MEMY-1805 marker2-fixhub court-doe-v-indyke-11869 (pepper 16-core): 108/108

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751696/EFTA02751696.md

@@ -0,0 +1,169 @@
+# EXHIBIT A
+
+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+x
+
+UNITED STATES OF AMERICA
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+x
+
+SEALED
+
+INDICTMENT
+
+19 Cr.
+
+19CRIM 490
+
+COUNT ONE
+
+(Sex Trafficking Conspiracy)
+
+The Grand Jury charges:
+
+## OVERVIEW
+
+1. As set forth herein, over the course of many years, JEFFREY EPSTEIN, the defendant, sexually exploited and abused dozens of minor girls at his homes in Manhattan, New York, and Palm Beach, Florida, among other locations.
+
+2. In particular, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence") to engage in sex acts with him, after which he would give the victims hundreds of dollars in cash. Moreover, and in order to maintain and increase his supply of victims, EPSTEIN also paid certain of his victims to recruit additional girls to be similarly abused by EPSTEIN. In
+
+this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in locations including New York and Palm Beach.
+
+3. The victims described herein were as young as 14 years old at the time they were abused by JEFFREY EPSTEIN, the defendant, and were, for various reasons, often particularly vulnerable to exploitation. EPSTEIN intentionally sought out minors and knew that many of his victims were in fact under the age of 18, including because, in some instances, minor victims expressly told him their age.
+
+4. In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, the defendant, worked and conspired with others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence.
+
+## FACTUAL BACKGROUND
+
+5. During all time periods charged in this Indictment, JEFFREY EPSTEIN, the defendant, was a financier with multiple residences in the continental United States, including the New York Residence and the Palm Beach Residence.
+
+6. Beginning in at least 2002, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and
+
+recruited, dozens of minor girls to engage in sex acts with him, after which EPSTEIN paid the victims hundreds of dollars in cash, at the New York Residence and the Palm Beach Residence.
+
+7. In both New York and Florida, JEFFREY EPSTEIN, the defendant, perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to EPSTEIN, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts. EPSTEIN paid his victims hundreds of dollars in cash for each encounter. Moreover, EPSTEIN actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. EPSTEIN incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each girl that they brought to EPSTEIN. In so doing, EPSTEIN maintained a steady supply of new victims to exploit.
+
+### The New York Residence
+
+8. At all times relevant to this Indictment, JEFFREY EPSTEIN, the defendant, possessed and controlled amulti-story private residence on the Upper East Side of Manhattan, New York, i.e., the New York Residence. Between at least in or about {sup}`2002` and in or about 2005, EPSTEIN abused numerous minor victims at the New York Residence by causing these victims to be recruited to engage in paid sex acts with him.
+
+9. When a victim arrived at the New York Residence, she typically would be escorted to a room with a massage table, where she would perform a massage on JEFFREY EPSTEIN, the defendant. The victims, who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts such as groping and direct and indirect contact with the victim's genitals. EPSTEIN typically would also masturbate during these sexualized encounters, ask victims to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys.
+
+10. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars in cash for each encounter.
+
+11. JEFFREY EPSTEIN, the defendant, knew that many of his New York victims were underage, including because certain victims told him their age. Further, once these minor victims were recruited, many were abused by EPSTEIN on multiple subsequent occasions at the New York Residence. EPSTEIN sometimes personally contacted victims to schedule appointments at the New York Residence. In other instances, EPSTEIN directed
+
+employees and associates, including aNew York-based employee ("Employee-1"), to communicate with victims via phone to arrange for these victims to return to the New York Residence for additional sexual encounters with EPSTEIN.
+
+12. Additionally, and to further facilitate his ability to abuse minor girls in New York, JEFFREY EPSTEIN, the defendant, asked and enticed certain of his victims to recruit additional girls to perform "massages" and similarly engage in sex acts with EPSTEIN. When avictim would recruit another girl for EPSTEIN, he paid both the victim-recruiter and the new victim hundreds of dollars in cash. Through these victimrecruiters, EPSTEIN gained access to and was able to abuse dozens of additional minor girls.
+
+13. In particular, certain recruiters brought dozens of additional minor girls to the New York Residence to give massages to and engage in sex acts with JEFFREY EPSTEIN, the defendant. EPSTEIN encouraged victims to recruit additional girls by offering to pay these victim-recruiters for every additional girl they brought to EPSTEIN. When avictimrecruiter accompanied anew minor victim to the New York Residence, both the victim-recruiter and the new minor victim were paid hundreds of dollars by EPSTEIN for each encounter. In addition, certain victim-recruiters routinely scheduled these
+
+encounters through Employee-1, who sometimes asked the recruiters to bring a specific minor girl for EPSTEIN.
+
+# The Palm Beach Residence
+
+14. In addition to recruiting and abusing minor girls in New York, JEFFREY EPSTEIN, the defendant, created a similar network of minor girls to victimize in Palm Beach, Florida, where EPSTEIN owned, possessed and controlled another large residence, i.e., the Palm Beach Residence. EPSTEIN frequently traveled from New York to Palm Beach by private jet, before which an employee or associate would ensure that minor victims were available for encounters upon his arrival in Florida.
+
+15. At the Palm Beach Residence, JEFFREY EPSTEIN, the defendant, engaged in a similar course of abusive conduct. When a victim initially arrived at the Palm Beach Residence, she would be escorted to a room, sometimes by an employee of EPSTEIN's, including, at times, two assistants ("Employee-2" and' "Employee-3") who, as described herein, were also responsible for scheduling sexual encounters with minor victims. Once inside, the victim would provide a nude or semi-nude massage for EPSTEIN, who would himself typically be naked. During these encounters, EPSTEIN would escalate the nature and scope of the physical contact to include sex acts such as groping and direct and indirect contact with the victim's genitals. EPSTEIN would also typically masturbate during these encounters, ask victims
+
+to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys.
+
+16. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars for each encounter.
+
+17. JEFFREY EPSTEIN, the defendant, knew that certain of his victims were underage, including because certain victims told him their age. In addition, as with New York-based victims, many Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant, on multiple additional occasions.
+
+18. JEFFREY EPSTEIN, the defendant, who during the relevant time period was frequently in New York, would arrange for Employee-2 or other employees to contact victims by phone in advance of EPSTEIN's travel to Florida to ensure appointments were scheduled for when he arrived. In particular, in certain instances, Employee-2 placed phone calls to minor victims in Florida to schedule encounters at the Palm Beach Residence. At the time of certain of those phone calls, EPSTEIN and Employee-2 were in New York, New York. Additionally, certain of the individuals victimized at the Palm Beach Residence were contacted by phone by Employee-3 to schedule these encounters.
+
+19. Moreover, as in New York, to ensure a steady stream of minor victims, JEFFREY EPSTEIN, the defendant, asked and enticed certain victims in Florida to recruit other girls to engage in sex acts. EPSTEIN paid hundreds of dollars to victimrecruiters for each additional girl they brought to the Palm Beach Residence.
+
+## STATUTORY ALLEGATIONS
+
+20. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York and elsewhere, JEFFREY EPSTEIN, the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, sex trafficking of minors, in violation of Title 18, United States Code, Section. 1591(a) and (b).
+
+21. It was a part and object of the conspiracy that JEFFREY EPSTEIN, the defendant, and others known and unknown, would and did, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, and obtain, by any means a person, and to benefit, financially and by receiving anything of value, from participation in a venture which has engaged in any such act, knowing that the person had not attained the age of 18 years and would be caused to engage in a
+
+commercial sex act, in violation of Title 18, United States Code, Sections 1591(a) and (b)(2).
+
+### Overt Acts
+
+22. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere:
+
+a. In or about 2004, JEFFREY EPSTEIN, the defendant, enticed and recruited multiple minor victims, including minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3, to engage in sex acts with EPSTEIN at his residences in Manhattan, New York, and Palm Beach, Florida, after which he provided them with hundreds of dollars in cash for each encounter.
+
+b. In or about 2002, Minor Victim-1 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the New York Residence over {sup}`a` period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-1 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-1 how old she was, and Minor Victim-1 answered truthfully.
+
+c. In or about 2004, Employee-1, located in the Southern District of New York, and on behalf of EPSTEIN, placed
+
+{sup}`a`telephone call to Minor Victim-1 in order to schedule an appointment for Minor Victim-1 to engage in paid sex acts with EPSTEIN.
+
+d. In or about 2004, Minor Victim-2 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over {sup}`a` period of years and was paid hundreds of dollars after each encounter. EPSTEIN also encouraged and enticed Minor Victim-2 to recruit other girls to engage in paid sex acts, which she did.
+
+e. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed {sup}`a`telephone call to Minor Victim-2 in order to schedule an appointment for Minor Victim-2 to engage in paid sex acts with EPSTEIN.
+
+f. In or about 2005, Minor Victim-3 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over {sup}`a` period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-3 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-3 how old she was, and Minor Victim-3 answered truthfully.
+
+g• In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed {sup}`a`telephone call to Minor Victim-3 in Florida in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN.
+
+h. In or about 2004, Employee-3 placed {sup}`a` telephone call to Minor Victim-3 in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN.
+
+(Title 18, United States Code, Section 371.)
+
+## COUNT TWO (Sex Trafficking)
+
+The Grand Jury further charges:
+
+23. The allegations contained in paragraphs {sup}`1` through 19 and 22 of this Indictment are repeated and realleged as if fully set forth within.
+
+24. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York, JEFFREY EPSTEIN, the defendant, willfully and knowingly, in and affecting interstate and foreign commerce, did recruit, entice, harbor, transport, provide, and obtain by any means {sup}`a` person, knowing that the person had not attained the age of {sup}`18` years and would be caused to engage in acommercial sex act, and did aid and abet the same, to wit, EPSTEIN recruited, enticed, harbored, transported, provided, and obtained numerous
+
+individuals-who were less than 18 years old, including but not limited to Minor Victim-1, as described above, and who were then caused to engage in at least one commercial sex act in Manhattan, New York.
+
+> (Title 18, United States Code, Sections 1591(a), (b)(2), and 2.)
+
+### FORFEITURE ALLEGATIONS
+
+25. As a result of committing the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 1594(c)(1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the offense alleged in Count Two, and any property, real or personal, constituting or derived from any proceeds obtained, directly or indirectly, as {sup}`a`result of the offense alleged in Count Two, or any property traceable to such property, and the following specific property:
+
+a. The lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 9 East 71st Street, New York, New York, with block number 1386 and lot number 10, owned by Maple, Inc.
+
+Substitute Asset Provision
+
+26. If any of the above-described forfeitable property, as a result of any act or omission of the defendant:
+
+- (a) cannot be located upon the exercise of due diligence;
+- (b) has been transferred or sold to, or deposited with, a third person;
+- (c) has been placed beyond the jurisdiction of the Court;
+- (d) has been substantially diminished in value; or
+- (e) has been commingled with other property which cannot be subdivided without difficulty;
+
+it is the intent of the United States, pursuant to 21 U.S.C. § 853(p) and 28 U.S.C. § 2461(c), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property.
+
+(Title 18, United States Code, Section 1594; Title 21, United States Code, Section 853(p); and Title 28, United States Code, Section 2461.)
+
+Form No. USA-33s-274 (Ed. 9-25-58)
+
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+# UNITED STATES OF AMERICA
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## INDICTMENT
+
+(18 U.S.C. §9 371, 1591(a), (b)(2), and 2)
+
+GEOFFREY S. BERMAN
+
+United States Attorney .
+
+CV...101,1010\M

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751696/EFTA02751696.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -58,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751696",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 3,
+  "fix_ids": "[\"builtin.empty-image\", \"swarm.html-myst-whitelist\"]",
+  "idempotent": true,
+  "input_sha256": "d329ab044e041a08599399d31295df84a3e6b543b1394ce953fd1c56058b95ba",
+  "output_sha256": "709f823e5e0ee495ab83f677a6909dd472394787c2f122dc1e734b18d0bf2d9a",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751711/EFTA02751711.md

@@ -0,0 +1,220 @@
+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+ANASTASIA DOE,
+
+Plaintiff, CASE NO.:
+
+vs.
+
+DARREN K. INDYKE AND RICHARD D. KAHN AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN
+
+Defendant.
+
+## COMPLAINT
+
+Plaintiff, ANASTASIA DOE, by and through her undersigned counsel, for her claims against Defendant, Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein, states and alleges as follows:
+
+- 1. The controversy in this cause of action exceeds the sum or value of \$75,000, exclusive of interest and costs, and is between citizens of different States. Therefore, jurisdiction is proper under 28 U.S.C. section 1332.
+- 2. Plaintiff who was born in 1989 and files this Complaint under a pseudonym in order to protect her identity because this Complaint makes allegations of a sensitive sexual nature the disclosure of which, in association with her name, would cause further harm to her.
+  - 3. Plaintiff is currently a resident of and domiciled in the state of New York.
+- 4. At all times material to this cause of action, Jeffrey Epstein travelled between and stayed regularly in multiple residences, including in New York, New York and the United States Virgin Islands. He was a citizen of the United States and a resident of the U.S. Virgin Islands.
+
+5. At all times material to this cause of action Jeffrey Epstein was an adult male born in 1953, who died on August 10, 2019.
+
+6. Defendant, Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein ("Estate of Jeffrey E. Epstein") the Estate of Jeffrey E. Epstein was opened and domiciled in the United States Virgin Islands, St. Division, and is the legal entity responsible for intentional, criminal, or tortious conduct committed by Jeffrey Epstein as described in this Complaint.
+
+7. A substantial part of the acts, events, and omissions giving rise to this cause of action occurred in the Southern District of New York; venue is proper in this District. 28 U.S.C. section 1391(bX2).
+
+8. At all times material to this cause of action, Jeffrey Epstein (legally represented now through Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein (and referred to herein as "Estate of Jeffrey E. Epstein") owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit, or conspire to commit, or cause to be committed intentional, criminal, fraudulent, or tortious acts against Plaintiff, including any acts that would cause Plaintiff to be harmed through conduct committed against her in violation of New York Penal Law section 214-G, New York Penal Law section 130.20; or New York Penal Law 130.25; or New York Penal Law 130.35; or New York Penal Law 130.40; or New York Penal Law 130.52; or New York Penal Law 130.66.
+
+# FACTUAL ALLEGATIONS
+
+9. At all times material to this cause of action, Jeffrey Epstein was an adult male over 45 years old. Epstein was tremendously wealthy, widely recognized as a billionaire, who used his wealth, power, resources, and connections to commit illegal sexual crimes in violation of federal and state statutes and to employ and conspire with other individuals and corporate entities to assist him in committing those crimes or torts or to facilitate or enable those acts to occur.
+
+10. Epstein displayed his enormous wealth, power, and influence to his employees; to the employees of the corporate or company entities who worked at his direction; to the victims procured for sexual purposes; and to the public, in order to advance and carry out and conceal his crimes and torts.
+
+11. The allegations herein primarily concern Jeffrey Epstein's conduct while at his townhouse in New York.
+
+12. Epstein had a compulsive sexual preference for young females as young as 14 years old.
+
+13. Epstein enjoyed sexual contact with young females, including minor children, and took pleasure corrupting vulnerable young females, including minor children, into engaging in sexual acts with him.
+
+14. Epstein directed a complex system of individuals, including employees and associates of entities, to work in concert and at his direction, for the purpose of harming teenage girls through sexual exploitation.
+
+15. On July 2, 2019, the United States Attorney's Office for the Southern District of New York filed a Sealed Two Count Indictment inclusive of One Count of Sex Trafficking Conspiracy and One Count of Sex Trafficking, in part due to Epstein's criminal activities against children in the New York Mansion located at 9 East 71a Street.
+
+16. On July 8, 2019, Jeffrey Epstein was arrested pursuant to the aforementioned Indictment, which is attached hereto as Exhibit A.
+
+17. The Indictment stated in part, and Plaintiff herein adopts as true, that "from at least in or about 2002, up to and including at least in or about 2005, Jeffrey Epstein, the defendant, enticed and recruited, and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence") to engage in sex acts with him, after which the victims were given hundreds of dollars in cash." Criminal Indictment at 1.
+
+18. "Moreover, and in order to maintain and increase his supply of victims, Epstein also paid certain of his victims to recruit additional girls to be similarly abused by EPSTEIN. In this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in locations including New York and Palm Beach." Criminal Indictment at 1-2.
+
+19. "The victims described herein were as young as 14 years old at the time they were abused by Jeffrey Epstein, and were, for various reasons, often particularly vulnerable to exploitation. Epstein intentionally sought out minors and knew that many of his victims were in fact under the age of 18, including because, in some instances, minor victims expressly told him their age." Criminal Indictment at 2.
+
+20. "In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, ... worked and conspired with others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence." Criminal Indictment at 2.
+
+21. The indictment further explained, and Plaintiff adopts and alleges, that, "[v]ictims were initially recruited to provide `massages' to Epstein, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts." Criminal Indictment at 3.
+
+22. "Between at least in or about 2002 and in or about 2005, Epstein abused numerous minor victims at the New York Residence by causing these victims to be recruited to engage in paid sex acts with him." Criminal Indictment at 3.
+
+23. Jeffrey Epstein received near daily massages from young females, often minors, who were not experienced in massage. Rather than receive regular body massages, Epstein was predictably sexually abusing the young females in violation of New York Penal Law Section 130.
+
+24. Jeffrey Epstein, specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females to sexually molest and abuse.
+
+## ANASTASIA DOE
+
+25. Minor victim ANASTASIA DOE was subjected to the types of illegal sexual acts detailed in the Criminal Indictment filed against Jeffrey Epstein by the Southern District of New York and adopts herein the allegations above detailed in paragraphs 8-24.
+
+26. Jeffrey Epstein committed acts of sexual abuse against Plaintiff from 2003 through 2008, beginning when she was 14 years old.
+
+27. In or about 2003, Plaintiff was recruited by another minor child to go to Jeffrey Epstein's mansion in Manhattan, New York to provide him with a "massage."
+
+28. The minor child who recruited Plaintiff informed Plaintiff that she would be paid \$300 to provide a massage to a rich man in Manhattan.
+
+29. Plaintiff was a minor female with no experience or training in massage.
+
+30. In 2003, Plaintiff's friend brought Plaintiff to Jeffrey Epstein's townhouse mansion located at 9 East 71' Street, NY to provide him with a massage.
+
+31. Upon arrival to the mansion, the two minor children were escorted inside by an employee working at the mansion up to Jeffrey Epstein's massage room.
+
+32. Plaintiffs friend entered the massage room with Plaintiff where they met Jeffrey Epstein.
+
+33. Jeffrey Epstein lay down naked on the massage table and instructed Plaintiff and her friend to remove their clothes, and both complied.
+
+34. Plaintiff's friend began instructing Plaintiff how to provide Jeffrey Epstein a massage and Plaintiff began doing as told.
+
+35. During the massage, Jeffrey Epstein turned over and began touching Plaintiff's breasts, and vagina.
+
+36. Jeffrey Epstein then began masturbating in front of Plaintiff while instructing Plaintiff to pinch his nipples.
+
+37. Jeffrey Epstein took out a vibrator sex toy and used it forcefully on Plaintiffs vagina.
+
+38. During this first encounter, Jeffrey Epstein penetrated Plaintiff's vagina with his finger and the sex toy.
+
+39. Jeffrey Epstein continued to masturbate until ejaculation, after which he paid Plaintiff \$300.
+
+40. After the first encounter, Plaintiff was asked for her telephone number which was kept by Jeffrey Epstein or one of his employees who worked at his NY mansion.
+
+41. Plaintiff was contacted regularly beginning in 2003 while she was 14 years old to schedule times for her to visit the mansion and engage in sexual acts with Jeffrey Epstein in his massage room.
+
+42. Lesley Groff, one of Jeffrey Epstein's most trusted employees, would typically call Plaintiff to schedule a time for her to visit Jeffrey Epstein at the mansion. Other times, Plaintiff would be called by Jeffrey Epstein directly.
+
+43. Beginning in 2003 through 2006, Plaintiff visited Jeffrey Epstein at his mansion on average once per week. During each visit, Jeffrey Epstein engaged in sexual contact with Plaintiff, which often included touching her naked breasts and vagina and using sex toys on her vagina.
+
+44. On numerous occasions, Jeffrey Epstein would forcibly insert his finger or sex toy into Plaintiff's vagina.
+
+45. On one occasion when Plaintiff was 15 years old, Jeffrey Epstein's girlfriend entered the massage room while Plaintiff was in there. Jeffrey Epstein ordered his girlfriend to engage in oral sex with Plaintiff during that occasion, which she did by force and against Plaintiff's will and consent.
+
+46. On another occasion, when Plaintiff was 16 years old, Jeffrey Epstein engaged in forcible sexual intercourse with Plaintiff, and paid her \$400 instead of the normal \$300 after that forcible sexual encounter.
+
+47. In addition to going to Jeffrey Epstein's mansion where Jeffrey Epstein violated the minor Plaintiff sexually, Jeffrey Epstein also encouraged Plaintiff to bring her high school friends to him for sexual purposes as well.
+
+48. Jeffrey Epstein told Plaintiff he would pay her \$300 for each friend she brought him.
+
+49. Plaintiff did as she was instructed to do and brought Jeffrey Epstein other females as young as 14 years old. Plaintiff was paid \$300 for each she brought.
+
+50. While Plaintiff was a minor child, beginning when she was 14 years old until Plaintiff was 17 years old, Jeffrey Epstein repeatedly committed sexual acts against Plaintiff constituting sexual offenses as defined in New York Penal Law § 130. On numerous occasions during that period of time, Jeffrey Epstein sexually touched and penetrated Plaintiff's vagina with his fingers and sex toys, he masturbated in front of her, caused her to engage in sex acts with another female, and on one occasion had sexual intercourse with Plaintiff when she was only 16 years old. All sexual acts were performed by Jeffrey Epstein intentionally and for no legitimate purpose and for his own gratification when Plaintiff was a minor child less than seventeen years of age.
+
+51. Pursuant to New York Penal Law § 130.05, a person is deemed incapable of consent when she is less than seventeen years old.
+
+52. Jeffrey Epstein committed sexual misconduct against Plaintiff as defined in § I30.20 of the New York Penal Law, inasmuch as Jeffrey Epstein engaged in sexual intercourse with Plaintiff without Plaintiff's consent.
+
+53. Jeffrey Epstein committed rape in the third degree as defined in §130.25 inasmuch as Jeffrey Epstein engaged in sexual intercourse with Plaintiff when Jeffrey Epstein was over 21 years old and Plaintiff was less than 17 years old.
+
+54. Jeffrey Epstein committed rape in the first degree as defined in §130.35 inasmuch as Jeffrey Epstein engaged in sexual intercourse with Plaintiff by forcible compulsion;
+
+55. Jeffrey Epstein caused a Criminal sexual act in the third degree to be committed as defined in §130.40 inasmuch as Jeffrey Epstein forced Plaintiff to be forcibly subjected to oral sexual contact by his girlfriend against Plaintiff's consent.
+
+56. Jeffrey Epstein committed a forcible touching against Plaintiff as defined in §130.52 of the New York Penal Law, inasmuch as Jeffrey Epstein, intentionally and for no legitimate purpose, engaged the forcible sexual touching of Plaintiff for the purpose of degrading or abusing her or for the purpose of gratifying his sexual desire.
+
+57. Jeffrey Epstein committed sexual abuse in the third degree against Plaintiff as defined in §130.55 of the New York Penal Law when he engaged in sexual contact with Phi at i Il beginning when she was 14 years old and including through a time when she was 17 years old and when Jeffrey Epstein was greater than 5 years her elder.
+
+58. Jeffrey Epstein committed an aggravated sexual abuse in the third degree against her as defined in §130.66 of the New York Penal Law, inasmuch as Jeffrey Epstein inserted a foreign object into the vagina of Plaintiff by forcible compulsion.
+
+### COUNT I BATTERYNIOLATION OF SECTION 130 AGAINST THE ESTATE OF JEFFREY E. EPSTEIN
+
+59. Plaintiff incorporates by reference paragraphs 1-58 and re-alleges them as if set forth fully herein.
+
+60. The intentional acts of Jeffrey Epstein against Plaintiff constitute a sexual offense as defined in New York Penal Law § 130, including but not limited to the following:
+
+- a. Sexual misconduct as defined in §130.20 inasmuch as Jeffrey Epstein engaged in sexual intercourse with Plaintiff without Plaintiff's consent;
+- b. Rape in the third degree as defined in §130.25 inasmuch as Jeffrey Epstein engaged in sexual intercourse with Plaintiff when Jeffrey Epstein was over 21 years old and Plaintiff was less than 17 years old.
+- c. Rape in the first degree as defined in §130.35 inasmuch as Jeffrey Epstein engaged in sexual intercourse with Plaintiff by forcible compulsion;
+
+d. Criminal Sexual Act in the third degree as defined in §130.40 inasmuch as Jeffrey Epstein forced Plaintiff to receive oral sexual contact by Jeffrey Epstein's girlfriend without Plaintiff's consent;
+
+e. Forcible touching as defined in §130.52 inasmuch as Jeffrey Epstein, intentionally and for no legitimate purpose, engaged the forcible sexual touching of Plaintiff for the purpose of degrading or abusing her or for the purpose of gratifying his own sexual desire; and
+
+f. Sexual abuse in the third degree as defined in §I30.66 inasmuch as Jeffrey Epstein inserted a foreign object in the vagina of Plaintiff by forcible compulsion.
+
+g. Aggravated sexual abuse in the second degree as defined in § 130.67 inasmuch as Jeffrey Epstein caused physical injury to Plaintiff when he inserted a finger into the vagina of Plaintiff by forcible compulsion.
+
+61. On numerous occasions as described in the complaint above, Epstein intentionally, forcibly, violently, or invasively used his fingers, and foreign objects to make unwanted, unlawful, harmful, and offensive physical contact with Plaintiff's body.
+
+62. This conduct caused Plaintiff serious and persistent harm and contributed to injuries that Plaintiff continues to suffer.
+
+63. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+64. As a direct and proximate result of Jeffrey Epstein's violations of New York Penal Law § 130, Plaintiff has in the past suffered and in the future will continue to suffer physical injury, pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and a loss of her capacity to enjoy life, as well as other damages. Plaintiff incurred medical and psychological expenses and Plaintiff will in
+
+the future suffer additional medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. Epstein for compensatory and general damages, and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
+
+### COUNT TWO SEXUAL ASSAULT
+
+65. Plaintiff incorporates by reference paragraphs 1-58 and re-alleges them as if set forth fully herein.
+
+66. On numerous occasions over three years, Epstein made violent sexual demands on Plaintiff while placing his hands on her body in a position of dominance and control and while touching Plaintiff in violent and invasive ways.
+
+67. These demands, often made when Epstein and Plaintiff were alone, were intended to frighten Plaintiff into submitting to Epstein's sexual demands and placed Plaintiff in apprehension of harm.
+
+68. This conduct caused Plaintiff serious and persistent harm and contributed to injuries that Plaintiff continues to suffer.
+
+69. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+70. As a direct and proximate result of Jeffrey Epstein's violations of New York Penal Law § 130, Plaintiff has in the past suffered and in the future will continue to suffer physical injury, pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and a loss of her capacity to enjoy life, as well as other damages. Plaintiff incurred medical and psychological expenses and Plaintiff will in the future suffer additional medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. Epstein for compensatory and general damages, and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
+
+### COUNT THREE INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
+
+71. Plaintiff incorporates by reference paragraphs 1-58 and re-alleges them as if set forth fully herein.
+
+72. Epstein's years long sexual abuse against a teenaged Plaintiff was extreme and outrageous conduct that shocks the conscience.
+
+73. Epstein's serial sexual assaults, committed during the course of a methodical plan of recruitment, enticement, and attack, inflicted severe pain and anguish upon Plaintiff.
+
+74. Epstein directed this conduct at Plaintiff and knew that it would cause severe and lasting emotional distress. Indeed, the conduct caused Plaintiff severe and lasting emotional distress and serious injuries to her mental health.
+
+75. Epstein's direction of his girlfriend to engage in unwanted oral sexual contact with Plaintiff was done with knowledge that it would cause severe and lasting emotional distress.
+
+76. Epstein's enticement and encouragement for Plaintiff to recruit other minor females for Jeffrey Epstein to sexually assault was done with knowledge it would cause severe and lasting emotional distress.
+
+77. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+78. As a direct and proximate result of Jeffrey Epstein's violations of New York Penal Law § 130, Plaintiff has in the past suffered and in the future will continue to suffer physical injury, pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and a loss of her capacity to enjoy life, as well as other damages. Plaintiff incurred medical and psychological expenses and Plaintiff will in the future suffer additional medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. Epstein for compensatory and general damages, and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
+
+### COUNT FOUR NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
+
+79. Plaintiff incorporates by reference paragraphs 1-58 and re-alleges them as if set forth fully herein.
+
+80. Epstein invited Plaintiff, then a teenaged girl, into his home for years. Once under his supervision, Epstein proceeded methodically to sexually abuse Plaintiff
+
+81. Epstein's conduct was extreme and outrageous, breached a duty owed directly to plaintiff, endangered her physical safety, and caused severe and lasting emotional distress and serious injuries to Plaintiff's mental health.
+
+82. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+83. As a direct and proximate result of Jeffrey Epstein's violations of New York Penal Law § 130, Plaintiff has in the past suffered and in the future will continue to suffer physical injury, pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and a loss of her capacity to enjoy life, as well as other damages. Plaintiff incurred medical and psychological expenses and Plaintiff will in the future suffer additional medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future.
+
+WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. Epstein for compensatory and general damages, and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
+
+Dated: December 27, 2019
+
+Respectfully Submitted,
+
+POTTINGER, LLC
+
+By: J. NY Bar No.: 5749684 Brittany N. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954)-524-2820 Fax: (954)-524-2822 Email: ecf@eplk.com brad®eplIc.com brittany®eplIc.com (Seeking Admission Pro Hac Vice)

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751711/EFTA02751711.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751711",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "f00a44b0a134d1f10aa0fbfe559edcdcf545a07f5356b80c2250e1448636760e",
+  "output_sha256": "f00a44b0a134d1f10aa0fbfe559edcdcf545a07f5356b80c2250e1448636760e",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751725/EFTA02751725.md

@@ -0,0 +1,101 @@
+The JS•44 civil cover shoot and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This tam. approved by the Judicial Conference of the United States in September 1974, is required for use of the Clerk of Court for the purpose of initiating the civil docket sheet.
+
+PLAINTIFFS Anastasia Doe
+
+DEFENDANTS Darren K. Indyke and Richard D. Kahn
+
+allEYS (FIRM NAME. ADDRESS. AND TELEPHONE NUMBER ATTORNEYS (IF KNOWN) Pottinger LLC 425 North Andrews, Ave., Suite 2, Fort Lauderdale, FL 33301 954.524.2820
+
+CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE) (00 NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
+
+28 U.S.C. section 1332
+
+Has this action, case, or proceeding, or one essentially the same been previously filed in SONY at any time? No aYesO Judge Previously Assigned
+
+If yes. was this case Vol. O Invol. O Dismissed. No O Yes O If yes, give date 8 Case No.
+
+IS THIS AN INTIMIAITONAL AMUIRATON user No E Yea O
+
+(PLACE AN lx) IN ONE BOX ONLY)
+
+| TORTS |  | PERSONAL INJURY |  | PERSONAL INJURY |  | FORFEITURE/PENALTY |  | BANKRUPTCY |  | OTHER STATUTES |  |
+| ---------- | -- | ----------------------------------------------------- | -- | ---------------------------------------------------- | -- | ---------------------------------------------------- | -- | --------------------------------------------- | -- | -------------------------------------------------------------------------- | -- |
+| CONTRACT |  | PERSONAL INJURY |  | PERSONAL INJURY |  | FORFEITURE/PENALTY |  | BANKRUPTCY |  | OTHER STATUTES |  |
+| [ ] 110 |  | INSURANCE |  | [ ] 367 HEALTHCARE/ |  | [ ] 625 DRUG RELATED |  | [ ] 422 APPEAL |  | [ ] 375 FALSE CLAIMS |  |
+| [ ] 120 |  | MARINE |  | [ ] 315 AIRPLANE PERSONAL INJURY/PRODUCT LIABILITY |  | [ ] 625 DRUG RELATED SEIZURE OF PROPERTY |  | 28 USC 158 |  | [ ] 376 QUI TAM |  |
+| [ ] 130 |  | ACT |  | [ ] 365 PERSONAL INJURY PRODUCT LIABILITY |  | [ ] 423 WITHDRAWAL |  | [ ] 423 WITHDRAWAL |  | [ ] 400 STATE REAPPORTIONMENT |  |
+| [ ] 140 |  | NEGOTIABLE INSTRUMENT |  | [ ] 320 ASSAULT, LIBEL & SLANDER |  | [ ] 690 OTHER |  | 28 USC 157 |  | [ ] 410 ANTITRUST |  |
+| [ ] 150 |  | RECOVERY OF OVERPAYMENT & ENFORCEMENT |  | [ ] 330 FEDERAL EMPLOYERS' LIABILITY |  | [ ] 368 ASBESTOS PERSONAL INJURY PRODUCT LIABILITY |  | [ ] 830 COPYRIGHTS |  | [ ] 430 BANKS & BANKING |  |
+| [ ] 151 |  | OF JUDGMENT |  | [ ] 340 MARINE |  | [ ] 680 OTHER |  | [ ] 830 PATENT |  | [ ] 450 COMMERCE |  |
+| [ ] 152 |  | MEDICARE ACT |  | [ ] 345 MARINE PRODUCT LIABILITY |  | [ ] 830 PATENT |  | [ ] 835 PATENT-ABBREVIATED |  | [ ] 470 RACKETEER INFLU-ENCED & CORRUPT ORGANIZATION ACT (RICO) |  |
+| [ ] 152 |  | RECOVERY OF DEFAULTED STUDENT LOANS (EXCL VETERANS) |  | [ ] 350 MOTOR VEHICLE |  | [ ] 371 TRUTH IN LENDING |  | [ ] 840 TRADEMARK |  | [ ] 480 CONSUMER CREDIT (RICO) |  |
+| [ ] 153 |  | STUDENT LOANS (EXCL VETERANS) |  | [ ] 355 MOTOR VEHICLE PRODUCT LIABILITY |  | [ ] 850 PATENT-ABBREVIATED |  | [ ] 490 CABLE/SATELLITE TV |  | [ ] 480 CONSUMER CREDIT |  |
+| [ ] 153 |  | RECOVERY OF OVERPAYMENT |  | [ ] 360 OTHER PERSONAL INJURY |  | [ ] 380 OTHER PERSONAL PROPERTY DAMAGE |  | [ ] 861 HIA (1395ff) |  | [ ] 850 SECURITIES/COMMODITIES/EXCHANGE |  |
+| [ ] 160 |  | STOCKHOLDERS SUITS |  | [ ] 362 PERSONAL INJURY - MED MALPRACTICE |  | [ ] 385 PROPERTY DAMAGE PRODUCT LIABILITY |  | [ ] 720 LABOR/MGMT RELATIONS |  | [ ] 865 RSI (405(g)) |  |
+| [ ] 160 |  | STOCKHOLDERS SUITS |  | [ ] 380 OTHER PERSONAL PROPERTY DAMAGE |  | [ ] 710 FAIR LABOR STANDARDS ACT |  | [ ] 865 RSI (405(g)) |  | [ ] 890 OTHER STATUTORY ACTIONS |  |
+| [ ] 190 |  | OTHER CONTRACT |  | [ ] 510 MOTIONS TO VACATE SENTENCE |  | [ ] 750 RAILWAY LABOR ACT |  | [ ] 870 TAXES (U.S. Plaintiff or Defendant) |  | [ ] 891 AGRICULTURAL ACTS |  |
+| [ ] 195 |  | CONTRACT PRODUCT LIABILITY |  | [ ] 463 ALIEN DETAINEE |  | [ ] 751 FAMILY MEDICAL LEAVE ACT (FMLA) |  | [ ] 871 IRS-THIRD PARTY |  | [ ] 893 ENVIRONMENTAL MATTERS |  |
+| [ ] 196 |  | FRANCHISE |  | [ ] 540 MANDAMUS & OTHER |  | [ ] 791 EMPL RET INC SECURITY ACT (ERISA) |  | [ ] 870 TAXES (U.S. Plaintiff or Defendant) |  | [ ] 895 FREEDOM OF INFORMATION ACT |  |
+| [ ] 210 |  | LAND CONDEMNATION |  | [ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner) |  | [ ] 550 CIVIL RIGHTS |  | [ ] 870 TAXES (U.S. Plaintiff or Defendant) |  | [ ] 896 ARBITRATION |  |
+| [ ] 210 |  | LAND CONDEMNATION |  | [ ] 442 EMPLOYMENT |  | [ ] 462 NATURALIZATION |  | [ ] 871 IRS-THIRD PARTY |  | [ ] 899 ADMINISTRATIVE PROCEDURE ACT/REVIEW OR APPEAL OF AGENCY DECISION |  |
+| [ ] 220 |  | FORECLOSURE |  | [ ] 443 HOUSING/ACCOMMODATIONS |  | [ ] 550 CIVIL RIGHTS |  | [ ] 465 OTHER IMMIGRATION ACTIONS |  | [ ] 950 CONSTITUTIONALITY OF STATE STATUTES |  |
+| [ ] 230 |  | RENT LEASE & EJECTMENT |  | [ ] 445 AMERICANS WITH DISABILITIES - EMPLOYMENT |  | [ ] 550 CIVIL RIGHTS |  | [ ] 465 OTHER IMMIGRATION ACTIONS |  | [ ] 950 CONSTITUTIONALITY OF STATE STATUTES |  |
+| [ ] 240 |  | TORTS TO LAND |  | [ ] 446 AMERICANS WITH DISABILITIES -OTHER |  | [ ] 560 CIVIL DETAINEE |  | [ ] 460 OTHER IMMIGRATION ACTIONS |  | [ ] 950 CONSTITUTIONALITY OF STATE STATUTES |  |
+| [ ] 245 |  | TORT PRODUCT LIABILITY |  | [ ] 446 AMERICANS WITH DISA |  |  |  |  |  |  |  |
+
+REAL PROPERTY
+
+NATURE OF SUIT
+
+Check if demanded in complaint:
+
+❑ CHECK IF THIS IS ACLASS ACTION UNDER F.R.C.P. 23
+
+DEMAND \$ OTHER JUDGE DOCKET NUMBER
+
+DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y. AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 137 IF SO, STATE:
+
+ **1** Original Proceeding  **2** Removed from State Court  **3** Remanded from Appellate Court  **4** Reinstated or Reopened  **5** Transferred from (Specify District)  **6** Multidistrict Litigation (Transferred)  **7** Appeal to District Judge from Magistrate Judge
+
+ **a. all parties represented**  **b. At least one party is pro se.**  **8** Multidistrict Litigation (Direct File)
+
+(PLACE AN *x* IN ONE BOX ONLY) **BASIS OF JURISDICTION** *IF DIVERSITY, INDICATE CITIZENSHIP BELOW.*  
+ 1 U.S. PLAINTIFF  2 U.S. DEFENDANT  3 FEDERAL QUESTION  4 DIVERSITY  
+ (U.S. NOT A PARTY)
+
+## CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)
+
+(Place an (XJ in one box for Plaintiff and one box for Defendant)
+
+|  | PTF | DEF |  | PTF DEF |  | PTF | DEF |
+| -------------------------- | ------- | ------- | --------------------------------- | ----------- | --------------------------------------------------------------- | ------ | ------ |
+| CITIZEN OF THIS STATE | (id I | ( J I | CITIZEN OR SUBJECT OF A | I 13( (3 |  |  |  |
+| CITIZEN OF ANOTHER STATE | )2 | (34 2 | INCORPORATED or PRINCIPAL PLACE | I ) 4 ( 4 |  |  |  |
+|  |  |  | FOREIGN COUNTRY |  | INCORPORATED and PRINCIPAL PLACE OF BUSINESS IN ANOTHER STATE | 1 15 | I 5 |
+|  |  |  | OF BUSINESS IN THIS STATE |  | FOREIGN NATION | ( )6 | ( IN |
+
+PLASIDRESS(ES) AND COUNTY(IES)
+
+do Pottinger, LLC, 425 North Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301
+
+DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)
+
+Darren K. Indyke and Richard D. Kahn, as Co-Executors Of The Estate Of Jeffrey E. Epstein, do Darren K. Indyke, Esq. 575 Lexington Ave., 4th FI, New York, NY 10022
+
+DEFENDANT(S) ADDRESS UNKNOWN
+
+REPRESENTATION IS HEREBY MADE THAT. AT THIS TIME. I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
+
+## COURTHOUSE ASSIGNMENT
+
+I hereby certify that this case should be assigned to the courthouse indicated below pursuant to Local Rule for Division of Business 18.20 or 21.
+
+Check one: THIS ACTION SHOULD BE ASSIGNED TO: O PLAINS g MANHATTAN
+
+DATE 12/27/2019 SIGNATU /s ATTOR RECORD ADMITTED TO PRACTICE IN THIS DISTRICT RE OF NEY OF bd NO
+
+f I YES (DATE ADMITTED Mo. Yr. RECEIPT Si Attorney Bar Code N
+
+Magistrate Judge is to be designated by the Clerk of the Court.
+
+Magistrate Judge is so Designated.

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751725/EFTA02751725.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -3657,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751725",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 299,
+  "fix_ids": "[\"builtin.table-boundary-padding\", \"epstein_legal.flight-log-tables.normalize\"]",
+  "idempotent": true,
+  "input_sha256": "803029905545832e063fa02e2a0b421894e02380fe44307c9a8d8c4c29422854",
+  "output_sha256": "abcf7db991cd1a30480410d2d506c41c3e93de88ffd26a5e2e3b769f4201a6a2",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751727/EFTA02751727.md

@@ -0,0 +1,112 @@
+**UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF NEW YORK**
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+vs.
+
+DARREN K. INDYKE AND RICHARD D.  
+KAHAN, AS CO-EXECUTORS OF THE ESTATE  
+OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+Case No. 1:19-cv-11869
+
+**AFFIRMATION OF [REDACTED] J.  
+[REDACTED] IN SUPPORT OF  
+APPLICATION FOR ADMISSION  
+PRO HAC VICE**
+
+I, [REDACTED] J. [REDACTED] hereby declare as follows:
+
+1. 1. I have never been convicted of a felony.
+2. 2. I have never been censured, suspended, disbarred or denied admission or readmission by any court.
+3. 3. There are no pending disciplinary proceedings against me in any state or federal court.
+4. 4. I am a member in good standing of the bar of the State of Florida.
+5. 5. I am a member in good standing of the bar of District of Columbia.
+6. 6. I am a member in good standing of the bar of the State of New York.
+
+I hereby declare under penalty of perjury that the foregoing statements are true and correct.
+
+Dated: December 27, 2019  
+Fort Lauderdale, Florida
+
+Respectfully submitted,  
+[REDACTED] POTTINGER, LLC
+
+By:
+
+
+
+## Lipton Court ofitortba Certificate of (Snob iptaithing
+
+I JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that
+
+JAMES
+
+was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida on March 8, 2002, is presently in good standing, and that the private and professional character of the attorney appear to be good.
+
+![](_page_1_Picture_6.jpeg)
+
+WITNESS my hand and the Seal of the Supreme Court of Florida at Tallahassee, the Capital, this August 15, 2019.
+
+Clerk of the Supreme Court of Florida
+
+![](_page_2_Picture_95.jpeg)
+
+# The Florida Bar
+
+651 East Jefferson Street  
+Tallahassee, FL 32399-2300
+
+Joshua E. [REDACTED]  
+Executive Director
+
+850/561-5600  
+www.FLORIDABAR.org
+
+State of Florida )
+
+County of [REDACTED] )
+
+In Re: 0542075  
+[REDACTED] James [REDACTED]  
+[REDACTED] Pottinger LLC  
+425 N Andrews Ave Ste 2  
+Ft Lauderdale, FL 33301-3268
+
+I CERTIFY THE FOLLOWING:
+
+I am the custodian of membership records of The Florida Bar.
+
+Membership records of The Florida Bar indicate that The Florida Bar member listed above was admitted to practice law in the state of Florida on **March 8, 2002**.
+
+The Florida Bar member above is an active member in good standing of The Florida Bar who is eligible to practice law in the state of Florida.
+
+Dated this 27th day of **December, 2019**.
+
+Cynthia B. [REDACTED], CFO  
+Administration Division  
+The Florida Bar
+
+PG:R10  
+CTM-67839
+
+![](_page_2_Picture_111.jpeg)
+
+![](_page_3_Picture_1.jpeg)
+
+![](_page_3_Picture_2.jpeg)
+
+On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals, the District of Columbia Bar does hereby certify that
+
+a sraite4, Weanaz
+
+was duly qualified and admitted on June 5, 2017 as an attorney and counselor entitled to practice before this Court; and is, on the date indicated below, an Active member in good standing of this Bar.
+
+![](_page_3_Picture_6.jpeg)
+
+Issued By: District of Columbia Bar Membership

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751727/EFTA02751727.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -10,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751727",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 2,
+  "fix_ids": "[\"builtin.empty-image\"]",
+  "idempotent": true,
+  "input_sha256": "9a8c8961700f0a6d0e275d1ec967dce550855c9a386dc9cb6ac76ae0a3042f83",
+  "output_sha256": "bd910d39f6b81f9b428f8bdbe53e60704b60a7a1f69876b85b03a3e4d1ded8fd",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751731/EFTA02751731.md

@@ -0,0 +1,37 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+Case No. 1:19-cv-11869
+
+vs.
+
+DARREN K. INDYKE AND RICHARD D. KAHAN, AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+## ORDER FOR ADMISSION PRO HAC VICE
+
+The motion of J. to appear Pro Hac Vice in the above-captioned action is granted.
+
+Applicant has declared that he is a member in good standing of the bar of the State of Florida; and that his contact information is as follows:
+
+Applicant Name: J
+
+Firm Name:
+
+Address: 425 North Andrews Avenue Suite 2
+
+City / State / Zip: Fort Lauderdale. Florida 33301
+
+Telephone / Fax: (954) 524-2820/ (954) 524-2822
+
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff ANASTASIA DOE in the above entitled action;
+
+IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules Governing discipline of attorneys.
+
+Dated:
+
+United States District/Magistrate Judge

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751731/EFTA02751731.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751731",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "490658dafc90d9c5a8b86a3ed605219baead11d8f09f8d0d1d56fea9948c54e9",
+  "output_sha256": "490658dafc90d9c5a8b86a3ed605219baead11d8f09f8d0d1d56fea9948c54e9",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751732/EFTA02751732.md

@@ -0,0 +1,25 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+Case No. 1:19-cv-11869
+
+vs.
+
+DARREN K. INDYKE AND RICHARD D. KAHAN, AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+MOTION FOR ADMISSION PRO HAC VICE
+
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, J. hereby moves this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Plaintiff ANASTASIA DOE in the above-captioned action.
+
+I am in good standing of the bar of the State of Florida and the State of New York and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3
+
+Dated: December 27, 2019 Fort Lauderdale, Florida
+
+Res tfull submitted, POTTINGER, LLC
+
+By: ifinr J. NY Bar No.: 5749684 Brittany N. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954)-524-2820 Fax: (954)-524-2822 Email: ecf@epllc.com brad®eplIc.com brittany®eplIc.com (Seeking Admission Pro Hac Vice)

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751732/EFTA02751732.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751732",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "516022518751bef206ace6da9dffbd1700d8e20434b176ccf06577220b735079",
+  "output_sha256": "516022518751bef206ace6da9dffbd1700d8e20434b176ccf06577220b735079",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751733/EFTA02751733.md

@@ -0,0 +1,104 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+Case No. 1:19-cv-11869
+
+vs.
+
+DARREN K. INDYKE AND RICHARD D. KAHAN, AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+I, M. hereby declare as follows:
+
+AFFIRMATION OF SUPPIPI NI FOR ADMISSION PRO HAC VICE
+
+- 1. I have never been convicted of a felony.
+- 2. I have never been censured, suspended, disbarred or denied admission or readmission by any court.
+- 3. There are no pending disciplinary proceedings against me in any state or federal court.
+- 4. I am a member in good standing of the bar of the State of Florida.
+- 5. I am a member in good standing of the bar of District of Columbia.
+- 6. I am a member in good standing of the bar of the State of New York.
+
+I hereby declare under penalty of perjury that the foregoing statements are true and correct.
+
+Dated: December 27, 2019
+
+Fort Lauderdale, Florida Re ctfull submitted, POTTINGER, LLC
+
+By:
+
+NY Bar NME 84 Bradley J. 425 N. Andrell. Suite 2 Brittany N. Fort Lauderdale, FL 33301 (954)-524-2820 Fax: (954)-524-2822 Email: ecf®eplle.com brad@epllc.com brittany®epllc.com (Seeking Admission Pro Hac Vice)
+
+# Supreme Court of Florida Certificate of Good Standing
+
+***I JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that***
+
+**[REDACTED] JAMES [REDACTED]**
+
+***was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida* [REDACTED] March 8, 2002, is presently in good standing, and that the private and professional character of the attorney appear to be good.**
+
+***WITNESS my hand and the Seal of the Supreme Court of Florida at Tallahassee, the Capital, this December 31, 2019.***
+
+![](_page_1_Picture_60.jpeg)
+
+*Clerk of the Supreme Court of Florida.*
+
+![](_page_2_Picture_104.jpeg)
+
+# The Florida Bar
+
+651 East Jefferson Street  
+Tallahassee, FL 32399-2300
+
+Joshua E. [REDACTED]  
+Executive Director
+
+850/561-5600  
+www.FLORIDABAR.org
+
+State of Florida )
+
+County of [REDACTED] )
+
+In Re: 0542075  
+[REDACTED] James [REDACTED]  
+[REDACTED] Pottinger LLC  
+425 N Andrews Ave Ste 2  
+Ft Lauderdale, FL 33301-3268
+
+I CERTIFY THE FOLLOWING:
+
+I am the custodian of membership records of The Florida Bar.
+
+Membership records of The Florida Bar indicate that The Florida Bar member listed above was admitted to practice law in the state of Florida on **March 8, 2002**.
+
+The Florida Bar member above is an active member in good standing of The Florida Bar who is eligible to practice law in the state of Florida.
+
+Dated this 27th day of **December, 2019**.
+
+Cynthia B. [REDACTED], CFO  
+Administration Division  
+The Florida Bar
+
+PG:R10  
+CTM-67839
+
+![](_page_2_Picture_120.jpeg)
+
+![](_page_3_Picture_1.jpeg)
+
+![](_page_3_Picture_2.jpeg)
+
+On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals, the District of Columbia Bar does hereby certify that
+
+a "mat edte As • a
+
+was duly qualified and admitted on June 5, 2017 as an attorney and counselor entitled to practice before this Court; and is, on the date indicated below, an Active member in good standing of this Bar.
+
+![](_page_3_Picture_6.jpeg)
+
+Issued By: District of Columbia Bar Membership

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751733/EFTA02751733.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -10,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751733",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 2,
+  "fix_ids": "[\"builtin.empty-image\"]",
+  "idempotent": true,
+  "input_sha256": "91f2eec33bdc37ecbf30ca9f140ac7587fa9f52269163ce9709a850f0b98e7be",
+  "output_sha256": "6c11603e50da676c6ff1d3a078eb9247bb9ac2f4c293b674a64d5a503ce39f08",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751737/EFTA02751737.md

@@ -0,0 +1,37 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+Case No. 1:19-cv-11869
+
+vs.
+
+DARREN K. INDYKE AND RICHARD D. KAHAN, AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+ORDER FOR ADMISSION PRO HAC VICE
+
+The motion of J. to appear Pro Hac Vice in the above-captioned action is granted.
+
+Applicant has declared that he is a member in good standing of the bar of the State of Florida; and that his contact information is as follows:
+
+Applicant Name: J
+
+Firm Name: Pottir LC
+
+Address: 425 North Andrews Avenue Suite 2
+
+City / State / Zip: Fort Lauderdale. Florida 33301
+
+Telephone / Fax: (954) 524-2820/ (954) 524-2822
+
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff ANASTASIA DOE in the above entitled action;
+
+IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules Governing discipline of attorneys.
+
+Dated:
+
+United States District/Magistrate Judge

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751737/EFTA02751737.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751737",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "7692229b4673d5b73713d7eb81c732029be0302ba264b07e0513f37ac5a95fc1",
+  "output_sha256": "7692229b4673d5b73713d7eb81c732029be0302ba264b07e0513f37ac5a95fc1",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751738/EFTA02751738.md

@@ -0,0 +1,25 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+Case No. 1:19-cv-11869
+
+vs.
+
+DARREN K. INDYKE AND RICHARD D. KAHAN, AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+MOTION FOR ADMISSION PRO HAC VICE
+
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, J. hereby moves this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Plaintiff ANASTASIA DOE in the above-captioned action.
+
+I am in good standing of the bar of the State of Florida and the State of New York and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3
+
+Dated: December 27, 2019 Fort Lauderdale, Florida
+
+Res tfull submitted, POTTINGER, LLC
+
+By: ifinr J. NY Bar No.: 5749684 Brittany N. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954)-524-2820 Fax: (954)-524-2822 Email: ecf@epllc.com brad@eplIc.com brittany®eplIc.com (Seeking Admission Pro Hac Vice)

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751738/EFTA02751738.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751738",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "c189856c185f3ac8d6aa1627f39567217060018726f1552c059c2a4488358467",
+  "output_sha256": "c189856c185f3ac8d6aa1627f39567217060018726f1552c059c2a4488358467",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751739/EFTA02751739.md

@@ -0,0 +1,23 @@
+Bennet J. Moskowitz
+
+bennetmoskowitz@troutman.com
+
+January 7, 2020
+
+ECF
+
+Hon. Alison J. Nathan Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007
+
+Re: Anastasia Doe v. Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein, 1:19-cv-11869-Aal
+
+Dear Judge Nathan:
+
+We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, "Defendants") in the referenced action. We write to respectfully request the Court's approval of the parties' agreement described below.
+
+On December 30, 2019, subject to the Court's approval: (1) we agreed to accept service of Plaintiff's Complaint (ECF #1) on Defendants' behalf; and (2) Plaintiff consented to Defendants having through February 17, 2020 to answer, move or otherwise respond to Plaintiff's Complaint. There have been no previous requests for adjournments or extensions of time in this action.
+
+Respectfully submitted,
+
+/s/Bennet J. Moskowitz
+
+Bennet J. Moskowitz

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751739/EFTA02751739.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751739",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "a868f8d6dedd93bf9252b7fbca7c5bc085c4a698e151090b5096ec5936162f51",
+  "output_sha256": "a868f8d6dedd93bf9252b7fbca7c5bc085c4a698e151090b5096ec5936162f51",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751740/EFTA02751740.md

@@ -0,0 +1,45 @@
+Troutman Sanders LLP  
+875 Third Avenue  
+New York, New York 10022
+
+troutman.com
+
+![](_page_0_Picture_142.jpeg)
+
+**Bennet J. Moskowitz**  
+bennet.moskowitz@troutman.com
+
+January 7, 2020
+
+**ECF**
+
+Hon. Alison J. Nathan  
+Thurgood Marshall  
+United States Courthouse  
+40 Foley Square  
+New York, NY 10007
+
+![](_page_0_Picture_147.jpeg)
+
+**Re: Anastasia Doe v. Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein, 1:19-cv-11869-AJN**
+
+Dear Judge Nathan:
+
+We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, "Defendants") in the referenced action. We write to respectfully request the Court's approval of the parties' agreement described below.
+
+On December 30, 2019, subject to the Court's approval: (1) we agreed to accept service of Plaintiff's Complaint (ECF #1) on Defendants' behalf; and (2) Plaintiff consented to Defendants having through February 17, 2020 to answer, move or otherwise respond to Plaintiff's Complaint. There have been no previous requests for adjournments or extensions of time in this action.
+
+**SO  
+GROUP RED**
+
+Respectfully submitted,
+
+/s/ Bennet J. Moskowitz  
+Bennet J. Moskowitz
+
+**SO ORDERED:**
+
+*[Handwritten signature]*  
+1/8/20  
+HON. ALISON NATHAN  
+UNITED STATES DISTRICT JUDGE

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751740/EFTA02751740.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751740",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "84455ec8aea87bf59711d1661b674fe069909f8e1ae5873e25d7cba742939334",
+  "output_sha256": "84455ec8aea87bf59711d1661b674fe069909f8e1ae5873e25d7cba742939334",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751741/EFTA02751741.md

@@ -0,0 +1,25 @@
+UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF NEW YORK
+
+Plaintiff, Anastasia Doe  
+-v-  
+Defendant. Darren █ Indyke and Richard D. Kahn
+
+ORDER OF REFERENCE  
+TO A MAGISTRATE JUDGE
+
+![](_page_0_Picture_148.jpeg)
+
+The above entitled action is referred to the designated Magistrate Judge for the following purpose(s):
+
+| <input checked="" type="checkbox"/> General Pretrial (includes scheduling, discovery, non-dispositive pretrial motions, and settlement) | <input type="checkbox"/> Consent under 28 U.S.C. §636(c) for all purposes (including trial) |
+| ----------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------- |
+| <input type="checkbox"/> Specific Non-Dispositive Motion/Dispute:*<br>_____<br>_____<br>_____ | <input type="checkbox"/> Consent under 28 U.S.C. §636(c) for limited purpose (e.g., dispositive motion, preliminary injunction)<br>Purpose: _____ |
+| <input type="checkbox"/> Settlement*<br>_____ | <input type="checkbox"/> Habeas Corpus |
+| <input type="checkbox"/> Inquest After Default/Damages Hearing | <input type="checkbox"/> Social Security<br>Dispositive Motion (i.e., motion requiring a Report and Recommendation)<br>Particular Motion: _____ |
+
+\*Do not check if already referred for general pretrial.
+
+Dated 11/8/20
+
+United States District Judge

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751741/EFTA02751741.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -369,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751741",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 8,
+  "fix_ids": "[\"builtin.empty-image\", \"builtin.table-boundary-padding\", \"epstein_legal.flight-log-tables.normalize\"]",
+  "idempotent": true,
+  "input_sha256": "6c6bcc8ee50035597453ee0f8d7cc4f8697540801d30a62a89bc3c9e981ea6b0",
+  "output_sha256": "c787ee7139be686edca9228fa80ea3af21e0c65cac587ccb2e5116a129793736",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751742/EFTA02751742.md

@@ -0,0 +1,35 @@
+![](_page_0_Picture_1.jpeg)
+
+![](_page_0_Picture_3.jpeg)
+
+Florida Office
+
+J. "Os Seth M. Lehrman tt Brittany N. Matthew D. Weissing
+
+## FILED VIA ECF
+
+Magistrate Judge Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl St., New York, NY 10007 POTTINGER LLC\_\_
+
+425 North Andrews Avenue Suite 2 Fon Lauderdale, FL 33301
+
+Telephone (954)524-2820 Fax (954)524-2822
+
+January 10, 2020
+
+Re: VE v. Nine East 71815treet et al., No. 19-cv-07625 (S.D.N.Y.) (Nathan, J.) Katlyn Doe v. Darren K Indyke et al., No. 19-cv-07771 (S.D.N.Y.) (Castel, J.) Pricilla Doe v. Darren K. Indyke et aL., No. 19-cv-07772 (S.D.N.Y.) (Carter, J.) Lisa Doe v. Darren K. Indyke et aL, No. 19-cv-07773 (S.D.N.Y.) (Ramos, J.) Anastasia Doe v. Darren K. Indyke, et at, No. 19-cv-11869 (S.D.N.Y.) (Nathan, J.)
+
+Dear Judge Freeman:
+
+New York Office J. Stanley Pottinger
+
+Admitted in California 0 Admitted in Dome of Columbia • Admitted in Clinida 4 Admitted in New Vork Board Cvnifird Cavil Trial layer
+
+We represent the five Plaintiffs referenced above whose cases have all been assigned to Your Honor. While we agree with Defendants' assertion that our discussions with the designers and administrator of the Epstein Victims' Compensation Program have been positive and productive, in our view, it remains important to every aspect of the process that our cases are not stayed and that they proceed accordingly.
+
+As we explained during the Case Management Conference that was held on November 21, 2019, our clients have varying views of the process, and while each will maintain an open mind about potential alternative resolution, those who have filed lawsuits do not wish to delay the expeditious litigation of their claims.
+
+We have and will continue to work with Mr. Moskowitz to ensure that we arrive at as many agreements as possible. Consequently, we agree with the following discovery schedule as proposed in his report: Plaintiffs and the Estate will make initial disclosures by January 23, 2020; the Parties will exchange proposed discovery plans by January 30, 2020; and the Parties will jointly submit to Your Honor a proposed discovery plan by February 6, 2020.
+
+Respectfully Submitted,
+
+J.

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751742/EFTA02751742.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751742",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "f3ef063b90b063bb1a18ddc2eaf58b20096f2c7c4dbb2aeec4f76ff19f6f5674",
+  "output_sha256": "f3ef063b90b063bb1a18ddc2eaf58b20096f2c7c4dbb2aeec4f76ff19f6f5674",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751743/EFTA02751743.md

@@ -0,0 +1,21 @@
+Bennet J. Moskowitz bennet.moskowitz@troutman.com
+
+January 10, 2020
+
+ECF
+
+Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007
+
+Re: VE, 1:19-cv-07625-AJN-DCF; Katlyn Doe, 1:19-cv-07771-PKC-DCF; Priscilla Doe, 1:19-cv-07772-ALC-DCF; Lisa Doe, 1:19-cv-07773-ER-DCF; Anastasia Doe, 1:19-cv-11869-AJN-DCF
+
+Dear Judge Freeman:
+
+We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), Nine East 71st Street, Corporation, Financial Trust Company, Inc., NES, LLC, Florida Science Foundation, Inc., HBRK Associates, Inc., JEGE, Inc., Maple, Inc., and LSJ, LLC (together, "Defendants"; and Defendants together with Plaintiffs VE, Katlyn Doe, Priscilla Doe, Lisa Doe and Anastasia Doe, the "Parties") in the referenced actions, as applicable. We write on behalf of all Parties to report to the Court regarding settlement and to respectfully request that the Court approve the Parties' discovery proposal.
+
+We understand that the vast majority of the plaintiffs in the above referenced and other actions against the Estate pending in this District will or are very likely to participate in the Epstein Victims' Compensation Program (the "Program"), with five plaintiffs having already voluntarily stayed their actions pending their participation in the Program. Counsel for all such plaintiffs have conferred extensively with the Program designers and administrator, including in person, to, among other things, provide specific input on the draft Program protocol issued on December 13, 2019. We understand such discussions have been positive and productive.
+
+The Parties propose the following schedule for discovery: Plaintiffs and the Estate will make initial disclosures by January 23, 2020; the Parties will exchange proposed discovery plans by January 30, 2020; and the Parties will jointly submit to Your Honor a proposed discovery plan by February 6, 2020.
+
+Respectfully submitted,
+
+s/Bennet J. Moskowitz Bennet J. Moskowitz

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751743/EFTA02751743.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751743",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "fd0fa90eea800e6fad2bdb2bd4b734302512796b52e945c67c0df0835df2e196",
+  "output_sha256": "fd0fa90eea800e6fad2bdb2bd4b734302512796b52e945c67c0df0835df2e196",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751745/EFTA02751745.md

@@ -0,0 +1,102 @@
+**UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF NEW YORK**
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+vs.
+
+DARREN K. INDYKE AND RICHARD D.  
+KAHAN, AS CO-EXECUTORS OF THE ESTATE  
+OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+Case No. 1:19-CV-11869-AJN
+
+**AFFIRMATION OF BRITTANY N.  
+[REDACTED] IN SUPPORT OF  
+APPLICATION FOR ADMISSION  
+PRO HAC VICE**
+
+I, Brittany N. [REDACTED], hereby declare as follows:
+
+1. 1. I have never been convicted of a felony.
+2. 2. I have never been censured, suspended, disbarred or denied admission or readmission by any court.
+3. 3. There are no pending disciplinary proceedings against me in any state or federal court.
+4. 4. I am a member in good standing of the bar of the State of Florida.
+
+I hereby declare under penalty of perjury that the foregoing statements are true and correct.
+
+Dated: January 13 2020  
+Fort Lauderdale, Florida
+
+Respectfully submitted,  
+[REDACTED] POTTINGER, LLC
+
+Brittany N. Henderson  
+425 North Andrews Avenue, Suite 2  
+Fort Lauderdale, Florida 33301  
+Tel: (954) 524-2820  
+Fax: (954) 524-2822  
+Email: [brittany@epllc.com](mailto:brittany@epllc.com); [ecf@epllc.com](mailto:ecf@epllc.com)
+
+*Attorney for Plaintiff, ANASTASIA DOE*
+
+# Supreme Court of Florida Certificate of Good Standing
+
+***I JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that***
+
+**BRITTANY NICOLE HENDERSON**
+
+***was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida on September 21, 2015, is presently in good standing, and that the private and professional character of the attorney appear to be good.***
+
+***WITNESS my hand and the Seal of the Supreme Court of Florida at Tallahassee, the Capital, this December 31, 2019.***
+
+![](_page_1_Picture_161.jpeg)
+
+*Clerk of the Supreme Court of Florida.*
+
+![](_page_2_Picture_101.jpeg)
+
+# The Florida Bar
+
+651 East Jefferson Street  
+Tallahassee, FL 32399-2300
+
+Joshua E. [REDACTED]  
+Executive Director
+
+850/561-5600  
+www.FLORIDABAR.org
+
+State of Florida )
+
+County of [REDACTED] )
+
+In Re: 0118247
+
+Brittany Nicole [REDACTED]  
+[REDACTED] Pottinger LLC  
+425 N Andrews Ave Ste 2  
+Ft Lauderdale, FL 33301-3268
+
+**I CERTIFY THE FOLLOWING:**
+
+I am the custodian of membership records of The Florida Bar.
+
+Membership records of The Florida Bar indicate that The Florida Bar member listed above was admitted to practice law in the state of Florida on **September 21, 2015**.
+
+The Florida Bar member above is an active member in good standing of The Florida Bar who is eligible to practice law in the state of Florida.
+
+Dated this 10th day of **January, 2020**.
+
+Cynthia B. [REDACTED], CFO  
+Administration Division  
+The Florida Bar
+
+PG:R10  
+CTM-69088
+
+![](_page_2_Picture_118.jpeg)

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751745/EFTA02751745.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -75,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751745",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 6,
+  "fix_ids": "[\"builtin.empty-image\", \"epstein_legal.redaction-normalization.block-characters\"]",
+  "idempotent": true,
+  "input_sha256": "b2f4fd00b7f663cfdb07e2f44f8cdd74533d3020d564a56330473f89fc019e21",
+  "output_sha256": "a618407f241e7c03bba6f9c7904968e3dbef5c743e71f6a1bf4c42cee9278fdd",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751748/EFTA02751748.md

@@ -0,0 +1,37 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+Case No. 1:19-CV-11869-AJN
+
+vs.
+
+DARREN K. INDYKE AND RICHARD D. KAHAN, AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+## ORDER FOR ADMISSION PRO HAC VICE
+
+The motion of Brittany N. to appear Pro Hac Vice in the above-captioned action is granted.
+
+Applicant has declared that she is a member in good standing of the bar of the State of Florida; and that her contact information is as follows:
+
+Applicant Name: Brittany N.
+
+Firm Name: Pottinger LLC
+
+Address: 425 North Andrews Avenue, Suite 2
+
+City / State / Zip: Fort Lauderdale, Florida 33301
+
+Telephone / Fax: (954) 524-2820/ (954) 524-2822
+
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff ANASTASIA DOE in the above entitled action;
+
+IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hoc Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules Governing discipline of attorneys.
+
+Dated:
+
+United States District/Magistrate Judge

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751748/EFTA02751748.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751748",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "5a25fc748f0dbfbf6245b286be2c2b8f8c3dff7d1804aa9aee1fc42cae45ac9f",
+  "output_sha256": "5a25fc748f0dbfbf6245b286be2c2b8f8c3dff7d1804aa9aee1fc42cae45ac9f",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751749/EFTA02751749.md

@@ -0,0 +1,27 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+Case No. l :19-CV- I I 869-AJN
+
+vs.
+
+DARREN K. INDYKE AND RICHARD D. KAHAN, AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+## MOTION FOR ADMISSION PRO HAC VICE
+
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, Brittany N. hereby moves this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Plaintiff ANASTASIA DOE in the above-captioned action.
+
+I am in good standing of the bar of the State of Florida and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3
+
+Dated: January 13, 2020
+
+Fort Lauderdale, Florida Res tfull submitted, POTTINGER, LLC
+
+> /s/ Brittany N. Brittany N. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: ecf@eplIc.com brittany®eplIc.com
+
+Attorney for Plaintiff ANASTASIA DOE

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751749/EFTA02751749.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751749",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "f72adeabe0092c062e668e9628f7def0ba55caaf628444d1eaff0c6fde0b1e2e",
+  "output_sha256": "f72adeabe0092c062e668e9628f7def0ba55caaf628444d1eaff0c6fde0b1e2e",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751750/EFTA02751750.md

@@ -0,0 +1,51 @@
+UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF NEW YORK
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+vs.
+
+DARREN K. INDYKE AND RICHARD D.  
+KAHAN, AS CO-EXECUTORS OF THE ESTATE  
+OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+USDC SDNY  
+DOCUMENT  
+ELECTRONICALLY FILED  
+DOC #:  
+DATE FILED: 11/14/2020
+
+Case No. 1:19-CV-11869-AJN
+
+ORDER FOR ADMISSION  
+PRO HAC VICE
+
+The motion of Brittany N. [REDACTED] to appear *Pro Hac Vice* in the above-captioned action is granted.
+
+Applicant has declared that she is a member in good standing of the bar of the State of Florida; and that her contact information is as follows:
+
+Applicant Name: Brittany N. [REDACTED]
+
+Firm Name: [REDACTED] Pottinger LLC
+
+Address: 425 North Andrews Avenue, Suite 2
+
+City / State / Zip: Fort Lauderdale, Florida 33301
+
+Telephone / Fax: (954) 524-2820/ (954) 524-2822
+
+Applicant having requested admission *Pro Hac Vice* to appear for all purposes as counsel for Plaintiff **ANASTASIA DOE** in the above entitled action;
+
+**IT IS HEREBY ORDERED** that the Applicant is admitted to practice *Pro Hac Vice* in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules Governing discipline of attorneys.
+
+Dated: 11/14/2020
+
+*[Signature]*  
+United States District/Magistrate Judge  
+**DEBRA FREEMAN**  
+UNITED STATES MAGISTRATE JUDGE  
+SOUTHERN DISTRICT OF NEW YORK

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751750/EFTA02751750.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751750",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "2748d12bcd2dd485d9365da8d8c7ace8eea92437c9172f317c570213c3380317",
+  "output_sha256": "2748d12bcd2dd485d9365da8d8c7ace8eea92437c9172f317c570213c3380317",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751751/EFTA02751751.md

@@ -0,0 +1,55 @@
+The Clerk of Court of the Southern District of New York is directed to docket the within ORDER in each of the following actions:
+
+VE v. Nine East 71st Street et a1., No. 1:19-cv-07625 (AJN) (DF)
+
+Katlyn Doe v. Indyke et at, No. 1:19-cv-07771 (PKC) (DF)
+
+Priscilla Doe v. Indyke et al., No. 1:19-cv-07772 (ALC) (DF)
+
+Lisa Doe v. Indyke et al., No. 1:19-cv-07773 (ER) (DF)
+
+Jane Doe v. Indyke et al., No. 1:19-cv-08673 (KPF) (DF)
+
+v. Indyke et aL, No. 1:19-cv-10475 (LGS) (DF)
+
+v. Indyke et aL, No. 1:19-cv-10476 (PGG) (DF)
+
+v. Indyke et aL, No. 1:19-cv-10479 (ALC) (DF)
+
+Jane Doe 1000 v. Indyke et al., No. 1:19-cv-10577 (LGS) (DF)
+
+Jane Doe 15 v. Indyke et al., No. I :19-cv-10653 (PAE) (DF)
+
+Mary Doe v. Indyke et aL, No. 1:19-cv-I 0758 (PAE) (DF)
+
+v. Indyke et aL, No. 1:19-cv-10788 (GHW) (DF)
+
+Anastasia Doe v. Indyke et at, No. 1:19-cv-11869 (MN) (DF)
+
+![](_page_0_Picture_15.jpeg)
+
+## DEBRA FREEMAN, United States Magistrate Judge:
+
+The above-referenced cases — all brought by plaintiffs claiming that they were sexually abused by Jeffrey Epstein and seeking damages from his estate — have been neither consolidated for any purpose, nor designated as "related" by the Court. Nonetheless, these cases (together with certain other, similar cases, not listed above) have been referred to the undersigned for general pretrial supervision, so that discovery — and potentially settlement — may be coordinated as reasonable. While, at the parties' request, discovery in the other Jeffrey Epstein cases referred to this Court has been stayed pending a further report on the parties' settlement efforts, the parties to each of the above-referenced cases have requested, by submissions dated January 10, 2020, that this Court set a discovery schedule. This Court's having reviewed the parties' submissions, it is hereby ORDERED that:
+
+1. In each of the above-referenced cases in which the parties have not yet submitted a jointly proposed discovery plan pursuant to Rule 26(f) of the Federal Rules of Civil Procedure, the parties are directed to submit a proposed discovery schedule for this Court's review no later
+
+than February 6, 2020. This submission should address all of the matters set out in Rule 26(f)(3), and should specifically include proposed deadlines for:
+
+- a service of initial disclosures under Rule 26(a)(1);
+- b. service of initial document requests and interrogatories;
+- c. any motion for joinder of other parties or amendment of the pleadings;
+- d. completion of fact discovery; and
+- e. expert disclosures and the completion of expert discovery, if any.
+
+2. As to each of the above-referenced cases, this Court will hold a pretrial conference pursuant to Rule 16 of the Federal Rules of Civil Procedure on February 11, 2020, at 10:00 a.m., in Courtroom 17A at the United States Courthouse, 500 Pearl Street, New York, NY 10007. The parties should be aware, however, that the mere fact that this Court will be holding a single, joint case-management conference does not necessarily mean that this Court will set an identical discovery schedule in each case. At the conference, counsel should be prepared to address whether there are reasons why these cases should be treated differently for scheduling purposes.
+
+Dated: New York, New York January 14, 2019
+
+SO ORDERED
+
+Ahleet A9-7 DEBRA FREEMAN United States Magistrate Judge
+
+Copies to:
+
+All counsel in the above-referenced cases (via ECF)

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751751/EFTA02751751.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751751",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "df8c88adf840ac760d2f3cfb70b2c6c03a1a3e739db2b575cf829178e46826e4",
+  "output_sha256": "df8c88adf840ac760d2f3cfb70b2c6c03a1a3e739db2b575cf829178e46826e4",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751753/EFTA02751753.md

@@ -0,0 +1,23 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+v.
+
+DARREN K. INDYKE AND RICHARD D. KAHN CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+Case No. 1:19-cv-11869-MN
+
+## NON-DISCLOSURE AGREEMENT
+
+I, , acknowledge that I understand that the identity of the Plaintiff in this action is confidential. I agree that: (1) I will hold in confidence Plaintiff's identity; (2) I will use Plaintiff's identity only in connection with this litigation; and (3) I will take all due precautions to prevent the unauthorized or inadvertent disclosure of Plaintiff's identity.
+
+By acknowledging these obligations under this Non-Disclosure Agreement, I understand that I am submitting myself to the jurisdiction of the United States District Court for the Southern District of New York for the purpose of any issue or dispute arising hereunder, and that my willful violation of any term of the Non-Disclosure Agreement could subject me to punishment for contempt of court.
+
+Dated:
+
+[Signature]

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751753/EFTA02751753.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751753",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "7c52eca2dcb3f5013624cc3634ff37ea7d56315c8c8f28971c15c8d788225937",
+  "output_sha256": "7c52eca2dcb3f5013624cc3634ff37ea7d56315c8c8f28971c15c8d788225937",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751754/EFTA02751754.md

@@ -0,0 +1,72 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+ANASTASIA DOE,
+
+Plaintiff;
+
+v.
+
+DARREN K. INDYKE AND RICHARD D. KAHN CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+Case No. I :19-cv- I 1869-AJN
+
+## ORDER ON PLAINTIFF'S ANONYMITY
+
+IT IS HEREBY ORDERED that any person subject to this Order, including the parties to this action and their respective counsel of record, shall adhere to the following terms:
+
+- I. Within three (3) days of entry of this Order, Counsel of Record for Plaintiff shall disclose Plaintiff's identity to Counsel of Record for Defendants, in writing.
+- 2. Counsel of Record for Defendants may disclose Plaintiff's identity only to Defendants and any attorneys, paralegals, and clerical or other assistants working with or for Defendants on matters related to this action; and the recipients of such information shall not disclose it to any other persons.
+- 3. If Defendants wish to disclose Plaintiff's identity to any person not otherwise permitted to receive such information under this Order, Defendants are limited to doing so in connection with defending this action, and must require such person to first execute a non-disclosure agreement, in a form agreed to by the parties, that prevents such person from disclosing Plaintiff's identity to any other persons. Defendants must maintain a list of all such persons to whom Plaintiff's identity is disclosed and copies of the executed non-disclosure agreements, all of which are subject to in camera inspection.
+- 4. All portions of pleadings, motions or other papers filed with the Court that disclose Plaintiff's identity shall be filed under seal with the Clerk of the Court and kept under seal until further order of the Court. The parties shall use their best efforts to minimize such sealing. Any party filing a motion or any other papers with the Court under seal shall also publicly file a redacted copy of the same, via the Court's Electronic Case Filing system, that redacts the Plaintiff's identity and text that would reveal Plaintiff's identity.
+
+- 5. The parties may seek to modify or amend this Order at any time upon motion to the Court or by stipulation.
+
+SO ORDERED.
+
+Date: New York, New York Alison J. Nathan
+
+United States District Judge
+
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+v.
+
+DARREN K. INDYKE AND RICHARD D. KAHN CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+Case No. 1:19-cv-11869-AJN
+
+## JOINT STIPULATION FOR ORDER ON PLAINTIFF'S ANONYMITY
+
+Plaintiff, Anastasia Doe ("Plaintiff'), jointly with Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, through undersigned counsel for Plaintiff, hereby respectfully submit the following Stipulation and (Proposed) Order on Plaintiffs Anonymity.
+
+The parties have reached an agreement on a form Anonymity Order, which includes the condition that a Non-Disclosure Agreement be signed by any non-party provided with the identity of Plaintiff.
+
+The parties respectfully request the Court enter the attached (proposed) Order and Agreed Non-Disclosure Agreement.
+
+Dated: January 28, 2020 New York, New York Res tfull Submitted, POTT1NGER, LLC
+
+B: J. r
+
+425 N. Andrews Ave., Suite 2
+
+Fort Lauderdale, FL 33301
+
+(954)-524-2820
+
+Fax: (954)-524-2822
+
+Email: ecf@epllc.com
+
+brad®eplle.com
+
+brittany@eplic.com
+
+Attorneys for Plaintiff (ADMISSION PRO HAC VICE)

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751754/EFTA02751754.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751754",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "7514990c72d651f5c5dc920f19764c3064042ebd2c6525ad070b1c3d5e91a54d",
+  "output_sha256": "7514990c72d651f5c5dc920f19764c3064042ebd2c6525ad070b1c3d5e91a54d",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751758/EFTA02751758.md

@@ -0,0 +1,35 @@
+## UNITED STATES DISTRICT COUR-SOUTHERN DISTRICT OF NEW YOR.
+
+ANASTASIA DOE,
+
+Plaintiff,
+
+v.
+
+DARREN K. INDYKE AND RICHARD D. KAHN CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN,
+
+Defendant.
+
+USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: J
+
+Case No. 1:19-cv-11869-AJN
+
+## ORDER ON PLALNTIFF'S ANONYMITY
+
+IT IS HEREBY ORDERED that any person subject to this Order, including the parties to this action and their respective counsel of record, shall adhere to the following terms:
+
+- 1. Within three (3) days of entry of this Order, Counsel of Record for Plaintiff shall disclose Plaintiff's identity to Counsel of Record for Defendants, in writing.
+- 2. Counsel of Record for Defendants may disclose Plaintiff's identity only to Defendants and any attorneys, paralegals, and clerical or other assistants working with or for Defendants on matters related to this action; and the recipients of such information shall not disclose it to any other persons.
+- 3. If Defendants wish to disclose Plaintiff's identity to any person not otherwise permitted to receive such information under this Order, Defendants are limited to doing so in connection with defending this action, and must require such person to first execute a non-disclosure agreement, in a form agreed to by the parties, that prevents such person from disclosing Plaintiff's identity to any other persons. Defendants must maintain a list of all such persons to whom Plaintiff's identity is disclosed and copies of the executed non-disclosure agreements, all of which are subject to in camera inspection.
+- 4. All portions of pleadings, motions or other papers filed with the Court that disclose Plaintiff's identity shall be filed under seal with the Clerk of the Court and kept under seal until further order of the Court. The parties shall use their best efforts to minimize such sealing. Any party filing a motion or any other papers with the Court under seal shall also publicly file a redacted copy of the same, via the Court's Electronic Case Filing system, that redacts the Plaintiff's identity and text that would reveal Plaintiff's identity.
+
+1. 5. The parties may seek to modify or amend this Order at any time upon motion to the Court or by stipulation.
+
+SO ORDERED.
+
+Date: 1/29/2020  
+New York, New York
+
+DEBRA FREEMAN  
+UNITED STATES MAGISTRATE JUDGE  
+SOUTHERN DISTRICT OF NEW YORK

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751758/EFTA02751758.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -5,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751758",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 1,
+  "fix_ids": "[\"builtin.empty-image\"]",
+  "idempotent": true,
+  "input_sha256": "6655a67710d9c39b164635a772fd98a83c22c7e71634131f71749fd719ff7762",
+  "output_sha256": "a4425b45320093a4bd0137ded4e1e0d6ed13cbdabad0c48d8a9f052d741df98f",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751760/EFTA02751760.md

@@ -0,0 +1,36 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+X ANASTASIA DOE, Plaintiff, : Index No. 1:19-cv-11869-MKV-DCF v. DARREN K. INDYKE AND RICHARD D. KAHN, AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. X
+
+## JOINT PROPOSED DISCOVERY SCHEDULE
+
+Pursuant to the Court's Order dated January 14, 2020 and Rule 26(0(3) of the Federal Rule of Civil Procedure, Plaintiff Anastasia Doe and Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors" and together with Plaintiff, the "Parties") hereby jointly submit the following proposed discovery schedule:
+
+- I. The Parties shall serve their initial disclosures pursuant to Rule 26(a)(1) no later than February 7, 2020;
+- 2. Plaintiff shall provide HIPAA-compliant medical records release authorizations to the Co-Executors no later than 14 days from the request therefor,
+- 3. The Parties shall serve initial document requests and interrogatories no later than 30 days from the Court's entry of the discovery schedule;
+- 4. Any motion for joinder of other parties or amendment of the pleadings shall be made no later than 45 days from the Court's entry of the discovery schedule;
+- 5. Fact discovery shall be completed no later than 140 days from the Court's entry of the discovery schedule;
+- 6. Expert disclosures and expert discovery shall be completed no later than 200 days from the Court's entry of the discovery schedule; and
+
+- 7. The Parties shall have 30 days from the service of an expert's initial report to serve a rebuttal report.
+
+At this time, the Parties anticipate that discovery may be needed on the following subjects: (1) Mr. Epstein's alleged torts committed against Plaintiff and (2) Plaintiff's alleged damages.
+
+Within 14 days from the Court's entry of the discovery schedule, the Co-Executors will provide Plaintiff with a standard, proposed electronically stored information ("ESI") protocol in order to address any issues about disclosure, discovery, or preservation of ESI, including the form or forms in which it should be produced.
+
+Within 14 days from the Court's entry of the discovery schedule, the Co-Executors will provide Plaintiff with a proposed protective order, with standard clawback provisions, to address any issues about claims of privilege or of protection as trial-preparation materials.
+
+At this time, the Parties have no proposed changes to the limitations on discovery imposed by the Federal Rules of Civil Procedure or by the Local Rules of the United States District Court for the Southern District of New York.
+
+With the exception of the protective order mentioned above, the Parties are not currently aware of any other orders that the Court should issue under Rule 26(c) or under Rule 16(b) and (c).
+
+The Parties respectfully request that the Court enter this joint proposed discovery schedule in this matter.
+
+Dated: New York, New York February 6.2020
+
+By: /s/ Brad By: Is/ Bennet J. Moskowitz Brad Bennet J. Moskowitz 425 North Andrews Avenue, Suite 2 875 Third Avenue Fort Lauderdale, Florida 33301 New York, New York 10022
+
+POTTINGER LLC TROUTMAN SANDERS LLP
+
+Attorney for Plaintiff Attorney for Defendants

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751760/EFTA02751760.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751760",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "d19ed82363c0f3aaa08ae6f4bb79ba12a3c1f591ca679a3ff46f6a0987f022ef",
+  "output_sha256": "d19ed82363c0f3aaa08ae6f4bb79ba12a3c1f591ca679a3ff46f6a0987f022ef",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751763/EFTA02751763.md

@@ -0,0 +1,55 @@
+The Clerk of Court of the Southern District of New York is directed to docket the within ORDER in each of the following actions:
+
+USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC it: DATE FILEIT41412Q2a. VE v. Nine East 71st Street et aL, No. 1:19-cv-07625 (AJN) (DF)
+
+Katlyn Doe v. Indyke et at, No. 1:19-cv-07771 (PKC) (DF)
+
+Priscilla Doe v. Indyke et al., No. 1:19-cv-07772 (ALC) (DF)
+
+Lisa Doe v. Indyke et at, No. 1:19-cv-07773 (ER) (DF)
+
+Jane Doe v. Indyke et at, No. 1:19-cv-08673 (KPF) (DF)
+
+v. Indyke et aL, No. 1:19-cv-10475 (LGS) (DF)
+
+v. Indyke et aL, No. 1:19-cv-10476 (PGG) (DF)
+
+v. Indyke et at, No. 1:19-cv-10479 (ALC) (DF)
+
+Jane Doe 1000 v. Indyke et aL, No. 1:19-cv-10577 (LGS) (DF)
+
+Jane Doe 15 v. Indyke et aL, No. 1:19-cv-10653 (PAE) (DF)
+
+Mary Doe v. Indyke et at, No. 1:19-cv-10758 (PAE) (DF)
+
+v. Indyke et at, No. l:19-cv-10788 (O1-1W) (DF)
+
+Anastasia Doe v. Indyke et aL, No. 1:19-cv-11869 (AJN) (DF)
+
+## DEBRA FREEMAN, United States Magistrate Judge:
+
+The Court having held a case management conference on February 11, 2020, with counsel for all parties in the above-referenced cases, it is hereby ORDERED, as stated at the conference, that:
+
+- 1. To the extent not already made, the parties shall make initial disclosures under Rule 26(a)(1) of the Federal Rules of Civil Procedure no later than February 25, 2020.
+- 2. The parties shall serve their initial document requests and interrogatories no later than March 10, 2020. In their initial interrogatories, the parties may, as reasonable, seek information outside the scope of Local Civil Rule 33.3(a).
+- 3. Any motions to amend the pleadings or to join any additional parties shall be filed no later than April 30, 2020.
+  - 4. All fact discovery shall be completed no later than June 10, 2020.
+
+- 5. Expert discovery shall be conducted on the following schedule:
+  - a. Plaintiffs' expert reports shall be served no later than June 10, 2020.
+  - b. Defendants' rebuttal reports shall be served no later than July 10, 2020.
+  - c. Expert discovery shall be completed no later than July 31, 2020.
+
+6. The parties may stipulate to modify interim deadlines in this Scheduling Order, without seeking prior leave of Court.
+
+7. The parties to the above-referenced cases shall submit joint status reports to the Court, regarding discovery and the progress of settlement discussions, no later than April 30, 2020.
+
+Dated: New York, New York February 11, 2020
+
+SO ORDERED
+
+DEBRA FREEMAN United States Magistrate Judge
+
+Copies to:
+
+All counsel in the above-referenced cases (via ECF)

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751763/EFTA02751763.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751763",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "2dfb6f4d0aaad75866dfcab421a238b6f0e476fe14a1795b0468525ff236dbf0",
+  "output_sha256": "2dfb6f4d0aaad75866dfcab421a238b6f0e476fe14a1795b0468525ff236dbf0",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751765/EFTA02751765.md

@@ -0,0 +1,41 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+X ANASTASIA DOE, Plaintiff, Index No. I :19-cv-11869-MKV-DCF v. DARREN K. INDYKE AND RICHARD D. KAHN AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. X
+
+## AFFIDAVIT IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
+
+I, Mary "Molly" S. DiRago, declare as follow:
+
+I. I am a member in good standing of the State Bar of Illinois and an associate with the law firm Troutman Sanders LLP, counsel for Defendants, Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"). I submit this affidavit in support of my Motion for Admission Pro Hac Vice before this Court.
+
+2. I have never been convicted of a felony.
+
+3. I have never been censured, suspended, disbarred, or denied admission or readmission by any court.
+
+4. There are no disciplinary proceedings presently against me.
+
+I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
+
+Dated: February 14, 2020 Respectfully Submitted,
+
+Is/ Mary "Molly" S. DiRago
+
+Mary "Molly" S. DiRago (Pro Hac Vice Pending)
+
+Troutman Sanders LLP
+
+One North Wacker Drive, Suite 2905
+
+Chicago, 60606
+
+(312) 759-1926
+
+(312) 759-1939 (Fax)
+
+molly.dirago@troutman.com
+
+Attorneys for Defendants Darren K. Indyke and
+
+Richard D. Kahn, Co-Executors of the Estate of
+
+Jeffrey E. Epstein

marker2-fixhub/court-doe-v-indyke-11869/EFTA02751765/EFTA02751765.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": 0,
+  "dataset": "marker2",
+  "doc_id": "EFTA02751765",
+  "engine": "marker-pdf-2.0.0+surya-0.22.1",
+  "event_count": 0,
+  "fix_ids": "[]",
+  "idempotent": true,
+  "input_sha256": "a33526706b19e06f9a05d8fb5c89a0400df33f80cf3e58fbb1d340c50acaa19e",
+  "output_sha256": "a33526706b19e06f9a05d8fb5c89a0400df33f80cf3e58fbb1d340c50acaa19e",
+  "page_markers": false,
+  "source_id": "marker2-court-doe-v-indyke-11869",
+  "text_format": "markdown"
+}