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Legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party witness Jean Luc Bruhnel (spelled Bruhnel in document). The filing opposes Plaintiff Jane Doe's motion to compel Bruhnel to appear for a deposition, arguing that Bruhnel is a French citizen who has left the US with no plans to return and cannot be compelled by the Court to return. The document asserts that the Plaintiff should use the Hague Convention or other international mechanisms to secure testimony abroad and accuses Plaintiff's counsel of misrepresentation and failure to follow proper procedure.
This document is a Notice of Taking Videotaped Deposition and an associated Subpoena filed in the US District Court for the Southern District of Florida (Case No. 08-CIV-MARRA/JOHNSON). Plaintiff Jane Doe, represented by attorney Brad Edwards of Rothstein Rosenfeldt Adler, commanded Jean Luc Bruhel to appear for a deposition on September 22, 2009, in New York City. The document contains the legal notice, the subpoena addressed to Bruhel at a New York address, and standard Federal Rules of Civil Procedure regarding subpoenas.
This document is an Order of Reference to a Magistrate Judge filed on November 14, 2019, in the case of Jane Doe 17 v. Darren K. Indyke, et al. (Case 1:19-cv-09610). Judge Paul A. Engelmayer ordered the case to be referred for General Pretrial, which includes scheduling, discovery, non-dispositive pretrial motions, and settlement.
A proposed court order from November 2019 in the Southern District of New York regarding case 1:19-cv-09610-PAE. The document grants Plaintiff Jane Doe 17's motion to proceed anonymously in a lawsuit against the Estate of Jeffrey Epstein (represented by Indyke and Kahn) and numerous associated corporate entities.
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.
This document is a legal filing from June 3, 2020, submitted by Troutman Sanders LLP to the SDNY Court. It informs Judge Freeman that the Superior Court of the U.S. Virgin Islands has officially granted the motion to establish the 'Epstein Victims' Compensation Program.' The attached exhibit is the Order from the USVI court, signed by Magistrate Judge Carolyn P. Hermon-Percell, authorizing the Co-Executors (Indyke and Kahn) to commence the program on or about June 15, 2020, following an agreement with the USVI Attorney General to lift liens to fund the program.
This document is a legal filing in the civil case Jane Doe 1000 v. Indyke & Kahn. It includes a letter from Plaintiff's counsel arguing that the Epstein Estate executors are improperly limiting discovery to a 4-year period and refusing to produce documents regarding Epstein's broader sex-trafficking conspiracy. Attached as Exhibit A are the Defendants' supplemental responses to interrogatories, which list specific employees (including Ghislaine Maxwell, Sarah Kellen, and pilots like Larry Visoski), email accounts used by Epstein (specifically noting 'jeevacation@gmail.com' and 'jeeproject@yahoo.com'), and numerous phone numbers associated with his properties in New York, Palm Beach, New Mexico, and the Virgin Islands.
This document is a Memorandum of Law in Support of Defendants' Motion to Dismiss Plaintiff's Complaint, filed by the executors of the Estate of Jeffrey E. Epstein. The defendants argue that the plaintiff's claims for battery and intentional infliction of emotional distress, stemming from alleged sexual assaults in 1999, are time-barred by the applicable statutes of limitations in New York and Florida. They further argue that recent New York legislation extending the statute of limitations does not apply retroactively to already expired claims, and that the plaintiff cannot claim equitable tolling or estoppel. Additionally, the defendants assert that punitive damages cannot be recovered from a decedent's estate under New York or Florida law.
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.
A status update letter dated August 14, 2020, from attorney Mariann Meier Wang to Judge Debra Freeman regarding three civil cases against the Estate of Jeffrey Epstein (Indyke et al.). The letter informs the court that the plaintiffs are currently presenting their claims to the Epstein Victims Compensation Program and requests that the court cases remain stayed pending the outcome of this alternative dispute resolution process.
This document is a Sheriff's Certificate of Service filed with the Supreme Court of New York. It certifies that Deputy Sheriff Qin Zhang personally served Jeffrey Epstein with legal documents (Order to Show Cause & Verified Petition) on July 22, 2019, at 10:15 AM at 150 Park Row, Manhattan (the Metropolitan Correctional Center). The document includes a physical description of Epstein at the time of service: 66 years old, 5'10", 240 lbs, with white hair.
This document is a letter from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Gregory H. Woods, dated January 21, 2020. It outlines the grounds for an anticipated motion to dismiss claims brought by plaintiff Teala Davies against the Estate of Jeffrey Epstein. The defense argues that Davies' claims of sexual assault (alleged to have occurred between 2002 and 2004 in FL, NM, NY, USVI, and France) are time-barred by applicable statutes of limitations and that punitive damages cannot be recovered from a deceased tortfeasor's estate.
This document is a Summons in a Civil Action filed on November 22, 2019, in the Southern District of New York (Case No. 19 Civ. 10788). The plaintiff, Teala Davies, is suing Darren K. Indyke and Richard D. Kahn in their capacity as Executors of the Estate of Jeffrey E. Epstein. The summons directs Indyke to respond to the complaint within 21 days and lists his attorney as Bennet J. Moskowitz of Troutman Sanders LLP.
This document is a 'Summons in a Civil Action' filed on November 21, 2019, in the Southern District of New York (Case 1:19-cv-10788). The plaintiff, Teala Davies, is suing Darren K. Indyke and Richard D. Kahn in their capacities as Executors of the Estate of Jeffrey E. Epstein. The summons is addressed to Indyke via his attorney Bennet J. Moskowitz and requires a response within 21 days.
This is a Memorandum of Law filed by the defendants (Executors of the Estate of Jeffrey Epstein) in support of their motion to dismiss the plaintiff's complaint. The defendants argue that the plaintiff's claims of sexual assault and battery are time-barred by the applicable statutes of limitations in multiple jurisdictions (USVI, NY, NM, FL, France) and that exceptions like CPLR 215(8)(a) or equitable tolling do not apply. Additionally, the defendants argue that punitive damages are not recoverable against a deceased tortfeasor's estate under the laws of any relevant jurisdiction.
This document is a legal complaint filed by Juliette Bryant against the executors of Jeffrey Edward Epstein's estate. It details allegations of sexual abuse and trafficking by Epstein, beginning when Bryant was 20 years old, and describes Epstein's extensive sex trafficking network and his previous legal actions and statements regarding his conduct.
This document is an email thread between a Detective from the NYPD/FBI Child Exploitation Human Trafficking Task Force and a witness/victim. In the most recent email (March 2023), the witness apologizes for refusing to testify previously due to fear and asks if it is possible to visit Ghislaine Maxwell in prison to seek closure. The thread also contains older correspondence from March and April 2021 regarding the scheduling of interviews and the witness's hesitation to speak without lawyer consultation.
An email dated December 13, 2021, with the subject 'Witnesses'. The sender is a Special Agent from the FBI New York Field Office's Child Exploitation/Human Trafficking unit. The specific identities of the sender and recipients are redacted. The date coincides with the timeframe of the Ghislaine Maxwell trial.
This document is an email chain from June 2022 between an FBI Special Agent (Child Exploitation/Human Trafficking) and an Assistant U.S. Attorney for the SDNY. The AUSA is gathering personal information (DOB, SSN, GS scale) to nominate the 'Epstein / Maxwell case' team, including the FBI agent, for a DOJ Director's Award for Superior Performance, citing the agent's 'extensive efforts with victims.' The emails note that sentencing has been completed and the team is seeking 'closure' by submitting the award nomination.
An internal FBI email chain dated June 27, 2022, from a Victim Specialist in the New York field office. The subject is 'Maxwell,' and the content discusses logistics for 'tomorrow' involving getting someone on a list and helping them 'get in.' Given the date, this almost certainly refers to preparations for Ghislaine Maxwell's sentencing hearing on June 28, 2022.
This document is an email chain from October 2021 between FBI agents (Child Exploitation/Human Trafficking unit) and USANYS/SDNY personnel. The discussion concerns the urgent retrieval of 'hotline tracking spreadsheets' related to Ghislaine Maxwell and Jeffrey Epstein. The requestor specifically notes the need for these documents to satisfy '3500' obligations (referring to the Jencks Act discovery requirements) and sets up a secure USAfx folder to transfer the data.
This document is an internal FBI email dated October 9, 2021, transmitting records obtained from the Palm Beach Police Department (PBPD). The attachments refer to a 'Trash Pull' investigation, specifically referencing a file dated November 6, 2006 ('11.6.06'), which corresponds to the initial investigation into Jeffrey Epstein. The email notes that an individual named Paul received these records on the day of the email.
This document contains an email chain from December 29-30, 2021, among law enforcement officials (including NYPD's Vice Human Trafficking Unit) celebrating the guilty verdict of Ghislaine Maxwell. The correspondence highlights the collaboration between local and federal agencies and notes that the investigators received numerous congratulatory calls from the victims of Maxwell and Epstein. The officials express relief at the case's conclusion and hope for a significant sentence for Maxwell.
This document is an email chain from April 2022 between the US Attorney's Office (USANYS) and an FBI Special Agent in the Child Exploitation/Human Trafficking division. The US Attorney's office informs the agent that they are nominating her for a WIFLE (Women in Federal Law Enforcement) award specifically citing her 'outstanding work on Maxwell' (Ghislaine Maxwell) and other cases.
This document is an FBI Payment Request (FD-794) dated October 7, 2021, for Case Number 31E-NY-3027571, which is associated with Violent Crimes Against Children. The request seeks reimbursement for personal funds used by the case team to purchase meals for trial witnesses on June 23, 2021. The request originated from the New York Division, Unit C-20, and was digitally approved via Sentinel.
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