This document is a civil summons filed on March 17, 2020, in the Southern District of New York (Case 1:20-cv-02365). Plaintiff Jane Doe is suing Darren K. Indyke and Richard D. Kahn in their capacities as executors of the Estate of Jeffrey E. Epstein. The summons is specifically addressed to Richard D. Kahn.
This document is a civil summons filed on March 17, 2020, in the Southern District of New York. It notifies Darren K. Indyke and Richard D. Kahn, as executors of Jeffrey Epstein's estate, that they are being sued by a plaintiff identified as Jane Doe. The document instructs the defendants to respond to the complaint within 21 days to the plaintiff's attorney, Daniel J. Kaiser.
A court filing from the Southern District of New York dated November 2, 2020, stipulating the dismissal of a case brought by 'Anastasia Doe' against the Estate of Jeffrey Epstein. The dismissal is with prejudice and results from the plaintiff resolving her claims through the Epstein Victims' Compensation Program. The document is signed by attorneys Bradley J. Edwards (Plaintiff) and Bennet J. Moskowitz (Defendants).
This document is a Notice of Change of Address filed on July 8, 2020, in the United States District Court for the Southern District of New York, for Case No. 19-CV-11869-MKV-DCF (Anastasia Doe v. Indyke & Kahn). Attorney Charles L. Glover notifies the court that his firm, formerly Troutman Sanders LLP, is now named Troutman Pepper Hamilton Sanders LLP, though the physical address in New York remains the same. Glover confirms he remains counsel of record for the case.
This document is a letter motion dated January 7, 2020, from attorney Bennet J. Moskowitz (Troutman Sanders LLP) to Judge Alison J. Nathan. It requests approval for an agreement where the Co-Executors of Jeffrey Epstein's estate (Indyke and Kahn) accept service of a complaint by Anastasia Doe and receive an extension until February 17, 2020, to respond. The document includes a handwritten 'SO ORDERED' endorsement by Judge Nathan dated January 8, 2020.
Legal correspondence dated January 7, 2020, from attorney Bennet J. Moskowitz to Judge Alison J. Nathan. The letter requests court approval for an agreement wherein the executors of Jeffrey Epstein's estate accept service of a complaint by 'Anastasia Doe' and receive an extension until February 17, 2020, to respond.
A status report filed on August 14, 2020, by attorney Bennet J. Moskowitz representing the Estate of Jeffrey Epstein and associated corporate entities. The document informs Judge Debra C. Freeman that Plaintiff Jane Doe 17 submitted a claim to the Epstein Victims' Compensation Program on July 11, 2020. The parties request that the current lawsuit remain stayed pending the resolution of the compensation claim.
A Notice of Change of Address filed on July 9, 2020, in the Southern District of New York case Jane Doe 17 v. Darren K. Indyke and Richard D. Kahn. Attorney Bennet J. Moskowitz notifies the court that his firm, Troutman Sanders LLP, has changed its name to Troutman Pepper Hamilton Sanders LLP, though the physical address and contact numbers remain the same.
A letter motion filed on March 6, 2020, by Andrew S. Buzin of Buzin Law P.C. requesting permission to withdraw as local counsel for plaintiff Jane Doe 17 in her case against Indyke and Kahn (executors of the Epstein estate). The client requested the discharge, and she remains represented by attorneys from Weisman, Brodie, Starr & Margolies, P.A. and Alan Goldfarb, P.A. The letter notes that the case is currently stayed pending the plaintiff's potential participation in the Epstein Victims' Compensation Program.
A letter motion dated December 19, 2019, from attorney Bennet J. Moskowitz representing the Estate of Jeffrey Epstein and associated corporate entities, requesting a brief extension to respond to the complaint in Jane Doe 17 v. Indyke et al. The letter lists numerous corporate defendants linked to Epstein, including Nine East 71st Street Corp and Financial Trust Company. Judge Paul A. Engelmayer granted the request on the same day and noted that future requests should be directed to Judge Freeman.
This document is a Rule 7.1 Statement filed on December 19, 2019, in the case of Jane Doe 17 v. The Estate of Jeffrey Epstein and various associated corporate entities. The filing, submitted by attorney Bennet J. Moskowitz of Troutman Sanders LLP, certifies that none of the defendant corporations have parent corporations or are owned 10% or more by publicly held corporations. It lists numerous entities associated with Epstein, including Nine East 71st Street Corporation, Financial Trust Company, and various LLCs.
This document is a Joint Stipulation filed on December 12, 2019, in the case of Jane Doe 17 v. The Estate of Jeffrey Epstein. The parties agree to an order protecting the Plaintiff's anonymity, outlining strict protocols for disclosing her identity only to necessary defense counsel and staff, requiring Non-Disclosure Agreements for any other necessary disclosures. It includes the text of the proposed order and a template NDA.
A letter from defense attorney Bennet J. Moskowitz to Judge Paul A. Engelmayer in the case of Jane Doe 17 v. Estate of Jeffrey Epstein. The defense requests the court vacate a recent order granting the plaintiff anonymity, not to oppose the anonymity itself, but to ensure they have the opportunity to respond regarding the specific terms of that anonymity to protect their defense rights, citing a previous deadline of December 21, 2019.
A Notice of Appearance filed on November 7, 2019, in the Southern District of New York for Case No. 1:19-cv-09610-PAE (Jane Doe 17 v. Estate of Jeffrey Epstein et al.). Attorney Bennet J. Moskowitz of Troutman Sanders LLP formally enters the case to represent the defendants, specifically the estate executors Darren K. Indyke and Richard D. Kahn, as well as numerous corporate entities associated with Epstein (e.g., Nine East 71st Street Corp, Financial Trust Company, JEGE Inc.).
A legal filing from Troutman Sanders LLP on behalf of the Estate of Jeffrey Epstein and associated corporate entities in the case Jane Doe 17 v. Indyke et al. The letter informs Judge Engelmayer of an agreement between parties regarding the acceptance of service and an extension of time until December 21, 2019, for the defendants to respond to the complaint. The judge granted and signed the order on November 5, 2019.
This document is an unopposed motion filed on October 24, 2019, in the Southern District of New York by attorney Andrew S. Buzin. The motion seeks the admission of Florida attorney Laura J. Starr *pro hac vice* to represent the Plaintiff, Jane Doe 17, in her lawsuit against the Estate of Jeffrey Epstein and associated entities. The filing includes Starr's declaration, a certificate of good standing from the Florida Supreme Court, and a proposed order. Defense counsel Bennet Moskowitz stated that the Defendants do not oppose the motion.
This document is a formal Summons in a Civil Action filed on October 22, 2019, in the Southern District of New York (Case 1:19-cv-09610). The plaintiff, identified as Jane Doe 17, is suing the Estate of Jeffrey E. Epstein (represented by Darren K. Indyke and Richard D. Kahn) and numerous associated corporate entities (Nine East 71st Street Corp, Laurel Inc, NES LLC, etc.). The summons instructs the defendants to respond within 21 days to avoid a default judgment and lists the plaintiff's legal representation.
This document is a Civil Cover Sheet (Form JS 44) filed on October 18, 2019, in the Southern District of New York for a lawsuit initiated by 'Jane Doe 17' against the Estate of Jeffrey Epstein and various associated corporate entities. The cause of action is listed as Battery under 18 U.S.C. sections 1591-1595 (statutes relating to sex trafficking and forced labor). The document identifies Darren K. Indyke and Richard D. Kahn as the personal representatives of the estate and lists several shell companies (like JEGE, Inc. and NES, LLC) as defendants whose addresses were unknown at the time of filing.
A Notice of Change of Address filed on July 10, 2020, in the Southern District of New York case Jane Doe 1000 v. Indyke et al. Attorney Matthew J. Aaronson notifies the court that his firm, Troutman Sanders LLP, is now named Troutman Pepper Hamilton Sanders LLP, though the address remains 875 Third Avenue, New York.
This document is a 'Notice of Change of Address' filed on July 10, 2020, in the case of Jane Doe 1000 v. Indyke et al. Attorney Valerie Sirota notifies the court that her firm name has changed from Troutman Sanders LLP to Troutman Pepper Hamilton Sanders LLP, though her physical address in New York remains the same. She confirms she will continue to serve as counsel of record in the case.
Legal correspondence from Troutman Sanders LLP to Judge Freeman regarding the case of Jane Doe 1000 v. The Estate of Jeffrey Epstein. The defense argues against the Plaintiff's request for a 21-year discovery period, stating the alleged abuse occurred only between 1999 and 2002, and asserts that they are already processing a database of over 730,000 documents. The document mentions that flight logs will be produced if the complaint alleges the Plaintiff traveled on Epstein's plane, but does not contain the logs themselves.
This document is 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 formally notifies the court that she is representing defendants Darren K. Indyke and Richard D. Kahn in their capacities as executors of the Estate of Jeffrey Epstein against plaintiff Jane Doe 1000.
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-10577-LJL-DCF). Attorney Charles L. Glover of Troutman Sanders LLP formally enters his appearance as counsel representing defendants Darren K. Indyke and Richard D. Kahn in their capacities as executors of the Estate of Jeffrey Epstein.
This document is a letter from attorney Bennet Moskowitz to Judge Lewis J. Liman dated February 14, 2020, in the case of Jane Doe 1000 v. the Estate of Jeffrey Epstein. The letter requests approval for a briefing schedule regarding an anticipated motion to dismiss, with deadlines set for February, March, and April 2020. The document was endorsed and ordered by Judge Liman on February 18, 2020.
A letter from attorney Bennet J. Moskowitz to Judge Lorna G. Schofield dated January 2, 2020, regarding the case of Jane Doe 1000 v. the Estate of Jeffrey Epstein. The letter requests the referral of the case to Magistrate Judge Debra C. Freeman for general pretrial proceedings, noting that the plaintiff consents and that similar cases (specifically citing Teresa Helm and Juliette Bryant) have already been referred to her.
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