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009.pdf
A Waiver of the Service of Summons filed in the US District Court for the Southern District of New York on November 27, 2019, in the case of Teresa Helm v. Darren K. Indyke et al. Attorney Bennet Moskowitz of Troutman Sanders LLP signed the waiver on November 25, 2019, on behalf of defendants Darren K. Indyke and Richard D. Kahn, acknowledging receipt of the complaint from plaintiff's attorney David Boies.
004.pdf
This document is a civil summons issued on November 13, 2019, by the United States District Court for the Southern District of New York in the case of Teresa Helm v. Darren K. Indyke and Richard D. Kahn (Executors of the Estate of Jeffrey Epstein). The summons notifies the defendants that a lawsuit has been filed against them and instructs them to respond within 21 days. The second page contains a blank Proof of Service form.
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.
032.pdf
A legal stipulation filed on April 1, 2021, in the Southern District of New York, dismissing Maria Farmer's lawsuit against the executors of Jeffrey Epstein's estate (Indyke and Kahn). The dismissal is with prejudice and results from Farmer accepting an offer of compensation from the Epstein Victims’ Compensation Program.
030.pdf
A 'Notice of Change of Address' filed on July 9, 2020, in the Southern District of New York case Maria Farmer v. Darren K. Indyke and Richard D. Kahn. Attorney Bennet J. Moskowitz notifies the court that his law firm, formerly Troutman Sanders LLP, is now Troutman Pepper Hamilton Sanders LLP, though the address remains the same at 875 Third Avenue, New York, NY.
028.pdf
A legal stipulation filed on April 9, 2020, in the Southern District of New York, wherein Plaintiff Maria Farmer and the Executors of Jeffrey Epstein's estate (Indyke and Kahn) agreed to stay the lawsuit. The stay was requested to allow Farmer to participate in the 'Epstein Victims’ Compensation Program,' a non-adversarial alternative for resolving sexual abuse claims against the estate.
026.pdf
This document is the formal Answer and Affirmative Defenses filed by the Co-Executors of the Jeffrey Epstein Estate (Darren K. Indyke and Richard D. Kahn) in response to a civil complaint by Annie Farmer. The executors generally deny knowledge of the specific allegations of abuse but admit to certain procedural facts, such as Epstein's arrest date (July 6, 2019), death date (August 10, 2019), and property ownership in NY, NM, USVI, FL, and France. They assert ten affirmative defenses, including failure to state a claim, contributory negligence, assumption of risk, and statute of limitations arguments challenging the New York Child Victims' Act.
008.pdf
This document is a Waiver of the Service of Summons filed on November 27, 2019, in the case of Maria Farmer v. Darren K. Indyke et al (Case No. 1:19-cv-10474-NRB) in the Southern District of New York. Attorney Bennet Moskowitz of Troutman Sanders LLP signed the waiver on November 25, 2019, on behalf of defendants Darren K. Indyke and Richard D. Kahn, agreeing to waive formal service and respond to the complaint within 60 days. The waiver is addressed to plaintiff's attorney David Boies.
003.pdf
This document is a Summons in a Civil Action filed on November 12, 2019, in the Southern District of New York (Case 1:19-cv-10474-NRB). Plaintiff Maria Farmer is suing Darren K. Indyke and Richard D. Kahn in their capacities as executors of the Estate of Jeffrey Edward Epstein. The summons directs the defendants to respond to the complaint within 21 days of service, with Joshua Schiller of Boies Schiller Flexner LLP listed as the plaintiff's attorney.
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.
052.pdf
This document is a legal stipulation filed on November 5, 2021, in the Southern District of New York, regarding case 1:20-cv-02365-LJL-DCF. The plaintiff, 'Jane Doe,' voluntarily dismisses her claims with prejudice against the executors of Jeffrey Epstein's estate, Darren K. Indyke and Richard D. Kahn. The dismissal is agreed upon by counsel for both parties without costs to either side.
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.
045.pdf
This document is a transcript of a telephone conference held on August 26, 2021, before Magistrate Judge Debra C. Freeman in the case of Jane Doe v. Darren K. Indyke et al. The proceedings cover case management matters, including setting a scheduling order for discovery, discussing a forthcoming motion to dismiss, and granting the plaintiff's motion to proceed anonymously. The court also encourages the parties to engage in settlement discussions and outlines procedures for status reports.
044.pdf
A letter from attorney Bennet J. Moskowitz to Judge Debra C. Freeman dated August 26, 2021, regarding the case Jane Doe v. Darren K. Indyke and Richard D. Kahn. The letter requests the withdrawal of a previously filed Joint Proposed Discovery Schedule (ECF No. 40) because it contained incorrect signature and contact information for the Plaintiff's counsel.
033.pdf
Legal correspondence dated August 13, 2021, from attorney Bennet J. Moskowitz to Judge Debra C. Freeman regarding the case of Jane Doe v. the Estate of Jeffrey Epstein. The letter requests permission to file a redacted statement concerning the Plaintiff's application to proceed anonymously. While the Co-Executors (Indyke and Kahn) do not oppose the anonymity, they wish to present specific material facts relevant to the application for the Court's consideration.
032.pdf
This document is a Notice of Appearance filed on August 13, 2021, in the US District Court for the Southern District of New York (Case 1:20-cv-02365). Attorney Bennet J. Moskowitz of Troutman Pepper Hamilton Sanders LLP enters his appearance as counsel for Defendants Darren K. Indyke and Richard D. Kahn, in their capacities as Co-Executors of the Estate of Jeffrey E. Epstein, in a lawsuit brought by a Jane Doe.
029.pdf
This document is a Notice of Motion filed on July 30, 2021, in the Southern District of New York (Case 1:20-cv-02365). Plaintiff Jane Doe is notifying the defendants (Executors of the Epstein Estate and various associated corporate entities) that she is moving the court for an order allowing her to proceed anonymously in the lawsuit.
028.pdf
This document is a legal letter dated June 30, 2021, from attorney Bennet J. Moskowitz to Judge Debra C. Freeman regarding the case Jane Doe v. Executors of the Estate of Jeffrey E. Epstein. The letter requests the lifting of a stay on the proceedings. A court order is superimposed on the document, dated July 22, 2021, which grants the request, lifts the stay, sets deadlines for filings, and schedules a telephonic pretrial conference for August 26, 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.
025.pdf
A status report filed on June 1, 2021, by attorney Bennet J. Moskowitz on behalf of the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in the case brought by Jane Doe. The letter informs Judge Freeman that the Plaintiff has submitted a claim to the Epstein Victims' Compensation Program. The parties jointly request that the civil case remain stayed while the compensation claim is considered, noting that a resolution via the Program would lead to the discontinuation of the lawsuit.
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.
019.pdf
A status report filed on January 4, 2021, by attorney Bennet J. Moskowitz on behalf of the Estate of Jeffrey Epstein executors (Indyke and Kahn) in the case of Jane Doe v. Indyke et al. The letter informs Judge Freeman that the Plaintiff intends to participate in the Epstein Victims’ Compensation Program and requests that the current litigation remain stayed pending the outcome of that claims process.
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.
005.pdf
This document is a Summons in a Civil Action issued by the United States District Court for the Southern District of New York on March 18, 2020. It notifies Darren K. Indyke, as an executor of the Estate of Jeffrey E. Epstein, that a lawsuit has been filed against him and co-executor Richard D. Kahn by a plaintiff identified as Jane Doe. The document instructs Indyke to respond to the complaint within 21 days or face a default judgment.
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