Legal correspondence from attorney Bennet J. Moskowitz to Judge Lorna G. Schofield requesting an extension for the defendants (Indyke and Kahn, executors of the Epstein Estate) to respond to a motion by Jane Doe 1000. The judge endorsed the letter on December 5, 2019, granting an adjournment of the deadline to January 16, 2020.
This document is a Waiver of the Service of Summons filed on November 27, 2019, in the Southern District of New York for Case 1:19-cv-10577-LGS (Jane Doe 1000 v. Darren K. Indyke et al). Attorney Bennet Moskowitz of Troutman Sanders LLP signs on behalf of defendants Darren K. Indyke and Richard D. Kahn (executors of the Epstein estate), acknowledging receipt of the complaint and agreeing to waive formal service. The waiver is addressed to plaintiff's attorney David Boies.
This document is a civil summons issued by the United States District Court for the Southern District of New York on November 18, 2019. The plaintiff, Jane Doe 1000, is suing Darren K. Indyke and Richard D. Kahn in their capacities as executors of the Estate of Jeffrey Edward Epstein. The defendants are directed to respond to the complaint through their attorney, Bennet J. Moskowitz, or the plaintiff's attorney, Joshua Schiller.
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.
This document is a Joint Stipulation and Order filed in June 2020 in the Southern District of New York, staying the lawsuit brought by Teala Davies against the executors of Jeffrey Epstein's estate. The stay was requested to allow the plaintiff to participate in the Epstein Victims’ Compensation Program, a non-adversarial alternative to litigation for resolving sexual abuse claims. Judge Debra C. Freeman signed the order on June 22, 2020, and directed the parties to submit a status report by August 14, 2020.
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.
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.
A letter motion filed by attorney Bennet J. Moskowitz on behalf of the Co-Executors of Jeffrey Epstein's estate (Indyke and Kahn) requesting a 30-day extension on various court deadlines due to the pandemic. The request applies to cases involving plaintiffs Jane Doe 15, Mary Doe, and Teala Davies. The motion was endorsed and ordered by Magistrate Judge Debra Freeman on April 14, 2020.
A letter dated April 13, 2020, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Debra C. Freeman. The letter represents the Co-Executors of the Estate of Jeffrey E. Epstein (Indyke and Kahn) in lawsuits brought by Jane Doe 15, Mary Doe, and Teala Davies. It requests a 30-day extension for various discovery and filing deadlines due to the COVID-19 pandemic, noting that the Plaintiffs have consented to this request.
This document is a Stipulated Confidentiality Agreement and Protective Order filed in the Southern District of New York for the case of Teala Davies v. The Executors of the Estate of Jeffrey Epstein (Indyke and Kahn). Dated March 16, 2020, it establishes protocols for handling confidential discovery materials, including medical records and financial information, and sets procedures for inadvertent disclosures and sealing documents. It includes a Non-Disclosure Agreement form (Exhibit A) to be signed by third parties accessing confidential information.
Legal correspondence from Troutman Sanders LLP to Judge Debra C. Freeman dated February 26, 2020, regarding the case Teala Davies v. Indyke et al. The letter requests approval for a briefing schedule concerning a Motion to Dismiss filed by the Co-Executors of the Estate of Jeffrey E. Epstein. It references prior settlement discussions held during a court conference on February 11, 2020.
A letter dated December 5, 2019, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Magistrate Judge Debra Freeman regarding the case Teala Davies v. Darren K. Indyke and Richard D. Kahn. Moskowitz requests an extension until January 20, 2020, for the defendants (Executors of Jeffrey Epstein's estate) to respond to the complaint. It also notes a scheduled Rule 26(f) conference for January 7, 2020.
This document is a 'Notice of Change of Address' filed on July 10, 2020, in the case of Juliette Bryant v. Darren K. Indyke and Richard D. Kahn (Case No. 1:19-cv-10479-ALC-DCF) in the Southern District of New York. Attorney Matthew J. Aaronson is notifying the court that his firm, formerly Troutman Sanders LLP, is now Troutman Pepper Hamilton Sanders LLP, though the physical address and contact numbers remain the same. He confirms he will continue as counsel of record.
This document is a 'Notice of Change of Address' filed in the US District Court for the Southern District of New York on July 10, 2020, for Case No. 1:19-cv-10479-ALC-DCF (Juliette Bryant v. Darren K. 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 contact information remains the same.
A Notice of Change of Address filed on July 9, 2020, in the Southern District of New York case Juliette Bryant v. Darren K. Indyke and Richard D. Kahn (Case No. 19-CV-10479). Attorney Bennet J. Moskowitz notifies the court that his 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. Moskowitz confirms he will continue as counsel of record on the case.
This document is a joint stipulation filed on June 12, 2020, in the Southern District of New York, staying the lawsuit brought by Juliette Bryant against the Estate of Jeffrey Epstein for 60 days. The stay is requested to allow Bryant to participate in the Epstein Victims’ Compensation Program, a non-adversarial alternative for resolving sexual abuse claims. Attorneys Sigrid McCawley (for Plaintiff) and Bennet J. Moskowitz (for Defendants) signed the agreement.
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-10479). Attorney Charles L. Glover of Troutman Sanders LLP formally notifies the court that he is appearing 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 lawsuit brought by plaintiff Juliette Bryant.
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 for Case No. 1:19-CV-10479. Attorney Matthew J. Aaronson of Troutman Sanders LLP formally enters his appearance as counsel for defendants Darren K. Indyke and Richard D. Kahn in their capacities as executors of the Estate of Jeffrey Edward Epstein in the lawsuit brought by plaintiff Juliette Bryant.
Legal correspondence dated May 8, 2020, from Matthew J. Aaronson (Troutman Sanders LLP) to Judge Debra C. Freeman. The letter represents the Co-Executors of the Jeffrey Epstein Estate (Indyke and Kahn) and objects to the Plaintiffs' request for a pre-motion conference regarding discovery disputes. The defense argues the request is premature as the parties were still in the 'meet-and-confer' process, and requests either a denial of the conference or permission to respond by May 13, 2020.
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.
This document is a civil summons filed on November 14, 2019, in the Southern District of New York for Case 1:19-cv-10479. Plaintiff Juliette Bryant is suing Darren K. Indyke and Richard D. Kahn in their capacities as executors of the Estate of Jeffrey Edward Epstein. The defendants are instructed to respond within 21 days to plaintiff's attorney Joshua Schiller.
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).
This document is a discovery production letter from the DOJ to Ghislaine Maxwell's defense team, dated August 5, 2021. It lists materials being turned over, including files recovered from discs seized at Jeffrey Epstein's New York residence, images from his electronic devices, Missouri records, a JPMorgan Chase return, and a 1995 Oxford letter. The letter also clarifies confidentiality designations under the Protective Order.
A UBS 'Letter of Authorization for Duplicate Recipient of Tax Records' signed by Ghislaine Maxwell on February 12, 2016. The document authorizes UBS to send copies of tax forms for account Y123692 to Alan Blecher at 685 Third Avenue, New York. Blecher's email address is associated with the accounting firm Marks Paneth.
A discovery production letter dated October 19, 2020, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. The letter outlines a production of evidence including FBI Florida and NY documents, Palm Beach Police Department (PBPD) materials, aerial video, and 3-D blueprints, spanning Bates numbers SDNY_GM_00328070 through SDNY_GM_00356148. The letter designates specific items as 'Confidential' or 'Highly Confidential' under a Protective Order.
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