, et al. The letter notes that Plaintiff's counsel refused to consent to the extension.
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.
023.pdf
This document is a civil summons filed on September 26, 2019, in the Southern District of New York for Case 1:19-cv-07625-AJN. The plaintiff, identified as 'VE', is suing several entities including Nine East 71st Street Corporation and Financial Trust Company, Inc., as well as Darren K. Indyke and Richard D. Kahn in their capacities as Co-Executors of the Estate of Jeffrey E. Epstein. The document requires the defendants to serve an answer to the complaint within 21 days to the plaintiff's attorney, J. Stanley Pottinger.
022.pdf
This document is a Summons in a Civil Action filed on September 25, 2019, in the Southern District of New York. The plaintiff, identified as 'VE', is suing several entities including Nine East 71st Street Corporation, Financial Trust Company, Inc., NES, LLC, and the executors of Jeffrey Epstein's estate (Darren K. Indyke and Richard D. Kahn). The summons instructs the defendants to respond to the complaint within 21 days.
021.pdf
This document is a legal letter dated September 18, 2019, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Alison J. Nathan. It concerns the case VE v. Nine East 71st Street, et al., representing the Estate of Jeffrey Epstein and associated entities. The letter confirms an agreement between the parties to accept service of the complaint and extends the defendants' deadline to respond until November 15, 2019; the request was 'So Ordered' by the judge on September 19, 2019.
056.pdf
This document is a 'Notice of Change of Address' filed on July 9, 2020, in the United States District Court for the Southern District of New York for the case Teresa Helm v. Darren K. Indyke and Richard D. Kahn (Case No. 19-CV-10476). Attorney Charles L. Glover notifies the court that his firm has changed names from Troutman Sanders LLP to Troutman Pepper Hamilton Sanders LLP, though the physical address at 875 Third Avenue, New York, remains the same. Glover confirms he will continue to serve as counsel of record on the case.
053.pdf
A Notice of Change of Address filed on July 9, 2020, in the case of Annie Farmer v. Darren K. Indyke and Richard D. Kahn (Case 19-CV-10475). Attorney Bennet J. Moskowitz notifies the court that his law firm's name has changed from Troutman Sanders LLP to Troutman Pepper Hamilton Sanders LLP, though the physical address and contact numbers remain the same.
041.pdf
A Notice of Appearance filed on May 8, 2020, in the US District Court for the Southern District of New York. Attorney Valerie Sirota of Troutman Sanders LLP enters her appearance as counsel for defendants Darren K. Indyke and Richard D. Kahn, the executors of the Estate of Jeffrey Epstein, in a lawsuit brought by plaintiff Teresa Helm.
040.pdf
A Notice of Appearance filed on May 8, 2020, in the US District Court for the Southern District of New York (Case No. 1:19-CV-10476-PGG-DCF). Attorney Charles L. Glover of Troutman Sanders LLP enters his appearance as counsel for defendants Darren K. Indyke and Richard D. Kahn in their capacities as executors of the Estate of Jeffrey Epstein in the lawsuit brought by Teresa Helm.
039.pdf
This document is a Notice of Appearance filed on May 8, 2020, in the United States District Court for the Southern District of New York (Case No. 1:19-CV-10476-PGG-DCF). Attorney Matthew J. Aaronson of Troutman Sanders LLP enters his appearance as counsel for defendants Darren K. Indyke and Richard D. Kahn, acting in their capacities as executors of the Estate of Jeffrey Edward Epstein, in the case brought by plaintiff Teresa Helm.
038.pdf
Legal correspondence from Troutman Sanders LLP to Judge Debra C. Freeman dated May 8, 2020. The letter requests the denial of Plaintiffs' (Jane Doe 1000, Teresa Helm, Juliette Bryant) request for a pre-motion conference regarding discovery disputes, characterizing the Plaintiffs' actions as premature and a violation of court rules regarding meet-and-confer obligations. The defense argues that good faith discussions were ongoing and accuses Plaintiffs of rushing to court to distract from their own refusal to produce medical records.
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