| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
Darren K. Indyke
|
Legal representative |
47
Very Strong
|
47 | |
|
person
Darren K. Indyke
|
Client |
26
Very Strong
|
26 | |
|
person
RICHARD D. KAHN
|
Client |
19
Very Strong
|
19 | |
|
person
RICHARD D. KAHN
|
Legal representative |
13
Very Strong
|
13 | |
|
organization
Estate of Jeffrey E. Epstein
|
Legal representative |
2
|
2 | |
|
organization
AMI
|
Employment |
2
|
2 | |
|
person
Indyke
|
Client |
2
|
2 | |
|
person
defendants
|
Legal representative |
2
|
2 | |
|
person
Darren K. Indyke
|
Counsel |
1
|
1 | |
|
person
Roberta Kaplan
|
Legal representative |
1
|
1 | |
|
organization
EST
|
Legal representative |
1
|
1 | |
|
organization
AMI
|
Business associate |
1
|
1 | |
|
person
Nine East 71st Street Corporation
|
Legal representative |
1
|
1 | |
|
person
Mariann Meier Wang
|
Opposing counsel |
1
|
1 | |
|
person
Indyke (Defendants)
|
Client |
1
|
1 | |
|
person
Andrew Villacastin
|
Legal representative |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2021-09-06 | N/A | Filing of Notice of Co-Executors' Motion to Dismiss Plaintiff's Complaint | New York, New York | View |
| 2021-08-26 | N/A | Request to withdraw document ECF No. 40 | Court Docket (ECF) | View |
| 2021-08-13 | N/A | Filing of Declaration of Bennet J. Moskowitz in support of Co-Executors' Statement | New York, New York | View |
| 2021-08-13 | N/A | Filing of Notice of Appearance by Bennet J. Moskowitz | New York, New York | View |
| 2021-06-30 | N/A | Filing of letter informing Court of desire to lift stay | New York, NY | View |
| 2020-12-01 | N/A | Joint Status Report submitted to the Court. | New York | View |
| 2020-12-01 | N/A | Filing of Joint Status Report | New York, NY | View |
| 2020-11-02 | N/A | Submission of Status Report | New York | View |
| 2020-11-02 | N/A | Submission of Joint Status Report via ECF | New York, NY | View |
| 2020-10-07 | N/A | Stipulation of Dismissal with Prejudice signed by parties. | New York, New York | View |
| 2020-10-01 | N/A | Submission of Joint Status Report requesting a stay of the case. | New York, NY | View |
| 2020-08-14 | N/A | Filing of joint status report requesting stay of discovery. | New York | View |
| 2020-08-14 | N/A | Filing of Status Report requesting continuation of stay | New York, NY | View |
| 2020-08-14 | N/A | Joint submission of status report and request for extension. | New York, NY | View |
| 2020-08-14 | N/A | Joint submission of status report requesting extension | New York, NY | View |
| 2020-07-09 | N/A | Filing of Notice of Change of Address by Bennet J. Moskowitz | Southern District of New York | View |
| 2020-06-19 | N/A | Joint Stipulation submitted by parties | New York, New York | View |
| 2020-06-12 | N/A | Filing of Joint Stipulation and Proposed Order Staying Action | New York, New York | View |
| 2020-06-12 | N/A | Joint Stipulation and Proposed Order Staying Action filed | Southern District of New York | View |
| 2020-05-21 | N/A | Filing of Stipulated Confidentiality Agreement and Protective Order | New York, New York | View |
| 2020-05-21 | N/A | Stipulated Confidentiality Agreement and Protective Order filed and signed by counsel for both pa... | New York, New York | View |
| 2020-04-30 | N/A | Filing of Document 40 in Case 1:19-cv-10788-GHW-DCF. | New York, NY | View |
| 2020-04-28 | N/A | Filing of Document 60 in Case 1:19-cv-07625-AJN-DCF | New York, NY | View |
| 2020-04-28 | N/A | Filing of letter to Judge Freeman regarding supplemental authority. | New York, NY | View |
| 2020-04-27 | N/A | Meet and confer telephone call regarding discovery deficiencies | Telephone | View |
This document is a Stipulation of Dismissal with Prejudice for Case No. 1:19-cv-09610-PAE-DCF in the Southern District of New York, filed on October 8, 2020. Plaintiff Jane Doe 17 voluntarily dismisses her action against the Estate of Jeffrey Epstein and various associated corporate entities without costs. The document is signed by attorneys David H. Brodie (for the Plaintiff) and Bennet J. Moskowitz (for the Defendants).
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.
This document is a legal declaration filed on December 23, 2019, by Bennet J. Moskowitz, an attorney for the Estate of Jeffrey Epstein and associated entities. The declaration serves to submit a copy of the Plaintiff's (Jane Doe 17) original complaint as an exhibit in support of the Defendants' Motion to Dismiss the case in the Southern District of New York.
This document is a Notice of Motion filed on December 23, 2019, in the Southern District of New York. The defendants, representing the Estate of Jeffrey Epstein and various associated corporations, are moving to dismiss the complaint of Plaintiff Jane Doe 17 with prejudice for failure to state a claim. The hearing is scheduled before Judge Paul E. Engelmayer.
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 a joint status report filed on August 14, 2020, by attorneys for both the Plaintiff (Jane Doe 1000) and the Defendants (Executors of the Epstein Estate). They requested a 45-day extension to the stay of discovery because the Plaintiff had submitted a claim to the Epstein Victims' Compensation Program and was awaiting a determination. The document includes a handwritten order by Magistrate Judge Debra Freeman dated September 11, 2020, granting the requested extension.
A joint status report filed on August 14, 2020, in the case of Jane Doe 1000 v. the Estate of Jeffrey Epstein. The attorneys for both parties inform Judge Freeman that the Plaintiff has submitted a claim to the Epstein Victims’ Compensation Program and request a 45-day extension to the stay of discovery to allow time for an eligibility determination.
This is a Joint Stipulation and Proposed Order filed in the US District Court (SDNY) on June 12, 2020, in the case of Jane Doe 1000 v. The Estate of Jeffrey Epstein. The parties agreed to stay (pause) the lawsuit for 60 days to allow the Plaintiff to participate in the Epstein Victims' Compensation Program, a non-adversarial alternative for resolving sexual abuse claims. If the claim is resolved through the program, the Plaintiff agrees to discontinue the legal action with prejudice.
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 Stipulated Confidentiality Agreement and Protective Order filed on May 21, 2020, in the case of Jane Doe 1000 v. The Estate of Jeffrey Epstein. It establishes strict protocols for handling confidential discovery materials, including medical records, financial data, and the identities of minor victims, to protect privacy during litigation. The order outlines procedures for designating information as confidential, limits who may view such materials, and provides a Non-Disclosure Agreement form (Exhibit A) for third parties.
This document is a legal filing from Plaintiff Jane Doe 1000's counsel requesting a pre-motion conference to compel Defendants (Epstein's executors Indyke and Kahn) to produce discovery documents and answer interrogatories. The filing includes exhibits of the discovery requests, which seek detailed information on Epstein's flight logs, financial transactions, communications with high-profile individuals (Prince Andrew, Bill Clinton, Alan Dershowitz), and the structure of his alleged sex-trafficking operation. The Defendants have objected to almost all requests, claiming they are overbroad or that they lack knowledge because Epstein is deceased, prompting the Plaintiff to seek court intervention. Note: While flight logs are requested, no actual flight data is contained in this document.
Defense counsel Bennet Moskowitz submits a letter to the Court in the 'Jane Doe 1000' case, attaching a recent Order from Judge Paul Engelmayer in the 'Jane Doe 15' case. The attached Order dismisses Jane Doe 15's claim for punitive damages against the Epstein Estate, ruling that under both New York and New Mexico law, punitive damages cannot be recovered from a deceased tortfeasor's estate. The Order details allegations that Jane Doe 15 was groomed by Epstein's secretary in New York and subsequently abused by Epstein at his New Mexico ranch in 2004.
A letter filed on April 15, 2020, by attorney Bennet J. Moskowitz of Troutman Sanders LLP to Magistrate Judge Debra C. Freeman. The letter requests a 30-day extension on various discovery and filing deadlines in three cases involving the Estate of Jeffrey Epstein (Plaintiffs Jane Doe 1000, Teresa Helm, and Juliette Bryant) due to the COVID-19 pandemic. The Judge signed and ordered the request on the same day.
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.
This document is a Notice of Motion to Dismiss filed on February 28, 2020, in the Southern District of New York (Case 1:19-cv-10577). The defendants, Darren K. Indyke and Richard D. Kahn (Executors of the Estate of Jeffrey Epstein), represented by Troutman Sanders LLP, are moving to dismiss the complaint of Plaintiff Jane Doe 1000 with prejudice pursuant to Rule 12(b)(6).
This document is a Discovery Plan and Proposed Scheduling Order filed on February 6, 2020, in the case of Jane Doe 1000 v. The Estate of Jeffrey Epstein. The Plaintiff requests broad discovery including flight logs, financial records, Amazon history, and communications with government officials and co-conspirators, while the Co-Executors attempt to limit the scope strictly to the Plaintiff's alleged abuse. The document outlines proposed deadlines for document requests, HIPAA releases, and expert discovery, noting significant disagreements between the parties on the timing of these phases.
This document is a letter from Bennet J. Moskowitz, attorney for the Co-Executors of Jeffrey Epstein's Estate, to Judge Lorna G. Schofield, dated January 24, 2020. The letter requests a pre-motion conference to move for the dismissal of a lawsuit filed by Jane Doe 1000. The defense argues that the plaintiff's claims regarding alleged abuse in 1999 are time-barred by the statutes of limitations in New York and Florida, do not qualify for tolling under the Child Victims Act or criminal proceeding statutes, and that punitive damages cannot be legally awarded against a decedent's estate.
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.
Request for a sixty-day stay of the action to attempt extrajudicial resolution (settlement).
Request to withdraw the Parties' Joint Proposed Discovery Schedule (ECF No. 40) due to incorrect signature and contact information.
Request to file Statement with redactions regarding Plaintiff's application to proceed anonymously.
Notification to the court that the Plaintiff desires to lift the stay of action; agreement on response deadlines; deadline for anonymous filing.
Request to lift stay of action and set deadlines for response and anonymity motion.
Status report informing the court that the Plaintiff has submitted a claim to the Epstein Victims' Compensation Program and requesting the case remain stayed.
Status report informing the judge that the Plaintiff has submitted a claim to the Epstein Victims' Compensation Program and requesting the case remain stayed.
Status report requesting the case remain stayed as the Plaintiff seeks to participate in the Epstein Victims’ Compensation Program.
Status report informing the court that the Plaintiff has received an award offer from the Compensation Program and the parties request the case remain stayed.
Joint status report requesting the case remain stayed while Plaintiff pursues a claim through the Epstein Victims' Compensation Program.
Status report requesting the case remain stayed as Plaintiff intends to submit a claim to the Epstein Victims' Compensation Program.
Joint status report requesting the case remain stayed as the Plaintiff has submitted a claim to the Epstein Victims' Compensation Program.
Status report informing the court that the Plaintiff intends to participate in the Epstein Victims’ Compensation Program and requesting the case remain stayed.
Joint status report informing the court that the Plaintiff has submitted a claim to the compensation program and requesting the case remain stayed.
Informing the court that Jane Doe 17 submitted a claim to the Victims' Compensation Program on July 11, 2020, and requesting the stay of the lawsuit continue.
Request to continue stay of action as Plaintiff submits claims to Epstein Victims' Compensation Program
Informing the NY Court that the USVI Superior Court entered an order establishing the Epstein Victims' Compensation Program.
Informing the court that the USVI Superior Court has granted the motion to establish the Epstein Victims' Compensation Program.
Informing the NY Court that the USVI Superior Court granted the motion to establish the Compensation Program.
Request for court approval of an agreement regarding service of complaint and extension of time to respond.
Submission of supplemental authority (Judge Engelmayer's Order in Jane Doe 15 case) regarding motion to dismiss punitive damages.
Letter supplementing a pending motion to dismiss with a recent Opinion & Order from Judge Engelmayer regarding punitive damages.
Supplementing a pending motion to dismiss with a recent Opinion & Order from Judge Engelmayer regarding punitive damages.
Complaint regarding Defendants' failure to respond to interrogatories and document requests.
Request to extend various discovery and filing deadlines by 30 days due to the pandemic.
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