Indyke sued in capacity as executor of the estate of Jeffrey E. Epstein
Identified as Co-Executor of the Estate of Jeffrey E. Epstein
Joint Personal Representative of the Estate of Jeffrey E. Epstein
Listed as Co-Executor Of The Estate Of Jeffrey E. Epstein
Indyke listed as Joint Personal Representative of the Estate of Jeffrey E. Epstein.
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Co-Executors of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Co-Executors of the Estate of Jeffrey E. Epstein
Indyke listed as Executor of Estate
executors of THE ESTATE OF JEFFERY E. EPSTEIN
Described as 'Co-Executor of the Estate of Jeffrey E. Epstein'
Described as 'executor of the ESTATE OF JEFFREY E. EPSTEIN'
Co-Executor of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
Darren K. Indyke... as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN
Co-Executors of the Estate of Jeffrey E. Epstein
Identified as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Executor of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
Described as Co-Executor of the Estate of Jeffrey E. Epstein.
Indyke listed as Executor of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
Darren K. Indyke, in his capacity as Executor of the Estate of Jeffrey E. Epstein
Joint Personal Representatives of the Estate of Jeffrey E. Epstein
Co-Executor of the Estate of Jeffrey E. Epstein
Described as Co-Executor of the Estate of Jeffrey E. Epstein
Listed as 'EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN'
Listed as 'EXECUTOR of THE ESTATE OF JEFFREY E. EPSTEIN'
Caption lists Indyke as executor of the Estate of Jeffrey E. Epstein
Named as 'executors of the ESTATE OF JEFFREY E. EPSTEIN'
Indyke listed as Executor of Estate
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'.
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Described as 'executors of the ESTATE OF JEFFREY E. EPSTEIN'
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Indyke is listed as Co-Executor of the Estate of Jeffrey E. Epstein
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Co-Executor of the Estate of Jeffrey E. Epstein
Described as Co-Executors of the Estate of Jeffrey E. Epstein
Darren K. Indyke, in his capacity as the Executor for the Estate of Jeffrey E. Epstein
Listed as 'EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN'
Listed as Joint Personal Representative of the Estate of Jeffrey E. Epstein
Listed as Executor of the Estate of Jeffrey E. Epstein
Executor of the Estate of Jeffrey E. Epstein
DARREN K. INDYKE... in their capacities as the executors of the ESTATE OF JEFFREY E. EPSTEIN
Identified as Executor of the Estate of Jeffrey E. Epstein.
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Co-Executors of the Estate of Jeffrey E. Epstein
Joint Personal Representative of The Estate of Jeffrey E. Epstein
Co-Executor of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
Named as Co-Executor of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
Indyke is Joint Personal Representative of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
Identified as Co-Executor of the Estate of Jeffrey E. Epstein
Indyke listed as Executor of the Estate of Jeffrey E. Epstein
DARREN K. INDYKE... as executors of the ESTATE OF JEFFREY E. EPSTEIN
Co-Executors of the Estate of Jeffrey E. Epstein
Co-Executor of Estate
Executor of the Estate of Jeffrey E. Epstein
Darren K. Indyke... as Joint Personal Representatives of the Estate of Jeffrey E. Epstein
Listed as Co-Executor of the Estate of Jeffrey E. Epstein
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN
Described as 'Co-Executor of the Estate of Jeffrey E. Epstein'
CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN
Indyke is Joint Personal Representative of the Estate of Jeffrey E. Epstein
Darren K. Indyke, in his capacity as Executor of the Estate of Jeffrey E. Epstein
Co-Executor of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
Co-Executors of the Estate of Jeffrey E. Epstein
Listed as Executor of the Estate of Jeffrey E. Epstein
Listed as Joint Personal Representative of the Estate
Described as Joint Personal Representative of the Estate of Jeffrey E. Epstein
Named as Executor of the Estate of Jeffrey E. Epstein
Joint Representative of the Estate of Jeffrey E. Epstein
Described as 'Co-Executors of the Estate of Jeffrey E. Epstein'
Indyke is Co-Executor of Epstein's estate
026.pdf
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.
028.pdf
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.
042.pdf
A letter from Troutman Sanders LLP to Judge Debra Freeman informing the SDNY court that the Superior Court of the Virgin Islands has officially authorized the establishment of the Epstein Victims' Compensation Program. The attached order, signed June 2, 2020, grants the motion to establish the program and authorizes its commencement on or about June 15, 2020, noting an agreement reached with the USVI Attorney General regarding liens and funding.
003.pdf
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.
005.pdf
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.
016.pdf
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.
028.pdf
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.
026.pdf
This document is a 'Notice of Defendants' Motion to Dismiss' filed on February 28, 2020, in the US District Court for the Southern District of New York (Case No. 1:19-cv-10788). The defendants, Darren K. Indyke and Richard D. Kahn (executors of Jeffrey Epstein's estate), represented by Bennet J. Moskowitz of Troutman Sanders LLP, are moving to dismiss the complaint filed by plaintiff Teala Davies with prejudice.
047.pdf
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.
052.pdf
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.
002.pdf
This document is a Civil Cover Sheet (Form JS 44) filed on October 17, 2019, in the Southern District of New York. The plaintiff, Jane Doe 17 (a resident of Florida), is suing the Estate of Jeffrey Epstein (represented by executors Darren Indyke and Richard Kahn) and various associated corporate entities for Battery under federal statutes including 18 USC 1591 (Sex Trafficking). The document lists numerous corporate defendants associated with Epstein (e.g., JEGE Inc., NES LLC) for which the plaintiff's attorney was unable to locate addresses.
029.pdf
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.
034.pdf
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.
002.pdf
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.
003.pdf
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.
010.pdf
This document is a letter filed on May 28, 2020, from attorney Bennet J. Moskowitz to Judge Lewis J. Liman in the case of Jane Doe v. the Executors of the Estate of Jeffrey E. Epstein. The letter outlines an agreement between the parties wherein the defendants accept service of the complaint and are granted an extension until July 21, 2020, to respond. The document includes an endorsement by Magistrate Judge Debra Freeman dated June 15, 2020, ordering approval of this agreement.
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.
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.
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.
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.
013.pdf
This document is a legal letter dated January 24, 2020, from attorney Bennet J. Moskowitz (representing the Estate of Jeffrey Epstein) to Judge Naomi Reice Buchwald. The letter requests a pre-motion conference to move for the dismissal of a lawsuit filed by Maria Farmer. The defense argues that Farmer's claims of assault occurring in Ohio in 1995/1996 are time-barred under both New York and Ohio statutes of limitations and that her arguments for tolling (based on Epstein's later criminal indictment or equitable estoppel) are legally insufficient. It also argues that punitive damages cannot be awarded against an 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.
012.pdf
Attorneys for the Estate of Jeffrey Epstein request a pre-motion conference to dismiss a lawsuit filed by Teresa Helm. The defense argues that Helm's claims of assault from 2002 are barred by the statute of limitations and that exceptions based on Epstein's criminal indictment do not apply because Helm was an adult (22) at the time, while the indictment focused on minors. Additionally, the defense argues that punitive damages cannot be legally awarded against a deceased person's estate under New York law.
050.pdf
This document contains a letter from Troutman Sanders LLP to Judge Debra Freeman in the SDNY, dated June 3, 2020, informing the court that the Superior Court of the Virgin Islands has officially authorized the establishment of the Epstein Victims' Compensation Program. Attached is the official Order from the USVI court (signed by Judge Hermon-Percell) granting the motion to establish the program and authorizing its commencement on June 15, 2020. The document notes that the USVI Attorney General has agreed to lift liens to allow funding for the program.
2022.12.20%20Motion%20-%20Motion.pdf
This document is a legal motion filed on December 20, 2022, in the Superior Court of the Virgin Islands by the Co-Executors of the Jeffrey Epstein Estate (Darren Indyke and Richard Kahn). They are moving to withdraw a previous motion for attorneys' fees because a resolution was reached in a related case (Govt of USVI v. Epstein Estate et al., ST-2020-CV-00014). The document includes a certificate of service listing government officials and attorneys served with this motion.
2021.04.13%20Reply%20Motion.pdf
This document is a 'Plaintiff's Reply to Co-Executors' Brief' filed on April 13, 2021, in the Superior Court of the Virgin Islands by Ghislaine Maxwell's legal team. Maxwell argues that her indemnification case against the Estate of Jeffrey Epstein should not be transferred to the Complex Litigation Division nor assigned to the same judge handling the 'CICO action' (Government v. Indyke). She asserts that her case does not meet the criteria for complex litigation and shares no common facts or claims with the government's racketeering case against the executors.
2021.12.07%20Notice%20of%20Entry%20of%20Judgment.pdf
This document is a Notice of Entry of Order from the Superior Court of the Virgin Islands filed on December 7, 2021. It pertains to three consolidated cases involving the Government of the USVI, the Estate of Jeffrey Epstein (with Darren K. Indyke as executor), and Ghislaine Maxwell (seeking indemnification). The notice lists numerous recipients, including judges and attorneys involved in the proceedings.
2022.07.01%20Order%20Scheduling%20Hearing.pdf
Court order from the Superior Court of the Virgin Islands dated July 1, 2022, in the case of Ghislaine Maxwell v. Estate of Jeffrey E. Epstein. Staff Master Joseph T. Gasper schedules a remote status conference for July 29, 2022, to discuss case management, including a pending motion to intervene by the VI Government and a motion to dismiss by the Estate. The document references delays requested by Maxwell's counsel due to her criminal case in the Southern District of New York.
2022.03.09%20Hearing%20-%20Record%20Of%20Proceeding.pdf
Record of Proceedings from the Superior Court of the Virgin Islands dated March 9, 2022, regarding a civil debt case (ST-2020-CV-00155) filed by Ghislaine Maxwell against the Estate of Jeffrey Epstein and its executors, Darren Indyke and Richard Kahn, as well as NES, LLC. The document details a status hearing presided over by Judge Harold W.L. Willocks, attended by attorneys Kyle R. Waldner and Christopher A. Kroblin. The court set a deadline of August 1, 2022, for the parties to file briefs.
023.pdf
This document is a civil summons filed on September 26, 2019, in the Southern District of New York for Case 1:19-cv-07625-AJN. The plaintiff, identified as 'VE', is suing several entities including Nine East 71st Street Corporation and Financial Trust Company, Inc., as well as Darren K. Indyke and Richard D. Kahn in their capacities as Co-Executors of the Estate of Jeffrey E. Epstein. The document requires the defendants to serve an answer to the complaint within 21 days to the plaintiff's attorney, J. Stanley Pottinger.
025.pdf
This document is a letter dated October 29, 2019, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Alison J. Nathan. The letter represents the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) and associated corporate entities in the case VE v. Nine East 71st Street, et al. It serves to clarify the record regarding an ex parte order issued in a related case (Katlyn Doe) and requests an extension until November 15, 2019, to respond to the Plaintiff's Motion to Proceed Anonymously.
054.pdf
This document is a Joint Proposed Discovery Schedule filed on February 6, 2020, in the case of VE v. Indyke et al. It outlines the agreed-upon timeline for the exchange of evidence, including initial disclosures, medical records, and expert reports. The filing identifies the key subjects of discovery as Epstein's alleged torts against the plaintiff, the liability of the corporate defendants, and the plaintiff's damages.
065.pdf
This document is a Joint Stipulation and Proposed Order filed on June 12, 2020, in the U.S. District Court for the Southern District of New York (Case No. 1:19-cv-07625). The plaintiff, identified as 'VE', and the defendants (Executors of the Epstein Estate and associated entities) agreed to stay the lawsuit to allow the plaintiff to participate in the 'Epstein Victims' Compensation Program', a non-adversarial alternative for resolving sexual abuse claims. The document is signed by attorneys Brad Edwards (for the plaintiff) and Bennet J. Moskowitz (for the defendants).
076.pdf
This document is a Joint Stipulation for Dismissal filed on December 8, 2020, in the U.S. District Court (SDNY). The plaintiff 'VE' and the defendants (Epstein's estate executors Indyke and Kahn, along with associated entities) agreed to dismiss the case with prejudice because the plaintiff resolved her claims through the Epstein Victims' Compensation Program. The order was signed by Judge Alison J. Nathan.
006.pdf
This document is a Motion for Admission Pro Hac Vice filed on August 27, 2019, in the Southern District of New York. Attorney Brittany N. Henderson of Edwards Pottinger, LLC requests permission to represent Plaintiff 'VE' in a civil case against the Estate of Jeffrey E. Epstein and associated entities (Nine East 71st Street Corp, Financial Trust Company, NES LLC). Henderson certifies her good standing with the Florida bar.
072.pdf
A legal status report filed on October 1, 2020, by attorney Bennet J. Moskowitz on behalf of the Epstein Estate executors (Indyke and Kahn) and the Plaintiff 'VE'. The letter informs Judge Freeman that the Plaintiff has submitted a claim to the Epstein Victims’ Compensation Program which is under review, and consequently requests that the civil case remain stayed.
048.pdf
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).
002.pdf
This document is a Civil Cover Sheet (Form JS 44) filed on December 27, 2019, in the Southern District of New York. The plaintiff, using the pseudonym Anastasia Doe, is suing Darren K. Indyke and Richard D. Kahn in their capacities as Co-Executors of the Estate of Jeffrey E. Epstein. The nature of the suit is listed as 'Other Personal Injury' and jurisdiction is based on diversity.
042.pdf
This document is a Court Order from the United States District Court Southern District of New York, dated March 6, 2020, in Case No. 1:19-cv-09610-PAE. The order, signed by Magistrate Judge Debra C. Freeman, officially relieves Andrew S. Buzin and Buzin Law, P.C. as counsel for the plaintiff, Jane Doe 17, in her lawsuit against the Estate of Jeffrey E. Epstein and various associated corporations.
022.pdf
This document is a Summons in a Civil Action filed on September 25, 2019, in the Southern District of New York. The plaintiff, identified as 'VE', is suing several entities including Nine East 71st Street Corporation, Financial Trust Company, Inc., NES, LLC, and the executors of Jeffrey Epstein's estate (Darren K. Indyke and Richard D. Kahn). The summons instructs the defendants to respond to the complaint within 21 days.
025.pdf
This document is a letter from attorney Bennet J. Moskowitz to Judge Debra C. Freeman dated April 15, 2020. It requests a 30-day extension for various discovery and filing deadlines in civil cases brought by Jane Doe 1000, Teresa Helm, and Juliette Bryant against the Estate of Jeffrey Epstein, citing delays caused by the COVID-19 pandemic.
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.
047.pdf
This document is a legal notice filed on September 6, 2021, in the US District Court for the Southern District of New York (Case No. 1:20-cv-02365-LJL-DCF). The defendants, Darren K. Indyke and Richard D. Kahn (executors of Jeffrey Epstein's estate), represented by attorney Bennet J. Moskowitz, are moving to dismiss the complaint filed by Plaintiff Jane Doe with prejudice under Rule 12(b)(6).
2023.02.15%20Notice%20of%20Entry%20of%20Judgment.pdf
This document is a Notice of Entry of Order from the Superior Court of the Virgin Islands, filed on February 15, 2023. It notifies Ghislaine Maxwell (Plaintiff) and various attorneys that an order was entered regarding case ST-2020-CV-00155, a debt action against the Estate of Jeffrey Epstein, his executors (Indyke and Kahn), and NES, LLC.
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.
031.pdf
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.
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.
012.pdf
This document is a letter from Bennet J. Moskowitz of Troutman Sanders LLP to Judge Andrew L. Carter Jr., dated January 24, 2020. It serves as a pre-motion letter outlining the Estate of Jeffrey Epstein's intent to move for dismissal of a lawsuit filed by Juliette Bryant. The Estate argues that Bryant's claims regarding alleged sexual abuse between 2002 and 2004 are time-barred by the statutes of limitations in New York, USVI, Florida, and New Mexico, and that she cannot rely on the Child Victims Act or tolling because she was an adult (age 20-22) at the time of the alleged incidents. Additionally, the letter argues that punitive damages cannot be recovered from a decedent's estate under the relevant laws.
014.pdf
A status report filed on August 14, 2020, by attorney Bennet J. Moskowitz regarding the case of Jane Doe v. The Estate of Jeffrey Epstein. The document informs Judge Freeman that the Plaintiff is submitting claims to the Epstein Victims' Compensation Program and requests that the legal action remain stayed.
033.pdf
This document is a legal declaration by attorney Daniel Mullkoff submitted in the case of Teala Davies v. Darren K. Indyke and Richard D. Kahn (Executors of the Epstein Estate). The declaration serves to introduce three exhibits into the court record: Epstein's Last Will and Testament (dated Aug 8, 2019), a complaint filed by the US Virgin Islands, and an Affidavit of Service from the case Araoz v. Epstein. The declaration opposes the Defendants' Motion to Dismiss.
029.pdf
A letter from attorney Bennet J. Moskowitz to Judge Alison J. Nathan requesting a two-week extension for the Epstein Estate executors and associated entities to respond to a complaint in the case 'VE v. Nine East 71st Street'. The Judge granted the request on November 14, 2019, extending the deadline to November 29, 2019, but handwritten notes explicitly state 'No further extensions'.
051.pdf
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.
037.pdf
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.
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.
017.pdf
This document is an Amended Order from the United States District Court for the Southern District of New York, dated January 22, 2020, in the civil case of Teala Davies v. Darren K. Indyke and Richard D. Kahn (Executors of the Estate of Jeffrey E. Epstein). Judge Gregory H. Woods refers the case to a Magistrate Judge for general pretrial purposes (scheduling, discovery, settlement) and for dispositive motions requiring a Report and Recommendation.
041-01.pdf
A court order from the Southern District of New York dated March 6, 2020, in the case of Jane Doe 17 v. The Estate of Jeffrey Epstein and associated entities. Judge Debra C. Freeman orders that attorney Andrew S. Buzin and his firm are relieved and discharged from representing the plaintiff, Jane Doe 17. The document lists numerous corporate defendants associated with Epstein's estate.
2022.09.08%20Notice%20of%20Entry%20of%20Judgment.pdf
A Notice of Entry of Order from the Superior Court of the Virgin Islands filed on September 8, 2022. The document concerns a debt action (Case ST-2020-CV-00155) brought by Ghislaine Maxwell against the Estate of Jeffrey Epstein, his executors (Indyke and Kahn), and NES, LLC. The notice informs the listed attorneys that an order dated September 7, 2022, has been entered into the record.
042.pdf
This document is a 'Joint Stipulation for Dismissal' filed on November 9, 2020, in the U.S. District Court for the Southern District of New York (Case 1:19-cv-11869). Plaintiff 'Anastasia Doe' agrees to dismiss her case against the Co-Executors of the Jeffrey Epstein Estate (Indyke and Kahn) with prejudice because her claims were resolved through the Epstein Victims' Compensation Program. The order is signed by Judge Mary Kay Vyskocil.
014.pdf
This document is a Court Order and Joint Stipulation filed on January 28, 2020, in the Southern District of New York regarding the case of Anastasia Doe v. The Estate of Jeffrey Epstein. The order, signed by Judge Alison J. Nathan, establishes strict protocols to maintain the plaintiff's anonymity, including requirements for sealing documents and executing non-disclosure agreements for any parties privy to her identity. It also documents the agreement between the Plaintiff's counsel (Bradley J. Edwards) and the Defendants (Executors Indyke and Kahn) to adhere to these anonymity protections.
2020.07.30%20Stipulation%20For%20Extension%20of%20Time.pdf
This document is a legal stipulation filed on July 30, 2020, in the Superior Court of the Virgin Islands (Case ST-20-CV-155). It represents an agreement between Ghislaine Maxwell (Plaintiff) and the Government of the U.S. Virgin Islands (Proposed Intervenor) to extend the deadline for Maxwell to respond to the Government's Motion to Intervene until August 17, 2020. The document lists the Estate of Jeffrey Epstein and his executors, Darren K. Indyke and Richard D. Kahn, as defendants.
020.pdf
A letter filed on February 20, 2020, by attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Paul G. Gardephe in the case of Teresa Helm v. the Estate of Jeffrey Epstein. Moskowitz requests a one-day extension for filing a Motion to Dismiss due to illness, pushing the deadline to February 24, 2020. The document includes a memo endorsement signed by Judge Gardephe on February 22, 2020, granting the request.
016.pdf
This document is a status report filed on October 1, 2020, by attorney Bennet J. Moskowitz on behalf of the Estate of Jeffrey Epstein's executors (Indyke and Kahn) in the case of Jane Doe v. Indyke et al. The letter informs Judge Freeman that the Plaintiff intends to submit a claim to the Epstein Victims’ Compensation Program. Consequently, both parties request that the court case remain stayed to save resources while the claim is processed through the Program.
074.pdf
A legal status report filed on December 1, 2020, by attorney Bennet J. Moskowitz regarding the case 'VE v. Darren Indyke and Richard D. Kahn'. The document informs Judge Debra C. Freeman that the plaintiff (VE) has submitted a claim to the Epstein Victims' Compensation Program and has received an award offer which she is considering. The parties request that the court case remain stayed while this settlement process concludes.
031.pdf
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.
033.pdf
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).
027.pdf
This document is a legal letter filed on July 21, 2021, in the case of Jane Doe v. the Executors of the Estate of Jeffrey E. Epstein. Plaintiff's attorney, Daniel J. Kaiser, requests a one-week extension from Judge Debra C. Freeman to submit a motion for the Plaintiff to proceed anonymously, citing a scheduling conflict with an arbitration. The letter notes that the Defendants consent to this extension request.
2020.09.28%20Response%20to%20Opposition.pdf
This is a Reply Brief filed by the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in response to a lawsuit by Ghislaine Maxwell. Maxwell is suing the Estate and NES, LLC for indemnification (payment of her legal fees) related to her criminal and civil cases in New York. The Co-Executors argue the case should be dismissed because: 1) The claim is 'unripe' as her underlying guilt or innocence hasn't been established; 2) Public policy forbids indemnifying criminal conduct; 3) The NES Operating Agreement explicitly allows the company to decline indemnification; and 4) The Statute of Frauds bars claims based on alleged oral promises.
024.pdf
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.
021.pdf
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.
2022.02.22%20Order%20Scheduling%20Hearing.pdf
A court order from the Superior Court of the Virgin Islands dated February 22, 2022, in the case of Ghislaine Maxwell v. Estate of Jeffrey E. Epstein et al. (Case No. ST-2020-CV-00155). Judge Harold W.L. Willocks ordered a status conference to be held via Zoom on March 9, 2022. The defendants include Epstein's estate, his executors Darren Indyke and Richard Kahn, and NES, LLC.
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.
040.pdf
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).
003-02.pdf
This document is a proposed Order for Admission Pro Hac Vice filed on December 27, 2019, in the Southern District of New York case of Anastasia Doe vs. The Estate of Jeffrey Epstein. The order grants attorney Bradley J. Edwards of Edwards Pottinger LLC permission to represent the plaintiff, Anastasia Doe, in this action.
040.pdf
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.
003.pdf
This document is a Motion for Admission Pro Hac Vice filed on December 27, 2019, in the Southern District of New York. Attorney Bradley J. Edwards seeks permission to represent Plaintiff Anastasia Doe in her lawsuit against Darren K. Indyke and Richard D. Kahan, the co-executors of the Estate of Jeffrey E. Epstein. Edwards attests to his good standing with the Florida and New York bars and lack of disciplinary history.
066.pdf
This document is a Joint Stipulation and Order Staying Action from June 2020 in the Southern District of New York. The plaintiff 'VE' and the defendants (Epstein's estate executors Indyke and Kahn, and associated entities) agreed to pause the litigation to allow the plaintiff to participate in the 'Epstein Victims' Compensation Program,' a non-adversarial alternative. Judge Debra Freeman signed the order, staying the case and requiring a status report by August 14, 2020.
2023.09.19%20Proposed%20Order.pdf
A court order from the Superior Court of the Virgin Islands dated September 19, 2023, dismissing Ghislaine Maxwell's complaint against the Estate of Jeffrey Epstein, executors Indyke and Kahn, and NES, LLC. The dismissal was granted based on a failure to prosecute or alternatively to compel the plaintiff to appear pro se. The order is signed by Presiding Judge Harold W.L. Willocks.
038.pdf
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.
019.pdf
Legal correspondence dated February 20, 2020, from attorney Bennet J. Moskowitz (Troutman Sanders LLP) to Judge Paul G. Gardephe regarding the case Teresa Helm v. The Estate of Jeffrey E. Epstein. The letter requests a one-business-day extension for filing the Defendants' Motion to Dismiss due to the attorney's recent illness, adjusting the deadline to February 24, 2020.
DOJ-OGR-00019445.jpg
This document is a Memorandum and Order from the U.S. District Court (SDNY) dated September 14, 2020, in the civil case of Jane Doe v. Darren K. Indyke, et al. Magistrate Judge Debra Freeman grants a motion filed by defendant Ghislaine Maxwell to stay the civil proceedings entirely pending the resolution of Maxwell's parallel criminal case (United States v. Ghislaine Maxwell). The document notes that Maxwell is currently in custody at the MDC awaiting a criminal trial scheduled for July 12, 2021.
DOJ-OGR-00015259.jpg
This document is the first page of a legal filing in the US District Court for the Southern District of New York (Case 1:20-cv-00484-JKG). It details Plaintiff 'Jane Doe's' response to the first set of interrogatories sent by the defendants, Darren K. Indyke and Richard D. Kahn, who are the executors of Jeffrey Epstein's estate. The page contains standard legal preliminary statements regarding non-admission of facts and is marked as a Defendant's Exhibit (J-15-R) in a related criminal case (S2 20 Cr. 330).
Entities connected to both Darren K. Indyke and JEFFREY E. EPSTEIN
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