diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751696/EFTA02751696.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751696/EFTA02751696.md new file mode 100644 index 0000000000000000000000000000000000000000..d8f4bb42d7d6aa2c58285189d84fe49542b1d745 --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751696/EFTA02751696.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751696/EFTA02751696.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..67736d464dee5f6b12c3668395da51308cec811c --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751711/EFTA02751711.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751711/EFTA02751711.md new file mode 100644 index 0000000000000000000000000000000000000000..4f67c0e7e39563b2458d8fb66c67f6818b895212 --- /dev/null +++ b/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) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751711/EFTA02751711.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751711/EFTA02751711.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..46d6b05435b95f62b7a57181a5765200ac3f1a6c --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751725/EFTA02751725.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751725/EFTA02751725.md new file mode 100644 index 0000000000000000000000000000000000000000..c1f1f4a2e5b0f417cbd459599b4feb0126855de4 --- /dev/null +++ b/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. \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751725/EFTA02751725.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751725/EFTA02751725.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1768df9480ef360bad3838ec0c6413131510436b --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751727/EFTA02751727.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751727/EFTA02751727.md new file mode 100644 index 0000000000000000000000000000000000000000..a1ee3f9d4a3149a9ca911c1da5436501d7b6cf5e --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751727/EFTA02751727.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751727/EFTA02751727.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9b104da957bf4544e6d19127a1662e6f009a5a38 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751731/EFTA02751731.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751731/EFTA02751731.md new file mode 100644 index 0000000000000000000000000000000000000000..e873ee5c5b11beb51e14c48d61193c60e4c81cca --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751731/EFTA02751731.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751731/EFTA02751731.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fbfbbf7525c12d79e7c0f707b90d1b84be87d787 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751732/EFTA02751732.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751732/EFTA02751732.md new file mode 100644 index 0000000000000000000000000000000000000000..658034915c013d4c716856e3deadff512756715d --- /dev/null +++ b/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) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751732/EFTA02751732.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751732/EFTA02751732.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e9fb4bfee1888ee8244967a910012f24d86eae36 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751733/EFTA02751733.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751733/EFTA02751733.md new file mode 100644 index 0000000000000000000000000000000000000000..47475ba5b83f9a05a0260f0e686fb73b28c36500 --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751733/EFTA02751733.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751733/EFTA02751733.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f17151a44a9f9d05c34fd8b19cdd22c45a0dccb0 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751737/EFTA02751737.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751737/EFTA02751737.md new file mode 100644 index 0000000000000000000000000000000000000000..e57a7049695fa60c482e0ea2587b279939bc548d --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751737/EFTA02751737.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751737/EFTA02751737.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e7d4d3c2efb27765983840326aa23329b8b01fa4 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751738/EFTA02751738.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751738/EFTA02751738.md new file mode 100644 index 0000000000000000000000000000000000000000..756a6414246f4d9b1aa40713d27639e2daaeab7a --- /dev/null +++ b/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) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751738/EFTA02751738.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751738/EFTA02751738.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1ca54c61a1998ef283693e1bd9dc3c3eb775a379 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751739/EFTA02751739.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751739/EFTA02751739.md new file mode 100644 index 0000000000000000000000000000000000000000..952f2de99b8f68565b1b0fb32823a8e7819b0a11 --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751739/EFTA02751739.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751739/EFTA02751739.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ed1f86a9d29b09060e260e8ae93c42d603bcc61f --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751740/EFTA02751740.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751740/EFTA02751740.md new file mode 100644 index 0000000000000000000000000000000000000000..36e19d96b42b04e7313430fe73e3723c3d203482 --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751740/EFTA02751740.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751740/EFTA02751740.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..59c741ed6a6e42c5bcd10d69974434ca6866787a --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751741/EFTA02751741.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751741/EFTA02751741.md new file mode 100644 index 0000000000000000000000000000000000000000..c967bd6b4dc8691913a1ce4395bc87da0f87a7d5 --- /dev/null +++ b/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): + +| General Pretrial (includes scheduling, discovery, non-dispositive pretrial motions, and settlement) | Consent under 28 U.S.C. §636(c) for all purposes (including trial) | +| ----------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------- | +| Specific Non-Dispositive Motion/Dispute:*
_____
_____
_____ | Consent under 28 U.S.C. §636(c) for limited purpose (e.g., dispositive motion, preliminary injunction)
Purpose: _____ | +| Settlement*
_____ | Habeas Corpus | +| Inquest After Default/Damages Hearing | Social Security
Dispositive Motion (i.e., motion requiring a Report and Recommendation)
Particular Motion: _____ | + +\*Do not check if already referred for general pretrial. + +Dated 11/8/20 + +United States District Judge \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751741/EFTA02751741.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751741/EFTA02751741.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..85fc6e95bce66085fc9a7d6f1635b34e609e15c1 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751742/EFTA02751742.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751742/EFTA02751742.md new file mode 100644 index 0000000000000000000000000000000000000000..12b2271c6b1a12516c2993ff33ffe71b9008decf --- /dev/null +++ b/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. \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751742/EFTA02751742.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751742/EFTA02751742.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3e559e901eb3ebe362c43e6ab5ac4164fba2086b --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751743/EFTA02751743.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751743/EFTA02751743.md new file mode 100644 index 0000000000000000000000000000000000000000..e398489864b0303fb5bbb28636fee0c80a35847e --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751743/EFTA02751743.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751743/EFTA02751743.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..07b286593ab1d3e411d7870fc3676202792f65b5 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751745/EFTA02751745.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751745/EFTA02751745.md new file mode 100644 index 0000000000000000000000000000000000000000..e3730d5b7de8cffe67c7250df7028bc25c86c9f1 --- /dev/null +++ b/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) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751745/EFTA02751745.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751745/EFTA02751745.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fe83a19e7877707cd7cd1ab661ae5192829e4c6b --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751748/EFTA02751748.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751748/EFTA02751748.md new file mode 100644 index 0000000000000000000000000000000000000000..3f6b0f3d1f03e444ec52472ad3da29ab8e9e3cd7 --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751748/EFTA02751748.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751748/EFTA02751748.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..74122d51a510983066221bba0596351f50b0b18d --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751749/EFTA02751749.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751749/EFTA02751749.md new file mode 100644 index 0000000000000000000000000000000000000000..26c50523b24402060af51ceb9cff3af3c2f12a2d --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751749/EFTA02751749.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751749/EFTA02751749.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..eb03ea68257c75e6eb7c672983db4b036c1c13f7 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751750/EFTA02751750.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751750/EFTA02751750.md new file mode 100644 index 0000000000000000000000000000000000000000..1adb7c0a96aee0deb21fc579df01eb70be5156fe --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751750/EFTA02751750.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751750/EFTA02751750.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..dc8247934153cbb133862ba98ff765b036451dd3 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751751/EFTA02751751.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751751/EFTA02751751.md new file mode 100644 index 0000000000000000000000000000000000000000..fa638cfd58f552cea4e6f79377a6e23b266e2057 --- /dev/null +++ b/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) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751751/EFTA02751751.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751751/EFTA02751751.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3149803dd55f88775e8494edbb7ef01ecdf0c816 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751753/EFTA02751753.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751753/EFTA02751753.md new file mode 100644 index 0000000000000000000000000000000000000000..eac393368f4ae045ee9e82f023189aa24adb45a7 --- /dev/null +++ b/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] \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751753/EFTA02751753.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751753/EFTA02751753.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..28f7c3e3f935cad9e6221eca8435bbdf2b76a4f6 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751754/EFTA02751754.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751754/EFTA02751754.md new file mode 100644 index 0000000000000000000000000000000000000000..befd20604d99ec308e44c7ac641fc0fb81904e0e --- /dev/null +++ b/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) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751754/EFTA02751754.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751754/EFTA02751754.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c244a5a2cbd2bc3b5c8e69cce567081a0e58116e --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751758/EFTA02751758.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751758/EFTA02751758.md new file mode 100644 index 0000000000000000000000000000000000000000..2de5c2832941d5fe37896df9f0e30476cd6268fd --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751758/EFTA02751758.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751758/EFTA02751758.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a8c77e6480d6d1910ef059a7fd0a05e400f73069 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751760/EFTA02751760.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751760/EFTA02751760.md new file mode 100644 index 0000000000000000000000000000000000000000..53009997cba964366659fb0f8cdcb0639ee1b4da --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751760/EFTA02751760.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751760/EFTA02751760.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bb0fcae35e06c05b9ce9337147108258fbef4f9e --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751763/EFTA02751763.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751763/EFTA02751763.md new file mode 100644 index 0000000000000000000000000000000000000000..f98d0e36057fee58a67980c1a8e47494d794f39b --- /dev/null +++ b/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) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751763/EFTA02751763.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751763/EFTA02751763.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..50f4b1b5b368dd038d252643b706da4782c50285 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751765/EFTA02751765.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751765/EFTA02751765.md new file mode 100644 index 0000000000000000000000000000000000000000..e7b0515da3e689e84d062ba175a087f312e595d2 --- /dev/null +++ b/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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751765/EFTA02751765.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751765/EFTA02751765.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1969b579c9427ba5003d2d190c2e45d4a1a008e7 --- /dev/null +++ b/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" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751767/EFTA02751767.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751767/EFTA02751767.md new file mode 100644 index 0000000000000000000000000000000000000000..8210c93d8669301987d5936fd6aca634fa5208b8 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751767/EFTA02751767.md @@ -0,0 +1,33 @@ +## Certificate of Admission To the Bar of Illinois + +I, Carolyn Taft Grosboll, Clerk of the Supreme Court of Illinois, do hereby certify that + +Mary Sharon DiRago + +has been duly licensed and admitted to practice as an Attorney and Counselor at Law within this State; has duly taken the required oath to support the CONSTITUTION OF THE UNITED STATES and of the STATE OF ILLINOIS, and also the oath of office prescribed by law, that said name was entered upon the Roll of Attorneys and Counselors in my office on 11/04/2004 and is in good standing, so far as the records of this office disclose. + +> IN WITNESS WHEREOF, I have hereunto subscribed my name and affixed the seal of said Court, this 31st day of January, 2020. + +> > Croy acieree + +Clerk, Supreme Court of the State of Illinois + +## CERTIFICATE OF GOOD STANDING + +![](_page_1_Picture_2.jpeg) + +United States of America + +}ss. Mary S DiRago + +Northern District of Illinois + +G. Bruton , Clerk of the United States District Court for the Northern District of Illinois, + +DO HEREBY CERTIFY That Mary S DiRago was duly admitted to practice in said Court on (12/08/2004) and is in good standing as a member of the bar of said court. + +Dated at Chicago, Illinois on (01/29/2020 ) + +3. Bruton , Clerk, + +By: 1 ma Lam Deputy Clerk \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751767/EFTA02751767.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751767/EFTA02751767.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..bb0e0bd5a55afe418c5eea5c238aa7edb9233a70 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751767/EFTA02751767.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751767", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "11627b64c06b0d3311f2f14eacca95dba6eef6b9f9d023d87cf47baf368461a0", + "output_sha256": "11627b64c06b0d3311f2f14eacca95dba6eef6b9f9d023d87cf47baf368461a0", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751769/EFTA02751769.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751769/EFTA02751769.md new file mode 100644 index 0000000000000000000000000000000000000000..b2ab147ebb6c645407b48e511cfb731023bdfa6e --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751769/EFTA02751769.md @@ -0,0 +1,19 @@ +## 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 + +## ORDER FOR ADMISSION PRO HAC VICE + +The motion of Mary "Molly" S. DiRago for admission to practice Pro Hac Vice in the above captioned action is granted. + +Applicant has declared that she is a member in good standing of the bar(s) of the state(s) of Illinois; and that her contact information is as follows: + +Mary "Molly" S. DiRago Troutman Sanders LLP One North Wacker Drive, Suite 2905 Chicago, 60606 (312) 759-1926 (312) 759-1939 (Fax) molly.dirago®troutman.com + +Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors") in the above entitled action; + +IT IS HEREBY ORDERED that 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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751769/EFTA02751769.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751769/EFTA02751769.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a541bcdb4345a852bca6e7683f63965905fb6dbf --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751769/EFTA02751769.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751769", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "a64f4c62629731663332ae31a5b8905a251cb04a97acaa3fd5be766fbc8f90b1", + "output_sha256": "a64f4c62629731663332ae31a5b8905a251cb04a97acaa3fd5be766fbc8f90b1", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751771/EFTA02751771.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751771/EFTA02751771.md new file mode 100644 index 0000000000000000000000000000000000000000..7ce91bd79cae0109830a5a8bb4111e907e328e26 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751771/EFTA02751771.md @@ -0,0 +1,45 @@ +## 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 + +## 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, Molly S. DiRago hereby moves this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the above-captioned action. + +I am in good standing of the bar(s) of the state of Illinois 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: February 14, 2020 Respectfully Submitted, + +/il 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 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751771/EFTA02751771.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751771/EFTA02751771.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3514f426a6e8eef1ed86e7f53c5351456b84e509 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751771/EFTA02751771.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751771", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "011ce3ec001bae8897fc1e16069c52e06bc9625fa2984ffda949668f44a43aee", + "output_sha256": "011ce3ec001bae8897fc1e16069c52e06bc9625fa2984ffda949668f44a43aee", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751773/EFTA02751773.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751773/EFTA02751773.md new file mode 100644 index 0000000000000000000000000000000000000000..f3281a3804674d5184b28729f6a421be6b3c5281 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751773/EFTA02751773.md @@ -0,0 +1,21 @@ +Bennet J. Moskowitz + +bennet.moskowitz@troutman.com + +February 17, 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-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, with Plaintiff's consent, of a two (2) day extension of time, from February 17, 2020 to February 19, 2020, for Defendants to respond to Plaintiff's Complaint (ECF #1). The Court previously approved the parties' agreement whereby we agreed to accept service of Plaintiff's Complaint on Defendants' behalf and Plaintiff consented to Defendants having through February 17 to respond to Plaintiff's Complaint. + +Respectfully submitted, + +/s/ Bennet J. Moskowitz + +Bennet J. Moskowitz \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751773/EFTA02751773.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751773/EFTA02751773.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a6c22db4bc487b596538311b837d9853cca8dc75 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751773/EFTA02751773.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751773", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "db779fb63776bb90437ce85881003ce523af84f64dd2276ae558ec872f451b4c", + "output_sha256": "db779fb63776bb90437ce85881003ce523af84f64dd2276ae558ec872f451b4c", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751774/EFTA02751774.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751774/EFTA02751774.md new file mode 100644 index 0000000000000000000000000000000000000000..5ed86a60d1581f91fd1334b89182b11fdd398fe0 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751774/EFTA02751774.md @@ -0,0 +1,21 @@ +Bennet J. Moskowitz + +bennet.moskowitz@troutman.com + +February 17, 2020 + +ECF + +Hon. Mar Vyskocil Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 + +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-MKV-DCF + +Dear Judge Vyskocil: + +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, with Plaintiff's consent, of a two (2) day extension of time, from February 17, 2020 to February 19, 2020, for Defendants to respond to Plaintiff's Complaint (ECF #1). The Court previously approved the parties' agreement whereby we agreed to accept service of Plaintiff's Complaint on Defendants' behalf and Plaintiff consented to Defendants having through February 17 to respond to Plaintiff's Complaint. + +Respectfully submitted, + +/s/ Bennet J. Moskowitz + +Bennet J. Moskowitz \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751774/EFTA02751774.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751774/EFTA02751774.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..364e1a42ba76569ad34639f0407eba154e39cfa1 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751774/EFTA02751774.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751774", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "9187fc659f787fd2cef32c25af3b40d42663ea5a79e735cf5a94b528f7342dc8", + "output_sha256": "9187fc659f787fd2cef32c25af3b40d42663ea5a79e735cf5a94b528f7342dc8", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751775/EFTA02751775.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751775/EFTA02751775.md new file mode 100644 index 0000000000000000000000000000000000000000..c36def92a8ee401231be7f68b745a6ea9b7ea403 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751775/EFTA02751775.md @@ -0,0 +1,29 @@ +Troutman Sanders LLP 875 Third Avenue New York, New York 10022 + +troutman.com + +Bennet J. Moskowitz bennet.moskowitz@troutman.com + +February 17, 2020 + +ECF + +Hon. Mar Vyskocil Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 + +![](_page_0_Picture_3.jpeg) + +Granted. SO ORDERED. + +Date: 2/18/2020 /6 United St as YDistrict Judge New York, New York ocil + +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-MKV-DCF + +Dear Judge Vyskocil: + +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, with Plaintiff's consent, of a two (2) day extension of time, from February 17, 2020 to February 19, 2020, for Defendants to respond to Plaintiff's Complaint (ECF #1). The Court previously approved the parties' agreement whereby we agreed to accept service of Plaintiff's Complaint on Defendants' behalf and Plaintiff consented to Defendants having through February 17 to respond to Plaintiff's Complaint. + +Respectfully submitted, + +/s/ Bennet J. Moskowitz Bennet J. Moskowitz + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC it. DATE FILED: 2/18/2020 \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751775/EFTA02751775.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751775/EFTA02751775.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3040ac268852d692478b6826d0fdd42dcb938eca --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751775/EFTA02751775.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751775", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "4ae1744a688b81543680095ebd0ede5667b22c73852d2bb5282372a14dd0c30f", + "output_sha256": "4ae1744a688b81543680095ebd0ede5667b22c73852d2bb5282372a14dd0c30f", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751776/EFTA02751776.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751776/EFTA02751776.md new file mode 100644 index 0000000000000000000000000000000000000000..6758b28bbc2daecce5a790e363e9415bd70c585c --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751776/EFTA02751776.md @@ -0,0 +1,236 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +ANASTASIA DOE, + +Plaintiff, CASE 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. + +# DEFENDANTS' ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF'S COMPLAINT + +Defendants Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein (the "Co-Executors"), through their undersigned counsel, hereby respond to the numbered paragraphs of Plaintiff's Complaint (ECF Doc. I) as follows: + +- I. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in the first sentence of paragraph I of the Complaint. The second sentence of paragraph 1 of the Complaint states a legal conclusion to which no response is required. +- 2. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 2 of the Complaint, except admit that Plaintiff filed the Complaint using a pseudonym. +- 3. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 3 of the Complaint. +- 4. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 4 of the Complaint, except admit that, at the time of his death, decedent Jeffrey E. Epstein ("Decedent") was a U.S. citizen. + +5. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 5 of the Complaint, except admit that Decedent was born in 1953 and died on August 10, 2019. + +6. Paragraph 6 of the Complaint states legal conclusions to which no response is required. To the extent a response is required, the Co-Executors deny the allegations in paragraph 6 of the Complaint except admit that, on August 15, 2019, a petition for probate and for letters testamentary In the Matter of the Estate offeffrey E. Epstein was filed in the Superior Court of the Virgin Islands Division of St. and St. John; and the Co-Executors refer thereto for the full text, terms and meaning thereof. + +7. Paragraph 7 of the Complaint states a legal conclusion to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 7 of the Complaint. + +8. Paragraph 8 of the Complaint states legal conclusions to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 8 of the Complaint; except the Co-Executors admit that, on September 6, 2019, the Superior Court of the Virgin Islands Division of St. and St. John issued Letters Testamentary appointing the Co-Executors as co-executors for Decedent's estate and refer thereto for the full text, terms and meaning thereof. + +# FACTUAL ALLEGATIONS + +9. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 9 of the Complaint. + +10. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 10 of the Complaint. + +11. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 11 of the Complaint. + +12. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 12 of the Complaint. + +13. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 13 of the Complaint. + +14. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 14 of the Complaint. + +15. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 15 of the Complaint, except admit the existence of the indictment attached to Plaintiffs Complaint and refer thereto for the full text, terms and meaning thereof. + +16. The Co-Executors deny the allegations in paragraph 16, except admit the existence of the indictment attached to Plaintiff's Complaint and refer thereto for the full text, terms and meaning thereof. + +17. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 17 of the Complaint, except admit the existence of the indictment attached to Plaintiff's Complaint and refer thereto for the full text, terms and meaning thereof. + +18. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 18 of the Complaint, except admit the existence of the indictment attached to Plaintiffs Complaint and refer thereto for the full text, terms and meaning thereof. + +19. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 19 of the Complaint, except admit the existence of the indictment attached to Plaintiffs Complaint and refer thereto for the full text, terms and meaning thereof. + +20. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 20 of the Complaint, except admit the existence of the indictment attached to Plaintiffs Complaint and refer thereto for the full text, terms and meaning thereof. + +21. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 21 of the Complaint, except admit the existence of the indictment attached to Plaintiffs Complaint and refer thereto for the full text, terms and meaning thereof. + +22. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 22 of the Complaint, except admit the existence of the indictment attached to Plaintiffs Complaint and refer thereto for the full text, terms and meaning thereof. + +23. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 23 of the Complaint. + +24. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 24 of the Complaint. + +### ANASTASIA DOE + +25. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 25 of the Complaint. + +26. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 26 of the Complaint. + +27. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 27 of the Complaint. + +28. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 28 of the Complaint. + +29. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 29 of the Complaint. + +30. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 30 of the Complaint. + +31. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 31 of the Complaint. + +32. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 32 of the Complaint. + +33. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 33 of the Complaint. + +34. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 34 of the Complaint. + +35. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 35 of the Complaint. + +36. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 36 of the Complaint. + +37. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 37 of the Complaint. + +38. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 38 of the Complaint. + +39. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 39 of the Complaint. + +40. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 40 of the Complaint. + +41. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 41 of the Complaint. + +42. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 42 of the Complaint. + +43. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 43 of the Complaint. + +44. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 44 of the Complaint. + +45. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 45 of the Complaint. + +46. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 46 of the Complaint. + +47. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 47 of the Complaint. + +48. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 48 of the Complaint. + +49. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 49 of the Complaint. + +50. Paragraph 50 of the Complaint states a legal conclusion to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 50 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 50 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +51. Paragraph 51 of the Complaint states a legal conclusion to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 51 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 51 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +52. Paragraph 52 of the Complaint states a legal conclusion to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 52 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 52 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +53. Paragraph 53 of the Complaint states a legal conclusion to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 53 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 53 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +54. Paragraph 54 of the Complaint states a legal conclusion to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 54 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 54 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +55. Paragraph 55 of the Complaint states a legal conclusion to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 55 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 55 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +56. Paragraph 56 of the Complaint states a legal conclusion to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 56 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 56 of the Complaint + +characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +57. Paragraph 57 of the Complaint states a legal conclusion to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 57 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 57 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +58. Paragraph 58 of the Complaint states a legal conclusion to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 58 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 58 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +## COUNT I BATTERYNIOLATION OF SECTION 130 AGAINST THE ESTATE OF JEFFREY E. EPSTEIN + +59. The Co-Executors incorporate their answers to paragraphs 1-58 of the Complaint as if set forth fully herein. + +60. Paragraph 60 of the Complaint states legal conclusions to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 60 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 60 of the Complaint characterize the referenced statutes, the statutes speaks for themselves. The Co-Executors refer to the referenced statutes for the full text, terms and meaning thereof. + +61. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 61 of the Complaint. + +62. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in Paragraph 62 of the Complaint. + +63. Paragraph 63 of the Complaint states legal conclusions to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 63 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 63 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +64. Paragraph 64 of the Complaint states legal conclusions to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 64 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 64 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +The "WHEREFORE" paragraph following paragraph 64 of the Complaint purports to state Plaintiff's prayer for relief and jury demand, to which no response is required. To the extent that a response is required, the Co-Executors, based on lack of knowledge or information sufficient to form a belief about the truth of Plaintiff's allegations, deny that Plaintiff is entitled to any of the relief described therein, or to any relief whatsoever. + +#### COUNT TWO SEXUAL ASSAULT + +65. The Co-Executors incorporate their answers to paragraphs 1-58 of the Complaint as if set forth fully herein. + +66. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 66 of the Complaint. + +67. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 67 of the Complaint. + +68. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 68 of the Complaint. + +69. Paragraph 69 of the Complaint states legal conclusions to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 69 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 69 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +70. Paragraph 70 of the Complaint states legal conclusions to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 70 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 70 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +"The "WHEREFORE" paragraph following paragraph 70 of the Complaint purports to state Plaintiff's prayer for relief and jury demand, to which no response is required. To the extent that a response is required, the Co-Executors, based on lack of knowledge or information sufficient to form a belief about the truth of Plaintiff's allegations, deny that Plaintiff is entitled to any of the relief described therein, or to any relief whatsoever. + +### COUNT THREE INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS + +71. The Co-Executors incorporate their answers to paragraphs 1-58 of the Complaint as if set forth fully herein. + +72. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 72 of the Complaint. + +73. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 73 of the Complaint. + +74. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 74 of the Complaint. + +75. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 75 of the Complaint. + +76. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 76 of the Complaint. + +77. Paragraph 77 of the Complaint states legal conclusions to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 77 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 77 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +78. Paragraph 78 of the Complaint states legal conclusions to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 78 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 78 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +The "WHEREFORE" paragraph following paragraph 78 of the Complaint purports to state Plaintiff's prayer for relief and jury demand, to which no response is required. To the extent that a response is required, the Co-Executors, based on lack of knowledge or information sufficient to form a belief about the truth of Plaintiff's allegations, deny that Plaintiff is entitled to any of the relief described therein, or to any relief whatsoever. + +## COUNT FOUR NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS + +79. The Co-Executors incorporate their answers to paragraphs 1-58 of the Complaint as if set forth fully herein. + +80. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 80 of the Complaint. + +81. The Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 81 of the Complaint. + +82. Paragraph 82 of the Complaint states legal conclusions to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 82 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 82 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +83. Paragraph 83 of the Complaint states legal conclusions to which no response is required. To the extent a response is required, the Co-Executors lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 83 of the Complaint. The Co-Executors further state that, to the extent the allegations in paragraph 83 of the Complaint characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the referenced statute for the full text, terms and meaning thereof. + +The "WHEREFORE" paragraph following paragraph 83 of the Complaint purports to state Plaintiff's prayer for relief and jury demand, to which no response is required. To the extent that a response is required, the Co-Executors, based on lack of knowledge or information sufficient to form a belief about the truth of Plaintiff's allegations, deny that Plaintiff is entitled to any of the relief described therein, or to any relief whatsoever. + +The Co-Executors deny any and all allegations in the Complaint not expressly admitted herein. + +# AFFIRMATIVE DEFENSES + +The Co-Executors, to the extent required by Fed. R. Civ. P. 8(c), assert the following affirmative defenses. By pleading these defenses, the Co-Executors do not assume the burden of proving any fact, issue, or element of a cause of action where such burden belongs to Plaintiff. Moreover, nothing stated herein is intended to or shall be construed as a concession that any particular issue or subject matter is relevant to Plaintiff's allegations. + +- 1. Plaintiff's Complaint fails, in whole or in part, to state a claim upon which relief can be granted. + +2. Plaintiff's claims are barred to the extent Plaintiff has not suffered any damages; alternatively, Plaintiff's claims are barred to the extent Plaintiff has not been damaged to the extent alleged, and failed to mitigate any damages she may have suffered. + +3. Contributory Negligence. If Plaintiff suffered or sustained any loss, injury, damage or detriment, and the same was directly and proximately caused and contributed to by the conduct, acts, omissions, activities, carelessness, negligence, and/or intentional misconduct of Plaintiff, Plaintiff's recovery herein is partially or completely barred. + +4. Assumption of Risk. Plaintiff's claims are barred to the extent that, at the time and place of the incidents alleged in Plaintiff's Complaint, Plaintiff knew of and fully understood the danger and risks incident to their undertaking; but despite such knowledge, Plaintiff freely and voluntarily assumed and exposed herself to all risks of harm and the consequential injuries and resultant damages, if any. + +5. Comparative Fault of Third Parties. If and to the extent that the Co-Executors are subjected to any liability to Plaintiff due, in whole or in part, to the acts, omissions, activities, carelessness, recklessness, negligence, and intentional misconduct of persons or entities other than Decedent, any recovery obtained by Plaintiff against the Co-Executors should be reduced in proportion to the respective negligence and fault and legal responsibility of all such other persons and entities, and their agents, servants and employees who contributed to or caused any such injury or damages, in accordance with the law of comparative negligence; the liability of the Co-Executors, if any, is limited in direct proportion to the percentage of fault actually attributed to Decedent. + +6. Statute of Limitations. The Complaint, and each and every cause of action contained therein, is barred by the applicable statute of limitations, including without limitation because the New York Child Victims' Act, including without limitation CPLR 2I4-g, violates the New York Constitution and the U.S. Constitution. + +7. Intervening/Superseding Causes. To the extent the injuries and damages which Plaintiff alleges were proximately caused by, or contributed to by, the acts of other persons or other entities, and said acts were intervening or superseding causes of the injuries and damages, if any, which Plaintiff alleges, Plaintiff is barred from any recovery against the Co-Executors. + +8. Plaintiff's claims are barred by the doctrines of waiver, estoppel and laches, + +9. Plaintiff's claims are barred by the doctrines of in pari delicto and unclean hands. + +10. To the extent Plaintiff seeks damages that are punitive in nature, they are barred including without limitation pursuant to N.Y. E.P.T.L. § 11-3.2. + +II. Plaintiff's claims are barred to the extent she is simultaneously prosecuting her claims in the Southern District of New York and the Superior Court of the Virgin Islands Division of St. and St. John. + +The Co-Executors have not knowingly or intentionally waived any applicable affirmative defenses and reserve the right to assert and rely upon such affirmative defenses as may become available or apparent during discovery. The Co-Executors further reserve the right to amend their Answer accordingly. + +Dated: New York, New York February 19, 2020 + +By: /s/ Bennet J. Moskowitz Bennet J. Moskowitz TROUTMAN SANDERS LLP 875 Third Avenue New York, New York 10022 + +Attorneys for Defendants \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751776/EFTA02751776.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751776/EFTA02751776.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2bbedbd2ddc083c5a9308c79e62b5c3e243356fe --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751776/EFTA02751776.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751776", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "1f5fcd5d5831eaf9d576e0a1bd6ee7f46ab1619390a68c1c916f01b6e5318a81", + "output_sha256": "1f5fcd5d5831eaf9d576e0a1bd6ee7f46ab1619390a68c1c916f01b6e5318a81", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751793/EFTA02751793.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751793/EFTA02751793.md new file mode 100644 index 0000000000000000000000000000000000000000..4e7fd04ad56a8ed88ab2dfd4a8920b3b00fcd1f0 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751793/EFTA02751793.md @@ -0,0 +1,35 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +ANASTASIA DOE. + +Plaintiff, + +-against-DARREN I INOTKE and RCHARD O. KAHN. a CO EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN. Defendant. Case No. 1:19-cv-11869-MKV-DCF + +## NOTICE OF CHANGE OF ADDRESS + +TO: ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES + +I have cases pending I have no cases pending + +Pursuant to Local Rule 1.3 of this Court, please take notice of the following attorney information change (s) for: + +Mary "Molly' S. DiRago FILL IN ATTORNEY NAME + +My SDNY Bar Number is: My State Bar Number is 6282757 + +I am. + +An attorney A Government Agency attorney A Pro Hac Vice attorney + +FIRM INFORMATION (Include full name of firm (OLD AND NEW), address, telephone number and fax number): + +OLD FIRM: FIRM NAME: TROUTMAN SANDERS UP FIRM ADDRESS:One North Wacker Drive. Suite 2905 Chicago. IL 60606 FIRM TELEPHONE NUMBER: giamet426 FIRM FAX NUM BER:szses + +NEW FIRM: FIRM NAME: TROUTMAN sANDERSLI.E.\_ FIRM ADDRESS:rntgaegthluileMarehicago—ILIDR0t\_ FIRM TELEPHONE NUMBER: (312)7S9T926 FIRM FAX NUMBER: 4312)759.1939 + +I will continue to be counsel of record on the above-entitled case at my new firm/agency. + +I am no longer counsel of record on the above-entitled case. An order withdrawing my appearance was entered on by Judge + +Dated: 03/20/2020 /s/ Mary \*Molly" S. DiRago ATTORNEY'S SIGNATURE \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751793/EFTA02751793.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751793/EFTA02751793.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..20b4622d7ef2672b9bf6f12d2c8a489c2122dce3 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751793/EFTA02751793.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751793", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "7fe38a82d846f1c0bf97380acb902daf45c7a909321ce9556b50d7aab6a3f367", + "output_sha256": "7fe38a82d846f1c0bf97380acb902daf45c7a909321ce9556b50d7aab6a3f367", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751794/EFTA02751794.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751794/EFTA02751794.md new file mode 100644 index 0000000000000000000000000000000000000000..7ba993839f6219f22112c15b8f0e1a0bf73452d4 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751794/EFTA02751794.md @@ -0,0 +1,28 @@ +Bennet J. Moskowitz D: 212-704-6000 bennet.moskowitz©iroutman.com + +April 14, 2020 + +## VIA ELECTRONIC COURT FILING + +Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl Street New York, New York 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-MKV-DCF + +Dear Judge Freeman: + +We represent Defendants in the above-referenced actions. In light of the ongoing pandemic and the various difficulties it has presented, we write with Plaintiffs' consent to request that the Court extend the remaining deadlines in the above-refenced actions, as set by this Court's Order dated February 11, 2020, by thirty (30) days, as follows: + +- the deadline for Plaintiffs to file any motions to amend the pleadings or to join any additional parties be extended from April 30, 2020 to June 1, 2020; +- the deadline for the Parties to submit joint status reports to the Court, regarding discovery and the progress of settlement discussions, be extended from April 30, 2020 to June 1, 2020; +- the deadline for the completion of fact discovery be extended from June 10, 2020 to July 10, 2020; +- the deadline for service of Plaintiffs' expert reports be extended from June 10, 2020 to July 10, 2020; +- the deadline for service of the Defendants' rebuttal reports be extended from July 10, 2020 to August 10, 2020; and +- the deadline for the completion of expert discovery be extended from July 31, 2020 to August 31, 2020. + +This is the first request for an extension of these deadlines. + +cc: Counsel of Record (via ECF) + +Respectfully submitted, + +s/Bennet J. Moskowitz Bennet J. Moskowitz \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751794/EFTA02751794.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751794/EFTA02751794.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..0d3719fbf559b52e521431166da720c7090ba573 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751794/EFTA02751794.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751794", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "26db79556436b47e7c2f97c1c3fb784078aa6005058b08d40248a4bc5b8dd64d", + "output_sha256": "26db79556436b47e7c2f97c1c3fb784078aa6005058b08d40248a4bc5b8dd64d", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751796/EFTA02751796.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751796/EFTA02751796.md new file mode 100644 index 0000000000000000000000000000000000000000..1cbc6b028aacd4f8df93bfc08539d33bb0bf2636 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751796/EFTA02751796.md @@ -0,0 +1,34 @@ +Bennet J. Moskowitz D: 212-704-6000 bennet.moskowitz@troutman.com + +## VIA ELECTRONIC COURT FILING + +Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl Street New York, New York 10007 + +## MEMORANDUM ENDORSED + +April 14, 2020 + +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-MKV-DCF + +Dear Judge Freeman: + +We represent Defendants in the above-referenced actions. In light of the ongoing pandemic and the various difficulties it has presented, we write with Plaintiffs' consent to request that the Court extend the remaining deadlines in the above-refenced actions, as set by this Court's Order dated February 11, 2020, by thirty (30) days, as follows: + +- the deadline for Plaintiffs to file any motions to amend the pleadings or to join any additional parties be extended from April 30, 2020 to June 1, 2020; +- the deadline for the Parties to submit joint status reports to the Court, regarding discovery and the progress of settlement discussions, be extended from April 30, 2020 to June 1, 2020; +- the deadline for the completion of fact discovery be extended from June 10, 2020 to July 10, 2020; +- the deadline for service of Plaintiffs' expert reports be extended from June 10, 2020 to July 10, 2020; +- the deadline for service of the Defendants' rebuttal reports be extended from July 10, 2020 to August 10, 2020; and +- the deadline for the completion of expert discovery be extended from July 31, 2020 to August 31, 2020. + +This is the first request for an extension of these deadlines. + +cc: Counsel of Record (via ECF) + +Respectfully submitted, + +s/Bennet J. Moskowitz Bennet J. Moskowitz + +April 14, 2020 SO ORDERED + +DEBRA FREEMAN United States Magistrate Judge \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751796/EFTA02751796.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751796/EFTA02751796.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7aac6ffa54635cabf0538ecb484b9f09dceb16b0 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751796/EFTA02751796.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751796", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "f14e50196a41c5ce8929eeca84b6fc40a87edf9e23c3bb8af49a2b455e4e7a9b", + "output_sha256": "f14e50196a41c5ce8929eeca84b6fc40a87edf9e23c3bb8af49a2b455e4e7a9b", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751798/EFTA02751798.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751798/EFTA02751798.md new file mode 100644 index 0000000000000000000000000000000000000000..32dc92785ea404bb61c11f756258bd2904b661cb --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751798/EFTA02751798.md @@ -0,0 +1,63 @@ +![](_page_0_Picture_1.jpeg) + +Florida Office + +J. Seth M. Lehrman Brittany N. "0 Matthew D. Weissing "i »04 + +## Filed Via ECF + +Magistrate Judge Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl Street, New York, NY 10007 POTTI NG ER LLC + +425 North Andrews Avenue Suite 2 Fort Lauderdak, FL 33301 + +Telephone (954)524-2820 Fax (954)524-2822 + +April 15, 2020 + +New York Office J. Stanley Pottinger t j Admitted in California 0 Admitted in DiStliCt of Columbia • Admitted in Florida j Admined in New York I Board rketified Civil Trul lawycr + +Re: VE v. Nine East 71" Street a aL, No. 19-cv-07625 (S.D.N.Y.) (Nathan, J.) Katlyn Doe v. Darren K. Indyke et aL, 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 at, No. 19-cv-07773 (S.D.N.Y.) (Ramos, J.) Anastasia Doe v. Darren K. Indyke, et aL, No. 19-cv-11869 (S.D.N.Y.) (Nathan, J.) + +Dear Judge Freeman, + +We represent the five Plaintiffs referenced above whose cases have all been assigned to Your Honor. We write to provide you with a Status Update regarding the progress of settlement discussions in the cases. As Your Honor is likely aware, counsel for claimants have spent a substantial amount of time working with both the Attorney General of the Virgin Islands and the Estate in an effort to facilitate the establishment of an independent and Voluntary Claims Resolution Program ("Program") for the purposes of resolving sexual abuse claims against Jeffrey Epstein. Unfortunately, we have reached a point of apparent impasse, and thus felt it necessary to apprise the Court of the recent events that have transpired. + +As Your Honor is aware, on November 14, 2019, the Estate sought approval of the Program from the probate court in the United States Virgin Islands. On January 15, 2020, just before the February 4, 2020 hearing wherein approval of the Program was anticipated, the Attorney General of the Virgin Islands filed a forfeiture action against the Estate along with a Criminal Activity Lien pursuant to the Criminally Influenced and Corrupt Organizations Act ("CICO"), effectively preventing the Estate from utilizing Estate assets to administer the Program. + +At the February 4, 2020 hearing in the Virgin Islands, Judge Hermon-Purcell informed everyone that the Attorney General's lien precluded the Court from allowing the Program to proceed and urged the Estate to meet with the Attorney General in an effort to resolve their disagreements to the extent necessary to allow the Program to move forward. The Attorney General expressed that she did not wish to impede the establishment of the Program, rather, she felt compelled to seek improvements to the Program to + +> 425 North Andrews Avenue, Suite 2, Fort Lauderdale, Florida 33301 954.524.2820 office 954.524.2822 fax + +ensure that its administration is both fair to the victims and independent from the Estate. In furtherance of that position, on February 10, the Attorney General wrote a letter to the Estate, outlining eleven substantive concerns about the manner in which the proposed Program was structured. Summarily, the Attorney General's main concerns centered on the following: (a) the independence of the Program Designers and Administrator, who were unilaterally selected by the Estate; (b) ensuring that assets would be preserved for victims who opted out of the program or came forward in the future to make sure that opting out of the Program was a meaningful option; and (c) the scope of the releases required of victims who participated in the program and their ability, and the ability of other witnesses, to cooperate with law enforcement. After careful consideration, including in-person meetings with several of Mr. Epstein's victims and counsel for many victims who flew back to the USVI, the Attorney General agreed to a partial lifting of her lien to allow for the immediate and effective implementation of the Program if the Estate would agree to certain improvements in the Program protocol. + +While it is true that counsel for the victims agreed with the Program moving forward as it was prior to the Attorney General's intervention, there were certain components of the Program that facially appeared to favor the Estate to the prejudice of the victims. The most obvious example of this is that the Estate unilaterally chose the Program Designers and Program Administrator, refusing to allow the victims or counsel any input in that selection process despite many requests for same. This issue was raised as a problem in front of Your Honor at the joint hearing on February I I, 2020. Your Honor even suggested at that hearing that if the appearance of the Program was going to be one of fairness, then the victims and their counsel should have some input in the selection process of the Administrator. The Estate did not listen, which only heightened the concerns of the Attorney General. + +We agree with the Attorney General that a Program of this nature requires excellent administration. For that reason, after meeting with and working with her for sn iy rnonths, the undersigned counsel gained confidence in the Estate selected Administrator, Jordana and believes she is best suited to serve in the role of Program Administrator. The Attorney General however, has taken great issue with the independence of the Program based on the fact that and the Program Designers—Ken Feinberg and Camille Biros—were unilaterally selected by the Estate without input from the victims. After much deliberation, and at the urging of the undersigned, the Attorney General agreed that her impartiality concerns could be meaningful) satisfied so long as the Estate would agree to add a victimselected Administrator to serve alongside + +We recommended Professor Marci as she is the foremost expert on child sexual abuse in the country. Professor has a wealth of knowledge and experience in the area of sexual abuse and would be an indispensable asset to the Program. Professor has an unparalleled understanding of the dynamics of sexual abuse, common responses to sexual abuse, and the impact of sexual abuse on victims. Because of unimpeachable record as an expert on the topic, the suggestion of adding her to the Program was ultimately accepted by the Attorney General and also by the Estate, the Program Designers, and the Program Administrator. + +This agreement was promisor although precise role had not been defined. In an effort to ensure that Professor expertise is utilized to the fullest extent possible, the Attorney General wanted Professor to have ual decision-making authority and for each claim to be decided by a consensus agreement between and Professor . The Estate rejected that notion outright claiming that any disagreement would delay what was designed to be an efficient + +process. Instead, the Estate proposed that would be available to consult with on an as-needed basis. + +On March 5, 2020, counsel for the Estate, counsel for the Attorney General, the undersigned counsel, and the Program Administrator met in Miami, Florida in an effort to resolve all outstanding issues to allow the Program to move forward, including to reach an agreement for Marci role in the Program. After the meeting, the undersigned believed all parties had agreed that Professor would be a Program Consultant with the ability to make a meaningful impact on the Program, but that all final claim decisions would rest exclusively with . Again, counsel for the victims found this a reement to be hopeful—albeit far from the Attorney General's original demand—as Professor would be able to provide input and valuable information on sexual abuse that would assist in the evaluation of the claims. + +After the Miami meeting, varying role descriptions remained pending for Professor The Attorney General and the victims merely requested that in order to serve as a meaningful Consultant to the Program, Professor should be permitted to review the claimant's files and rovide information to before evaluation decisions were made, understanding that could choose to completely ignore an o inions or suggestions made and that the ultimate decision will rest exclusively with . The Estate rejected outright the idea of allowin Professor to have access to the claimant files, and instead maintained that Professor would only be utilized to answer any general questions that may arise, if someone ever decided to call her with a question. With confidence that Professor involvement would enhance the quality of the Program and serve as an additional protection for the victims, the Attorney General reluctant! agreed to allow the Program to proceed notwithstanding the Estate's refusal to allow Professor to have decision making authority or even access to the view claimants Protarifiles, so long as the Program mandated periodic meetings between and Professor . The Estate and Attorney General agreed to bi-monthly meetings between the two, resolving the issue. + +In addition to the inclusion of Professor as a Program Consultant and referral source for counseling or other services to victims, all parties have agreed to make additional enhancements to the Program including: I) the probate court in the Virgin Islands will be responsible for approving and overseeing the expenses in operating the Program, 2) information provided by victims during the administration of the Program will be maintained as confidential and not be shared with the Estate or used against victims in defending claims, 3) the Program will report to the probate court on an aggregate basis the number and amount of claims awarded, and 4) a Victim Set-Aside Fund will be established with guaranteed minimum funding of \$25 million as a floor for victims who opt out of the Program or who emerge within eighteen months of the Program's launch. + +After what has turned into many months of time and effort expended to reach an agreement wherein the Attorney General would allow the Program to move forward, all parties—the Estate, the Attorney General, and counsel for many of the victims—did in fact agree on all aspects of the Program with the exception of the language of the proposed release to be signed by claimants. Both the Attorney General and the victims have asked that the release not include individual sex abusers aside from Jeffrey Epstein. Unfortunately, the Estate has remained steadfast in its position to require claimants resolving claims through the Program to release all abusers related to Epstein, making it clear that the release is designed in part to protect any criminal associated with the Epstein enterprise. While the victims do not + +believe this makes the statement the Estate should want to make, the Estate has claimed to do so in an effort to uphold their fiduciary duties. We recognize that the Program is whatever the Estate wants it to be and that if any victim does not want to release other criminals associated with Mr. Epstein then she can reject any offer made to her on that point. + +In an effort to begin obtaining justice and compensation for our clients as soon as possible, counsel for the victims have agreed to move forward with the Program using the release as drafted with the intention of negotiating the finer points of the release if and when such negotiation becomes necessary during the Program process. Such agreement to relent only came after multiple efforts for compromise were offered by both the Attorney General and the victims—all of which were rejected by the Estate. Despite our urging, the Attorney General has expressed that she cannot allow a Program to go forward that on its face aims to protect other criminals who abused young women unless the probate court in the Virgin Islands rules that the Program should move forward with the current release over her objection. + +As we have expressed to the Attorney General, the reality is that the Estate had no obligation to create a Program at all. The nature of many of these programs is that it is done for the benefit of the entity establishing the program—in this case the Estate. The Estate has not hidden behind that fact. The Estate had no obligation to consider the victims in choosing the Program Designers and Administrator. That decision to make a unilateral selection caused problems and made everyone skeptical from the very beginning. However, this is the Estate's Program and the Estate's rules. Recognizing that, we have assured the Attorney General that the victims are going into the Program eyes-wide-open, knowing that it is a Program designed by the Estate to protect the Estate and others. However, we have confidence and trust in the Program Administrator and her independence from the Estate and the fact that the claimants will have lawyers to advise them about the pros and cons of any settlement, including what she may be giving up. In that sense, the Program as designed, despite a less than optimal proposed release, is better than no program at all. + +This court has always been keenly interested in the Program that the Estate has touted so strongly at every hearing. We felt that it was necessary to provide this Court with a brief, yet detailed, overview of the current status of the Attorney General's lien and the negotiations as they relate to the Program. In an effort to finally obtain justice for many of Jeffrey Epstein's victims, we again request that this Court urge the Estate and the Attorney General alike to finalize their agreement so that the Attorney General will lift her lien and allow for the Program to go forward. + +POTTINGER + +ad wards + +? rittaStk nyHender Cat s t elL4-1"-- \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751798/EFTA02751798.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751798/EFTA02751798.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c35e37327bdb1e15d3a3cd55f4abe23cb3ccb44d --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751798/EFTA02751798.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751798", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "ddd10d2f826b325ea6dc9caf85645d8451b693b733eff3dee17fe6b9426eb706", + "output_sha256": "ddd10d2f826b325ea6dc9caf85645d8451b693b733eff3dee17fe6b9426eb706", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751802/EFTA02751802.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751802/EFTA02751802.md new file mode 100644 index 0000000000000000000000000000000000000000..b05b4ebb113ff02423b3f35542281489b22a8fad --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751802/EFTA02751802.md @@ -0,0 +1,392 @@ +SUPERIOR COURT +THE VIRGIN ISLANDS +20 MAR 24 AM 7:51 + +IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS +DIVISION OF ST. [REDACTED] & ST. JOHN + +\*\*\*\*\* + +| IN THE MATTER OF THE ESTATE OF +JEFFREY E. EPSTEIN, | ) | PROBATE NO. ST-19-PB-80 | +| ------------------------------------------------------- | --- | -------------------------------------- | +| | ) | | +| | ) | | +| Deceased. | ) | ACTION FOR TESTATE +ADMINISTRATION | + +**CO-EXECUTORS' STATUS REPORT ON CONTINUING +EFFORTS TO ESTABLISH VOLUNTARY COMPENSATION PROGRAM AND +REQUEST FOR RULING** + +Come now the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and provide the Court with this Status Report on their continuing efforts to establish an independent and voluntary claims resolution program (the "Program") for purposes of resolving sexual abuse claims against Jeffrey E. Epstein, deceased. + +If the Program fails to launch, it will be an extraordinary lost opportunity for eligible claimants to receive compensation and voluntarily resolve their claims of sexual abuse against Mr. Epstein through a confidential, non-adversarial alternative to litigation. And there will be only one culprit: the Attorney General of the Virgin Islands. Despite weeks of negotiation with the Attorney General's representatives — who prefer to file misleading "status reports" with the Court rather than engage in actual, good-faith discussions — the Co-Executors are no closer than before to having the Attorney General lift her liens on the Estate's accounts so that the Program can receive funds essential for its operations. + +The Co-Executors and the Attorney General agree on one point: both now seek a ruling from the Court that will enable the Program to go forward. The Co-Executors disagree, however, on the appropriate issue before the Court. According to the Attorney General, "[her] Office seeks a ruling from this Court as to whether the Program, as proposed, should be approved, or whether additional concessions, as outlined by the Attorney General, and in the better interests + +Estate of Jeffrey E Epstein Probate No. ST-I9-PB-80 Status Report and Request for Ruling Page 2 + +of the victims, are required for its approval and fair administration."' That is not the correct question: rather, it is whether the Co-Executors have acted in accordance with their fiduciary obligations imposed by USVI law on executors of estates. + +As the Court noted during the February 4, 2020 hearing (the "February 4 Hearing"), the Co-Executors function as an arm of the Court and are vested by law with the responsibility of administering the Estate. The actual issue before the Court is whether the Program that the Co-Executors seek to implement is consistent with their fiduciary duties. As Your Honor recognized. the Program as originally designed is not only consistent with the fiduciary duties of the Co-Executors, but, in fact "...we agreed that everybody believes this program is a great program..." (February 4 Hearing Tr. at 1 I 3:24-25.) + +Accordingly, the Co-Executors ask that the Court grant their Expedited Motion for Establishment of a Voluntary Claims Resolution Program, filed November 14, 2019, and allow the Co-Executors to move forward with the Program as originally conceived. + +# Background + +More than seven months ago, the Co-Executors sought to establish the Program by interviewing numerous highly-qualified candidates for the role of independent claims program designer and administrator. The individuals selected — Jordana , Kenneth Feinberg. and Camille Biros— are the gold standard, with unparalled experience in that regard.2 Designed and to be implemented by independent, nationally recognized claims administration experts, with input + +I. Government's Status Report. dated March I8.2020 ("Gov't. March I8 Status Report"). at 7 (emphasis supplied). + +{sup}`2.` For a detailed description of their qualifications as well as the function and structure of the Program, see the Co-Executors" Expedited Motion for Establishment of a Voluntary Claims Program, filed November 14, 2019; Request for Ruling on Expedited Motion for Establishment of a Voluntary Claims Resolution Program, filed December 4, 2019; Request for Immediate Hearing or Conference Regarding Expedited Motion for Establishment of a Voluntary Claims Resolution Program, filed December 13, 2019. + +Estate of Jeffrei E Epstein Probate No. ST-19-P8-80 Status Report and Request for Ruling Page 3 + +from interested parties including claimants and their representatives, the Program seeks to timely resolve claims through a process that is sensitive to the experiences and concerns of claimants and treats them with compassion, dignity, and respect. + +On February 4, 2020, the Court held an extensive hearing on the bona fides of the Program, taking detailed testimony. from Program Administrator Jordana and Program Designer Kenneth Feinberg. (February 4 Hearing Tr. at 103:12-186:14.) The Court also heard repeated approval of the Program from the multiple claimants' counsel present at that hearing. (Id. 84: 1 1-85:2; 85:6-19; 92:24-93:8.) As noted above, the Court recognized toward the end of the hearing that the Program is widely viewed as an important, positive step for both claimants and the Estate. (Id. at 113:24-25 ("THE COURT: . .. I think we agreed that everybody believes this program is a great program Only one person, alone among all involved, opposes the Program: the Attorney General.' To hold the Program hostage, the Attorney General issued Criminal Activity Liens freezing the Estate's accounts, including funds necessary to staff and operate the Program.4 + +At the conclusion of the February 4 hearing, the Court urged the Co-Executors and the Attorney General's representatives to see if they could come to an agreement on funding the Program. (Id. 112:4-12; 204:4-10.) Incredibly, the Attorney General tells the Court (twice) that it wrote to the Estate on February 10, 2020, but "received no response."' That is false: on February 12, 2020, counsel for the Estate wrote a six-page letter to the Attorney General addressing each of + +{sup}`3.` See Attorney General's Motion to Intervene, filed January 23, 2020 (attaching Government's Opposition to Estate's Motion for Establishment of a Voluntary Claims Resolution Program). + +{sup}`4.` The Co-Executors have now moved in the Superior Court to vacate those Liens. (See Expedited Motion to Vacate Liens, dated March 17, 2020). + +{sup}`5.` Gov't. March 18 Status Report, at I, 2. + +Estate of fete) E Epstein Probate No ST-19-PB-80 Status Report and Request for Ruling Page 4 + +the points raised in her letter two days earlier. [Exhibit Al And now, more than five weeks later, the Attorney General continues to seek to accomplish her previously-stated goal of scuttling the Program before it has a chance to succeed. + +### Recent Developments + +On February 28,2020, the Attorney General — who has no experience whatsoever with claims resolution programs -- presented the Co-Executors with an eleven-point laundry list of changes she demanded to the Program's funding, structure, and operations.' In their continued effort to make the Program a reality, the Co-Executors agreed to eight of those demands without substantial change; as to the other three, the Co-Executors agreed to the extent their fiduciary duties allow them.' Each of these three latter items is discussed below. + +- 1. The Attorney General Demands that Her Personally-Selected Candidate, a Biased Advocate with No Claims Administration Experience, Become a Co-Equal Prpaam Administrator + +The Attorney General demands that Professor Marci a legal academic in child sexual abuse at the University of Pennsylvania, assume a role in the Program co-equal with as Program Administrator.' But has no experience in mass tort claims resolution, and shoe-horning her into that inappropriate role will force the Estate to incur substantial additional time and expense with no commensurate benefit to the Program. That is not just the Co-Executor's view: the Program Administrator and the Program Designers unanimously + +{sup}`6.` See Gov't. March 18 Status Report. at Exhibit B. + +{sup}`7.` Bizarre/), the Attorne) General reports that she offered the "concessionn" that the Estate's cooperation with law enforcement not be tied to her approval of the Program. (Gov't. March IS Status Report, at 3.) The Co-Executors are extensions of the Court; they neither need nor require the Attorney General's "concession" to uphold their fiduciary duties to the Estate or cooperate with legitimate law enforcement efforts. + +{sup}`8.` See Gov't. March III Status Report. at 2. + +Estate al-affix.). E. Epstein Probate No ST-19-PB-80 Status Report and Request for Ruling Page 5 + +oppose this role for . The Court had the opportunity to hear MM testify about her experience and to explain her efforts to address the views of all those interested in the design and the implementation of the Program. And, before the Attorney General raised candidacy, not a single claimants' counsel raised any concern about qualifications, expertise or independence front the Estate. + +Nor would hiring in the role demanded by the Attorney General be consistent with the Co-Executors' fiduciary duties. outspoken views on the purported criminality of Mr. Epstein and those around him reveal her deep-seated bias against the Estate. It is rich irony that the Attorney General compares proposed role to that of a neutral arbitrator.' In this matter, is as far from a neutral party as one could possibly be: her public statements — on television, in opinion pieces and in multiple news articles — are replete with her strong, loudly-voiced bias against Decedent and anyone who knew him when he was alive, such that she believes the Estate should be drained of all assets without regard to any nexus to individual claims. Here are but a few examples: + +> "It took us 16 years, but New York will be the epicenter for taking down the powerful who sexually abused children in New York. It will start to happen this year — in the civil courts. That is because there is another path that justice will take to force the facts into the public square: On Aug. 14, the one-year look-back window in the New York Child Victims Act will kick into effect. When it does, every girl who was sexually abused through Epstein's scheme will be able to sue for civil damages the ones who caused the abuse. Epstein is wealthy and so are many of his friends who enjoyed spending time partying with him when these girls — lured into doing 'massages' for much-needed cash — were turned into victims of a wealthy sex-trafficking ring. The CVA will level the playing field by handing these women potent legal weapothid.ILLp new world, and it's finally getting close to fair." Marci New York Daily News, July 8, 2019 ("What Jeffrey Epstein's arrest + +{sup}`9.` See Gott. March Ig Status Report. at 2. + +means: it's a sign of how profoundly things have changed for sex abuse victims and perpetrators," available at ). + +- - "Marci [REDACTED], a child sex-abuse expert and founder of the nonprofit think tank CHILD USA, alleges that there's 'no question' that the men who palled around with Epstein must have noticed the presence of underage girls. 'There's also no question that they had to have known that these girls were supposedly providing massages — and that should have been warning bells all over the place,' [REDACTED] added." (Meera Jagannathan, *MarketWatch*, July 14, 2019 ("Amid new Jeffrey Epstein allegations, here's how to help a victim of child sex trafficking," available at ). +- - "Have you noticed that the latest in the Jeffrey Epstein child sex-trafficking scandal has focused on the powerful men involved, from Epstein to President Trump, Alex Acosta, Bill Clinton, Ken Starr, Alan Dershowitz and New York Attorney Geoffrey Berman? To be sure, these men—except for Berman—operated together to empower Epstein to abuse far more girls than he might have otherwise, and that is newsworthy." (Marci [REDACTED], *Miami Herald*, July 14, 2019 ("Epstein's victims deserve to find justice in civil court, too"; available at ). +- - "Basically, this failure to protect children is a political problem across the culture . . . This is outrageous that the [Epstein] victims themselves were not even part of the negotiation process. The arrogance of [ ] Epstein . . . in this situation is overwhelming . . . These women were sexually abused as children, one after the other. Dozens of them . . . This is exactly what is wrong with our society." (Marci [REDACTED], *The Rachel Maddow Show*, December 3, 2018; available at ). + +That is not a criticism of [REDACTED] — as a zealous advocate for children, she is of course entitled to voice her deeply-held beliefs. But it *does* disqualify her as any sort of a "neutral" voice in hearing and determining claims through the Program. + +Estate ofJeffrey E Epstein Probate No. ST-19-P8-80 Status Report and Request for Ruling Page 7 + +Despite obvious bias against the Estate and those around Mr. Epstein, the Co-Executors still sought to find a way in which her expertise on relevant issues might be used to benefit claimants, while at the same time avoiding opportunities for her prejudice to mar the Program Administrator's independent, neutral determinations. In their efforts at continuing compromise. the Co-Executors proposed to the Attorney General that play an extensive consulting role with the Program, a significant concession given bias: + +> "Professor Marci A. a nationally recognized sexual abuse expert. leading legal academic and advocate of victim's rights, will work closely with the Program Administrator to complement the Program's resources. role will be to further inform the Administrator and her staff about the dynamics of sexual abuse, common responses to sexual abuse. and the impact of sexual abuse on victims; to serve as a resource for the Administrator in developing or updating policies and procedures; to advise the Administrator regarding sensitivities involved in interactions with victims; and to serve as a referral source for the Administrator in providing post-determination information to claimants who seek guidance, counseling or other services." + +(See email from Daniel H. Weiner to Linda dated March 16, 2020, annexed as Exhibit D to the Government's March I8, 2020 Status Report.)10 + +Regrettably, the Attorney General rejected that generous proposal out-of-hand in her latest public filing." + +{sup}`10.` While the Attorney General purports t the Co-Executors' proposal, she leaves out entirely this extensive description of the role offered to . (Gov't. March 18 Status Report. at 4.) That is disingenuous in the extreme. + +{sup}`1` I. See Gov't. March 18 Status Report. at 4.5. + +# 2. The Attorney General Demands that the Co-Executors Restrict Funds Available to Claimants Under the Program + +The Attorney General also demands that the Co-Executors "set aside" — i.e., make unavailable to claimants seeking compensation through the Program — \$40 million for the next three years." Restricting the Estate's funds available to pay compensation determinations under the Program is anathema to the Co-Executors — after all, one of the primary attractions of the Program is that all of the Estate's funds are available to it. Removing \$40 million from the Estate's assets available to the Program — on top of the Attorney General's demand that, to ensure she gets paid if she prevails in her CICO action against the Estate, the Estate also "set aside" Little St. James Island, Great Saint James Island, and \$73.1 million in cash for past tax incentives — risks leaving the Program with insufficient funds to make good on its promise of speedy. just compensation. + +As a compromise, the Co-Executors offered to set aside \$25 million in assets for eighteen months, a time period that will extend well beyond the expected term of the Program. The Attorney General did not respond to the Co-Executors' good-faith compromise proposal. + +### 3. The Attorney General Demands that the Co-Executors Report to Her Information Not Required by Virgin Islands Law + +Finally, the Attorney General demands that, in addition to performing their fiduciary duties to the Court by accounting fir all items concerning the Estate in accordance with Virgin Islands law, the Co-Executors also report to the Attorney General on matters and entities outside the probate proceeding. Once again, that is inappropriate: the Attorney General, an active + +{sup}`12` The Attorney General initially insisted that any unused funds from this set-aside be donated to charity. That would constitute a direct breach of the Co-Executors' obligations under Virgin Islands law. + +Estate oPeffrey E. Epstein Probate No ST-19-P8-80 Status Report and Request for Ruling Page 9 + +litigant against the Estate, has no right to usurp the Court's authority to oversee the Co-Executors' administration of the Estate.13 + +• • • + +As the Attorney General continues to prolong her refusal to fund the Program finding one pretext after another to claim she simply wants to improve the Program, while taking actions that would remove over \$200 million from the Program and make it more costly and less effective — the Estate is forced to actively litigate scores of cases that could otherwise have been resolved through the Program. As a result, both claimants and the Estate are expending precious resources that would have been far better used in resolving claims through the Program." + +It is now-or-never for the Program. Accordingly, the Co-Executors Ask the Court to allow the Co-Executors to continue to perform their fiduciary duties, and — for the benefit of all stakeholders in the Estate, including those who seek to participate in the Program — grant their motion to establish the Program as originally conceived and presented to the Court on November 14, 2019. + +{sup}`13.` The Attorney General also takes a cheap shot at Program Designer Kenneth Feinberg, citing nine-year-old criticism of Mr. Feinberg in the BP Deepwater Horizon litigation. (Gov't. March 18 Status Report at 6 and Exhibit E.) Yet the court in that case expressly found that Mr. Feinberg urns -independent" in the sense that BP did not control his evaluation f v' al claims. (Id. Exh. D at p. II.) And Mr. Feinberg is no the Program Administrator here — is. + +{sup}`14.` The Attorney General's interference has forced the Estate to litigate against numerous plaintiffs who would have participated in the Program if they had the opportunity to do so. As we emphasized to the Court at our February 21, 2020 conference, the Co-Executors affirmatively decided to reduce litigation (and the adversity inherent in it) by making the Program available to litigants as well as to those who were harmed but either were not prepared to litigate in a public forum, or barred from recovery through the courts due to statute of limitations or other reasons. The Attorney General's actions have had the unfortunate effect of pitting many plaintiffs against the Estate. That is precisely the opposite of what the Co-Executors sought and the Court endorsed at the February 4 Hearing. + +*Estate of Jeffrey E. Epstein* +Status Report and Request for Ruling + +*Probate No. ST-19-PB-80* +Page 10 + +Respectfully, + +Dated: March 23, 2020 + +/s/ [REDACTED] *Kroblin* +[REDACTED] **KROBLIN, ESQ.** +**ANDREW W. HEYMANN, ESQ.** +**WILLIAM L. BLUM, ESQ.** +**SHARI N. D'ANDRADE, ESQ.** +**MARJORIE WHALEN, ESQ.** +V.I. Bar Nos. 966, 266, 136, 1221 & R2019 +KELLERHALS FERGUSON KROBLIN PLLC +[REDACTED] Palms Professional Building +9053 Estate [REDACTED], Suite 101 +St. [REDACTED], V.I. 00802 +Telephone: (340) 779-2564 +Facsimile: (888) 316-9269 +Email: ckroblin@kellfer.com +aheymann@solblum.com +wblum@solblum.com +sdandrade@kellfer.com +mwhalen@kellfer.com + +*Estate of Jeffrey E. Epstein* +Status Report and Request for Ruling + +*Probate No. ST-19-PB-80* +Page 11 + +**CERTIFICATE OF SERVICE** + +**I HEREBY CERTIFY** that on this 23{sup}`rd` day of March 2020, I caused a true and exact copy of the foregoing **Co-Executors' Status Report on Continuing Efforts to Establish Voluntary Compensation Program and Request for Ruling** to be served via electronic mail upon: + +John H. Benham, Esq. +Law Office of John H. Benham, P.C. +P.O. Box 11720 +St. [REDACTED], VI 00801 +*john@benhamlawvi.com* + +A. Jeffrey Weiss, Esq. +A.J. Weiss & Associates +6934 Vessup Lane +*jeffweiss@weisslaw-vi.net* + +Douglas B. Chanco, Esq. +ChancoSchiffer P.C. +3355 Lenox Road, Suite 750 +Atlanta, GA 30326 +*doug@csfirm.com* + +Sean [REDACTED], Esq. +Marjorie Rawls [REDACTED], P.C. +P.O. Box 6347 +St. [REDACTED], VI 00804 +*sean@marjorierobertspc.com* + +Richard Bourne-Vanneck, Esq. +Law Offices of Richard Bourne-Vanneck +9800 Buccaneer Mall Suite #9 +*richard@rpvblawoffices.com* + +Kevin F. D'Amour +Gaylin Vogel, Esq. +5143 Palm Passage, 18b & 19b +*kevin.damour@comcast.net* +*gaylin.vogel@comcast.net* + +John K. Dema +Law Offices of John K. Dema +1236 Strand Street, Suite 103 +St. Croix, VI +*jdema@demalaw.com* + +Melody D. Westfall, Esq. +Westfall Law PLLC +5032 Anchor Way, Suite 8 +Christiansted, St. Croix 00820 +*mwestfall@westfalllaw.com* + +Denise N. [REDACTED], Esq. +Attorney General +Ariel M. [REDACTED], Esq. +Chief, Civil Division +Virgin Islands Department of Justice +34-38 Krondprinsdens Gade +GERS Complex, 2{sup}`nd` Floor +St. [REDACTED], Virgin Islands 00804 +[REDACTED] + +/s/ [REDACTED] Kroblin + +![](_page_11_Picture_1.jpeg) + +Kellerhals Kroblln vac + +- Palms Protossionol SuIles 9053 Eststo M. Sults 101. St. M. VI 00002 344779.2564 Telephone I 11138318.9269 fa I weneltelltotam + +February 12, 2020 + +BY E-MAIL + +Denise N. Esq. Attorney General Virgin Islands Department of Justice Office of the Attorney General 34-38 Kronprindsens Gade GERS Complex, 2nd Floor St. VI 00802-5749 + +> Re: In the Matter of the Estate of Jeffrey E. Epstein Probate No. ST-19-PB-80 + +Attorney General + +As promised in my e-mail to you dated February 10, 2020, we write in response to your letter sent earlier that day regarding the formation of the voluntary compensation program — officially known as the Epstein Victims' Compensation Program (the "Program") — proposed by the Co-Executors in November 2019 and endorsed by • Superior Court Judge Hermon-Percell and multiple claimants' counsel at the Court's hearing held on February 4, 2020 (the "February 4 Hearing"). We believe your letter misapprehends both the Court's direction to the Co-Executors and the Attorney General's limited role in this matter, and that your suggestions concerning the purpose, structure and administration of the Program are far outside the scope of the single issue as to which the Court requested that we confer. + +# 1. The Program is Designed and Will be Administered by the Nation's Leading Expertsin the Field. + +As your representatives have no doubt reported to you, both Program Administrator Jordana H. and Program Designer Kenneth R. Feinberg testified at length at the February 4 Hearing. Nationally renowned and respected experts in the highly specialized field of mass tort claims resolution, Mr. Feinberg, and their colleague Camille Biros have extraordinary experience in administering programs addressing the Catholic Church's sexual abuse scandal, the Pennsylvania State University sexual abuse scandal, the Boeing 737 Max airplane crashes, the General Motors transmission recall, the Volkswagen diesel emissions scandal, the BP Deepwater Horizon oil spill, the Boston Marathon bombing, the September 11th terrorist attacks, and victims of exposure to Agent Orange, DES and asbestos, as well as several other mass torts. + +Both and Mr. Feinberg testified regarding their absolute independence from the Co-Executors in resolving through the Program claims of sexual abuse against Mr. Epstein, explaining that such independence is the sine qua non of their agreement to design and implement the Program. Far from questioning the capabilities, integrity, or independence of and Mr. Feinberg, the multiple stateside and Virgin Islands counsel for nearly three dozen individual claimants present at the February 4 Hearing supported the Program and the manner in which it was expeditiously developed without exception. + +Other than your counsel, no one in the courtroom (or elsewhere) voiced any objections to the Program, which — as designed by Mr. Feinberg and Ms. Biros — will provide claimants with an entirely voluntary, easily accessible, nonadversarial alternative to protracted civil litigation. As Judge Hermon-Percell appropriately concluded at the February 4 Hearing, the Program has the potential to save enormous amounts of time, risk, and money for both individual claimants and the Estate. + +# 2. The Court Urged the Co-Executors to Consult with the Attorney General on a Single Issue: Providing Adequate Funding for the Program. + +Your Office previously raised several objections to the Program'; each was addressed in detail at the February 4 Hearing. As the testimony of and Mr. Feinberg elucidated, those critiques were either misguided or mistaken, or both. 2 While there are various possible permutations in developing the precise details of a compensation mechanism, the Program designed by Mr. Feinberg and Ms. Biros — with substantial input from claimants' counsel — is cost-effective, fair and just. + +Perhaps most important, the Program is already well underway. As you know, and as and Mr. Feinberg testified, they have been working on the Program + +{sup}`1.` See Opposition to Estate's Motion for Establishment of a Voluntary Claims Resolution Program, dated January 23, 2020. + +{sup}`2.` Your February 10 letter indicates your Office's lingering confusion on certain aspects of the Program. For example, the Co-Executors have not jettisoned the concept of individual claimants signing releases if, and only if, those individuals elect to accept the compensation offered by the Program Administrator. It would be nonsensical for the Co-Executors to do so, since the Estate would otherwise risk being dragged back into litigation through third-party demands for contribution or indemnification. Given the Estate's need for legal finality and claimants' unfettered ability to oursue their claims in other fora, including through the courts, it is no surprise that — as both and Mr. Feinberg testified — such releases are commonplace in mass tort compensation programs. + +since well before the Co-Executors announced the "Establishment of the Epstein Victims Compensation Program" on November 14, 2019 - almost three months ago. As • MI, Mr. Feinberg and counsel for the claimants made clear at the February 4 Hearing, they have been working diligently and cooperatively to develop a Protocol for Judge Hermon-Percell's review and approval. + +Mr. Epstein died on August 10, 2019 - six months ago. You only first expressed disagreement with the Program when you filed your Complaint in the Superior Court on January 15, 2020. You did not seek to intervene in the Probate Court until January 23, 2020 or issue your liens until January 31, 2020. The concerns you now express raise an obvious question as to why you didn't propose a different compensation program before filing these pleadings - which taken together amount to an effort to block or at least substantially delay the Program. You certainly had every opportunity to contact the Co-Executors or Mr. Feinberg, or Ms. Biros and present your concerns and make your suggestions to improve the existing Program, but chose not to do so. And while this is neither the time nor the place to address each of your purported concerns about the Program, it is worth emphasizing that your letter is long on criticisms misplaced in our view — and woefully short on solutions. + +The bottom line is that the claimants have invested in the Program and both the Estate and the claimants are already incurring significant resources unnecessarily litigating while you are delaying the Program. That is something no one who is truly concerned about conserving Estate resources and offering claimants an alternative to litigation should desire. + +As the Co-Executors pointed out in their recent filings in the Superior Courts it is for the Court, not your Office, to oversee administration of the Estate and determine the propriety of the Co-Executors' actions under Virgin Islands law. There is only one point remaining to be discussed: how best to provide adequate funds for the Program. On this issue, the Co-Executors have made their position clear since the outset — they have placed no limits, either individually or in the aggregate, on the compensation that individual claimants may receive under the Program. That is the very best that the Co-Executors can do for existing and potential claimants, as they exercise their fiduciary duties under Virgin Islands law in administering the Estate. Your efforts seem singularly designed to thwart the proper exercise of these fiduciary duties to the substantial detriment of all such claimants. + +As you know, the Co-Executors believe that the liens placed by your Office on the Estate's assets are improper and invalid under Virgin Islands law. It is for that reason that they seek judicial relief from those liens, which if left in place will cause irreparable harm to the Estate's property — including assets that would otherwise be available to fund the Program. Already, the Co-Executors' ability to preserve the Estate's assets have been severely undercut. The enclosed check written to an exterminator needed to preserve one of the properties is the first of what will be many checks to bounce as a result of the lien imposed by your Office on the Estate's operating bank account. This is the first + +{sup}`3.` See Supplemental Brief Regarding Co-Executors' Obligations to Satisfy Expenses of Administration Notwithstanding Liens Issued to "The Estate," dated January 31, 2020; Emergency Motion for Order Releasing Funds for Administration of Estate, dated February 10, 2020. + +of what will become an avalanche of harms to the Estate. Your lien has also stripped the Co-Executors of their ability to meet payroll, and prevents them from paying electric, water, and other basic bills. As a result of your actions, all the Estate's assets - including the islands in SS - will rapidly lose value. Likewise, the impact on the properties in Paris, New York City, and Florida if the Estate is unable to pay for their operating and maintenance expenses will likely be swift and severe. And it will be hard if not impossible to rehire staff once they are forced to seek alternative employment. The harm will be irreparable and substantial. Most disappointing and in disregard of the Court's request, your Office is holding the Program hostage, thereby threatening to derail a vitally important process for claimants to obtain justice. + +The Co-Executors continue to hope that you will reverse your Office's position. In the interests of all concerned, the Co-Executors remain willing to work with you on how best to adequately fund the Program. Time is of the essence if the Program, and the hopes of those women who are eager to use it, are to survive. + +Respectfully, + +cc: Jordan H. Program Administrator + +Kroblin + +7105 3rd Avenue #438 +info@attackexterminating.com +www.attackexterminating.com + +![](_page_17_Picture_93.jpeg) + +BILL TO +NES, LLC +9 East 71st Street +New York, NY 10021 + +INVOICE # 2395 +DATE 01/01/2020 +DUE DATE 01/31/2020 +TERMS Net 30 + +| Monthly Service | 9 East 71st +Street | 1 | 100.00 | 100.00T | +| ----------------- | ----------------------- | --- | -------- | --------- | +| ----------------- | ----------------------- | --- | -------- | --------- | + +| SUBTOTAL | 100.00 | +| ------------- | -------- | +| TAX | 8.88 | +| TOTAL | 108.88 | +| BALANCE DUE | | + +**\$108.88** + +*AL* +*11/22/2020* + +THE PAGE OF THIS DOCUMENT HAS A DISCLOSED AND REVIEWED DESCRIPTION OF THE ENTIRE PAGE OF OFFICIAL DOCUMENT BY CHECK INDEXER OR ARCHIVE WITH PAROCK MEDIA TECHNICALS + +9053 ESTATE [REDACTED] STE 101 + +FIRST BANK +111A-B Cincinnato Gade +101-7285/2216 + + + +DATE 1/22/2020 + +PAY TO THE ORDER OF Attack Exterminating Company LLC + +\$ \*\*108.88 + +One Hundred Eight and 88/100 DOLLARS + +7105 3rd Avenue # 438 + +MEMO +Invoice # 2395 + +AUTHORIZED SIGNATURE + +MP + +![](_page_18_Picture_142.jpeg) + + +1/22/2020 + + + + +First Bank Estate JE Invoice # 2395 + + + +1/22/2020 + + + + +First Bank Estate JE Invoice # 2395 + + +# IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. & ST. JOHN + +IN THE MATTER OF THE ESTATE OF ) JEFFREY E. EPSTEIN, ) ) Deceased. ) PROBATE NO. ST-I9-PB-80 ACTION FOR TESTATE ADMINISTRATION + +# ORDER + +THIS MATTER is before the Court on the Co-Executors' Status Report on Continuing Efforts to Establish Voluntary Compensation Program and Request for Ruling. Having reviewed the Co-Executors' Status Report on Continuing Efforts to Establish Voluntary Compensation Program and Request for Ruling, the Court will grant the same. + +Accordingly, it is hereby: + +ORDERED that the Co-Executors' Status Report on Continuing Efforts to Establish Voluntary Compensation Program and Request for Ruling is GRANTED; and it is further + +ORDERED that the Co-Executors' Expedited Motion for Establishment of a Voluntary Claims Resolution Program is GRANTED; and it is further + +ORDERED that a copy of this Order shall be directed to counsel of record. + +Dated: + +ATTEST: TAMARA CHARLES Clerk of the Court + +BY: + +Court Clerk Supervisor + +CAROLYN P. HERMON-PERCELL Magistrate Judge of the Superior Court of the Virgin Islands \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751802/EFTA02751802.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751802/EFTA02751802.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ca97c794e2c7d7e87f119cafb80c6cc318b90508 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751802/EFTA02751802.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -811, + "dataset": "marker2", + "doc_id": "EFTA02751802", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 21, + "fix_ids": "[\"builtin.empty-image\", \"builtin.table-boundary-padding\", \"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.flight-log-tables.normalize\", \"epstein_legal.redaction-normalization.block-characters\", \"swarm.html-myst-whitelist\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "7c667f3001fdb13bbab721051fe8ed7df9d79cdb6e46318e19650d60c9f87e8f", + "output_sha256": "d533d49144fcafb2b33988ed2e9790d8beb9cc71564bbd05f1cf1294b0a9390e", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751822/EFTA02751822.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751822/EFTA02751822.md new file mode 100644 index 0000000000000000000000000000000000000000..cb30962ab7ff03dc4049c0bd8a57d0e1fd6250eb --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751822/EFTA02751822.md @@ -0,0 +1,314 @@ +#### IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. AND ST. JOHN \*\*\*\*\*\*\*\*\*\*\*\*\* \*\*\*\* \*\*\*\*\*\* \*\*\*\*\*\*\*\*\* + +IN THE MATTER OF THE ESTATE OF JEFFREY E. EPSTEIN, Deceased. PROBATE NO. ST-19-PB-80 ACTION FOR TESTATE ADMINISTRATION + +### CO-EXECUTORS' CORRECTIONS TO ATTORNEY GENERAL'S STATUS REPORT ON VOLUNTARY COMPENSATION PROGRAM AND RENEWED REOUEST FOR RULING + +On March 24, 2020, the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, asked the Court to grant their Expedited Motion for Establishment of a Voluntary Claims Resolution Program, filed November 14, 2019, and allow the Co-Executors to move forward with that Program as carefully constructed in consultation with claimants' counsel and leading independent claims program experts. + +The Co-Executors hereby renew their request. Because the Attorney General of the Virgin Islands has no standing in this Court to seek to re-shape the Program to suit her whims demanding changes that go against the considered views of the Co-Executors, recommendations of nationally recognized experts in the field, and endorsement by multiple claimants' counsel the Court should reject her continued efforts to undermine the Program. As detailed below, the Attorney General's most recent Status Report (filed April 7, 2020) substantially misrepresents the actual state of affairs regarding the Program, and requires correction. + +### 1. The Attorney General Misrepresents Claimants' Position Regarding the Proeram's Third-Party Release + +The Attorney General informs the Court that she and claimants' counsel are aligned on rejecting the third-party release (the "Release") that those claimants who elect to receive + +compensation under the Program would execute. (See 4/7/2020 AG Status Report at 2-3.)' That is false. On the very day that the Attorney General made that (mis)representation to the Court, the two most active claimants' counsel — together, representing by far the largest number of claimants — informed the Co-Executors and the Attorney General that they are prepared to proceed with the Program without change to the existing Release. + +The evidence on this point is undisputed. On the morning of April 7, 2020, David Boies of Boies Schiller Flexner LLP (counsel for at least five prospective claimants) informed the Co-Executors that the existing Release was acceptable as written: + +"1 spoke with [counsel for the Co-Executors] this morning. I am now in agreement that we should move forward with the claims process without trying to further modify the fRJelease. + +I am influenced by the desirability of getting the [P]rograrn underway so that our clients can begin getting compensation; by the fact that the [R]elease will be limited to persons who provided services to Epstein, with the [Rellease signed by individual victims who accept an award having a space to make clear that certain individuals . . . are not released, and by the fact that the release of Epstein's employees/service providers will be taken into account by the [Program] Administrator in setting the amount of the award. And, of course, this is a voluntary process where our clients get to decide whether to be bound after learning the amount of the proposed award." + +(See email from David Boies dated April 7, 2020 to and counsel for the Co-Executors, copy attached here as Exhibit B; emphasis supplied.) + +Claimants' counsels' intent to proceed with the Program including the Release as written was known to the Attorney General before she informed the Court otherwise. On April 6, 2020 — the day before the Attorney General filed her most recent Status Report — lead counsel for some two dozen other prospective claimants told her exactly that. Writing to Mr. Boies, + +{sup}`1.` A copy of the Release, provided on March 16, 2020 by the Co-Executors to the Attorney General and claimants' counsel, is attached hereto as Exhibit A. + +Estate oPerey E. Epstein Probate No. ST-19-PB-80 Co•Executors' Corrections to AG's Status Report & Renewed Request for Ruling Page 3 + +explained his agreement to accept the Release as written, and noted that he had the day before told the Attorney General of that fact: + +"We are now both on the same page. I would like, with your permission to forward that email [i.e., Mr. Boies' email quoted infra, approving the Release as written] to the AG, as l voiced a very similar position to her yesterday." + +(See email from dated April 7, 2020 to David Boies and counsel for the Co-Executors; copy attached as Exhibit C).2 + +It is one thing for the Attorney General, who has no experience or expertise with mass tort compensation programs, to inveigh against the Program. It is quite another for her to misrepresent to the Court that claimants' counsel join in her criticism of the Release. They do not. + +### 2. The Attorney General Misrepresents the Scope of the Release, Which is Designed to Prevent "Double Dipping" by Claimants + +The Attorney General also misrepresents the scope of the Release, asserting that the Estate seeks the release of "any party" who themselves participated in wrongdoing, including "individuals for whom the Estate has no liability." (See 4/7/2020 AG Status Report at 3.) Again, that is false. + +The Release is closely modeled on releases employed in multiple voluntary compensation programs administered by the Program Administrator and Designers, including the sexual abuse scandals currently faced by the Catholic Church. Contrary to the Attorney General's claim, it does not include "any party" who committed wrongdoing, nor have the Co-Executors ever proposed + +{sup}`2.` Both Mr. Boics and the Co-Executors immediately consented to Mr. request Mr. Boies' email with the Attorney General, who thus had both Mr. Boies' and Mr. statements accepting the Release as written before she filed her misleading Status Report with the Court. + +that it would.3 Rather, as the Co-Executors have explained several times to the Attorney General, the Release is aimed at protecting the assets of the Estate by ensuring that an individual claimant does not "double dip" — i.e., she cannot both elect to (1) receive full compensation from the Estate through the Program, and also (2) sue individuals affiliated with the Estate who may well implead the Estate under doctrines of contribution, indemnification, respondeat superior or otherwise.' The Co-Executors' duties under Virgin Islands law require them to protect the Estate's assets, including for the benefit of its creditors and claimants. The Release is indispensable in achieving that result. + +Nor should the Court accept the Attorney General's straw-man formulation that, "[a]ssuming a fairly bargained transaction, the Estate would have to offer increased compensation to victims to secure the third-party release to satisfy claims for which it has no legal responsibility." (4/7/2020 AG Status Report at 4.) As explained above, the Release is not aimed at claims for + +"The Co-Executors of the Estate of Jeffrey E. Epstein (the 'Epstein Estate'), the Co-Trustees of The 1953 Trust, the Epstein Estate, any entities owned or controlled in whole or part by the Estate (the 'Epstein Entities') and their respective current and former principals, officers, directors, stockholders, managers, members, partners, limited partners, trustees, beneficiaries, administrators, agents, employees, attorneys, predecessors, successors, assigns and affiliates, and any entities or individuals who are or have ever been engaged by (whether as independent contractors or otherwise), employed by, worked in any capacity for, or provided any services to Mr. Epstein, the Epstein Entities or the Epstein Estate." (Ex. A at 1-2.) + +The Release specifically provides that it will not release third panics unaffiliated with the Epstein Entities, including individuals specified by the claimant. (Id. at 4.) + +{sup}`3.` The subjects of the Release are limited to the individuals or entities affiliated with or who provided services to Mr. Epstein, as follows: + +{sup}`4.` This is no theoretical risk. On March 12, 2020, one of the primary individuals alleged to have worked as a "recruiter" of young women for Mr. Epstein brought suit in the Virgin Islands against the Estate and the Co-Executors, demanding indemnification. Ghislaine Maxwell v. Estate of Jeffrey E. et at, Civil Case No ST-20-CV-155 (Superior Court of the Virgin Islands, Division of St. and St. John). + +which the Estate "has no legal responsibility". Rather, its function is exactly the opposite: the Release's acknowledged purpose is to avoid having the Estate pulled into litigation by individuals who claim that the Estate is legally responsible for their actions. And, as claimants' counsel Mr. Boies recognized, the Program will properly offer compensation to legitimate claimants that reflects their release of any third parties who are affiliated with Mr. Epstein or the Estate. + +Consistent with their fiduciary duties, the Co-Executors determined that the benefits of including within the Release those individuals who Maxwell has already done) that the Estate bears financial responsibility for the claims against them, substantially outweighs the downside of not requiring a release of those persons. Those downsides include that the Co-Executors would be forced to (1) litigate against the very claimants the Estate will have compensated through the Program and thereby sought to both avoid being adverse to those claimants and incurring the financial costs of litigating against them; (2) litigate alongside persons for harms caused by their alleged conduct for which the Estate has already paid the plaintiff; and (3) pay twice for any harm caused by Mr. Epstein if the damages awarded in that litigation focus not just on the conduct of the released person but also Mr. Epstein's conduct.' + +### 3. The Attorney General Lacks Standing to Re-Shape the Program Developed by the Co-Executors and Experts in the Field + +More than two months ago — but five months after the Co-Executors and the independent claims program experts began working arduously to establish the Program — the Attorney General sought to intervene in this probate proceeding in order to oppose the Co-Executors' + +{sup}`5.` The Court should not credit the Attorney General's bizarre complaint that some claimants "may not even know the identity of their abusers," and thus could not specify them in the liability carve-out of the Release. (4/7/2020 AG Status Report at 3.) None of the 32 claimants who have filed lawsuits to date has been unable to identify her claimed abuser. Moreover, any claimant who cannot identify a purported abuser would not succeed in litigation against that person, since one cannot enforce a money judgment against an unnamed, unknown party. + +implementation of the Program.6 At the hearing on February 4, 2020, during which the Attorney General displayed her disregard for probate procedures and the Court's statutory authority, the Court expressly denied the Attorney General's motion. (February 4, 2020 Hearing Tr. at 98:8-12.) Accordingly, the Attorney General has no standing to demand that the Court re-shape the Program to suit her preferences or priorities. That includes her most recent demand that the Court ignore the Co-Executors, claimants' counsel and acknowledged experts in the field in order to rewrite the text of the Release. + +Just as the Attorney General sought to position herself as a substitute for the Court in reviewing and approving the Co-Executors' regular administration of the Estate, she now seeks to assume the mantle of Program overseer: demanding that her own hand-picked choice (Marci be placed on the Program's payroll; requiring that S25 million from the Estate be made unavailable to pay legitimate claimants through the Program; and rewriting the scope of the Release when everyone but her — including claimants' counsel, whose clients (unlike the Attorney General) would sign the Release — has accepted that Release as written. That is improper. + +The Attorney General has no right to inject herself into the Program, dictating its policies, procedures and administration. To allow her to do so would rob the Program of its independence, one of its most critical attributes. And the Attorney General has no business forcing the Court to act as umpire on each of her dissatisfactions with the Program; as the Court indicated on more than one occasion, it is up to the Co-Executors — acting as duly appointed extensions of the Court — + +{sup}`6.` See Attorney General's Motion to Intervene, filed January 23, 2020 (attaching Government's Opposition to Estate's Motion for Establishment of a Voluntary Claims Program). + +{sup}`7.` The Attorney General's separate CICO action would, if successful, remove an additional approximately \$150 million from the Estate's assets. Her public pronouncements notwithstanding, the Attorney General has never offered to make a penny of those Funds available to victims of sexual abuse. + +Estate obljrey E. Epstein Probate No. ST-19-PB-80 Co-Executors' Corrections to AG's Status Report & Renewed Request for Ruling Page 7 + +to fulfill their fiduciary duties to the Estate. As designed and to be implemented by nationally recognized experts, and as approved by virtually every claimants' counsel, the Epstein Victims' Compensation Program accomplishes that precise goal.' + +As in their March 24, 2020 application, the Co-Executors again ask the Court to allow them to continue to perform their fiduciary duties, and — for the benefit of all stakeholders in the Estate, including those women who seek to participate in the Program — grant their motion to establish the Program as originally conceived and presented to the Court on November 14, 2019. + +Respectfully, + +Dated: April 10, 2020 /s/ Kroblin Est . KROBLIN, ESQ. ANDREW W. HE , ESQ. WILLIAM L. BLUM, ESQ. SHARI N. D'ANDRADE, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar Nos. 966, 266, 136, 1221 & R2019 alms Pro '',es Building HALS KROBLIN PLLC .tS• 1•02 9053 Estate• Suite 101 Telep ce: (340) 779-2564 Facsimile: (888) 316-9269 Email: ckroblin@kellfer.com aheymann@solblum.com wblum@solblum.com sdandrade@kellfer.com mwhalen@kcllfer.com + +a Mr. Boles' co-counsel, Kevin D'Amour, echoed the statements of numerous claimants' counsel at the February 4, 2020 hearing: "I think if we go forward with this program we arc going to see great results and I think we are going to have a much better outcome if we can go forward with this program as soon as possible." (February 4, 2020 Hearing Tr. at 88:15-19.) The Court summarized the view of those present at that hearing, noting as follows: "I think we agreed that everybody believes this program is a great program..." (Id. at 113:24-25.) + +Estate ofJeffrey E. Epstein Probate No. ST-19-PB-80 Co-Executors' Corrections to AG's Status Report & Renewed Request for Ruling Page 8 + +### CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on this 10th day of April 2020,1 caused a true and exact copy of the foregoing Co-Executors' Corrections to Attorney General's Status Report on Voluntary Compensation Program and Renewed Request for Ruling to be served via electronic mail upon: + +John H. Benham, Esq. Law Office of John H. Benham, P.C. P.O. Box 11720 St. a, VI 00801 john@benhamlawvi.com + +Douglas B. Chanco, Esq. ChancoSchiffer P.C. 3355 Lenox Road, Suite 750 Atlanta, GA 30326 doug@afirm.com + +Richard Bourne-Vanneck, Esq. Law Offices of Richard Bourne-Vanneck 9800 Buccaneer Mall Suite #9 St. M, VI 00802 richard®r) pvblawoffices.com + +John K. Dema Law Offices of John K. Dema 1236 Strand Street, Suite 103 St. Croix, VI jdema@demalaw.com + +Denise N. MI Esq. Attorney General Mel M. M, Esq. Chief, Civil Division Virgin Islands Department of Justice 34-38 Krondprinsdens Gade GERS Complex, 2nd Floor St. Virgin Islands 00804 + +A. Jeffrey Weiss, Esq. A.J. Weiss & Associates 6934 Vessup Lane St. M, VI 00802 jejfiveiss@weisslaw-vi.net + +Sean Marjorie Rawls P.C. P.O. Box 6347 St. M, V100804 sean@marjorierobertspc.com + +Kevin F. D'Amour Gaylin Vogel, Esq. 5143 Palm Passage, 18b & 19b St. , VI 00802 kevin.damour@comcast.net gaylin.vogel®comcast. net + +Melody D. Westfall, Esq. Westfall Law PLLC 5032 Anchor Way, Suite 8 Christiansted, St. Croix 00820 mwestfall@westfalllaw.corn + +Is/ Kroblin + +![](_page_8_Picture_3.jpeg) + +## FW: EVCP - General Release + + +Marjorie whalen + +Weiner, Daniel H. Fri, Apr 10, 2020 at 11:58 AM To: mckroblin@kellfercom" , Shari D'Andrade , Marjorie Whalen + +Daniel H. Weiner l Partner + +Hughes Hubbard & LLP + +One Battery Park Plaza. 15th floor I New York. NY 10004-1482 Office +1 (212) 8374874 F CeN +1 (917) 574.3407 Fax .1 (212) 299-6874 daniel.weiner©hugheshubbard.com I Oro + +This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mall. Please notify the sender Immediately by e-mail if you have received this email by mistake and delete this e-mail from your system. E-maJ transmission cannot be guaranteed to be secure or error-free as information could be Intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions In the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version. + +From: Weiner, Daniel H. + +Sent: Monday, March 16, 202010:03 PM + +To: om> + +vi.gov>; 'pamela.tepper vi. ov' ; Francois@vi.govn trad ; + +Srittany@eplIc.corn. ; Chris + +ICroblin CkrOblin@kellfer.comn icscott@motleyrice.comi cscott@motleyrice.com> + +Subject EVCP - General Release + +Linda — + +As requested, we attach a proposed release to be executed by those claimants who elect to accept compensation through the Epstein Victims' Compensation Program. + +Best, + +Dan + +![](_page_8_Picture_23.jpeg) + +![](_page_8_Picture_26.jpeg) + +## EPSTEIN VICTIMS' COMPENSATION PROGRAM ("EVCP") + +### GENERAL RELEASE + +This General Release is made this day of 20 . + +WHEREAS, (the "Claimant"), submitted a claim for compensation to the Epstein Victims' Compensation Program ("EVCP") asserting that she is a victim of sexual abuse by Jeffrey E. Epstein; and + +WHEREAS, the EVCP Program Administrator (the "Administrator") determined pursuant to the EVCP Protocol that Claimant is eligible to participate in the EVCP; and + +WHEREAS, after reviewing Claimant's submissions and after careful consideration of documentation and proof, and after due deliberation, the Administrator issued a compensation determination to Claimant ("Compensation Offer"); and + +WHEREAS, several jurisdictions within the United States have enacted claims revival statutes concerning the timeliness of claims of sexual abuse; and + +WHEREAS, Claimant is aware that, by accepting this Compensation Offer from the EVCP, Claimant waives and releases certain individuals and entities from any and all claims or causes of action arising from Mr. Epstein's conduct, whether pursuant to claims revival statutes or otherwise; and + +WHEREAS, after careful consideration of the proposed Compensation Offer, including consultation with her legal counsel regarding the Compensation Offer, Claimant informed the Administrator that Claimant has decided to accept the Compensation Offer. + +### NOW THEREFORE, + +Claimant, , for and on behalf of herself and her heirs, devisees, legatees, distributees, executors, administrators, trustees, personal representatives, successors and assigns (collectively, "Releasor"), for and in consideration of Dollars (\$ ) (the Compensation Offer) to be received from the EVCP, the adequacy and sufficiency of which are hereby acknowledged, hereby releases and forever discharges the Co-Executors of the Estate of Jeffrey E. Epstein (the "Epstein Estate"), the Co-Trustees of The 1953 Trust, the Epstein Estate, any entities owned or controlled in whole or part by the Epstein Estate (the + +"Epstein Entities") and their respective current and former principals, officers, directors, stockholders, managers, members, partners, limited partners, trustees, beneficiaries, administrators, agents, employees, attorneys, predecessors, successors, assigns and affiliates, and any entities or individuals who are or have ever been engaged by (whether as independent contractors or otherwise), employed by, worked in any capacity for, or provided any services to Mr. Epstein, the Epstein Entities or the Epstein Estate (jointly and severally, the "Releasees"), from any and all claims, demands, actions, causes of action, suits, debts, dues, sums of money, accounts, variances, trespasses, damages and judgments, whether sounding in equity, tort, common law, contract, statute, regulation or otherwise and whether now existing, hereafter existing or revived in the future whatsoever in law, admiralty, equity or otherwise, including without limitation any and all claims or causes of action that arise or may arise from or which otherwise concern acts of sexual abuse by Mr. Epstein (the "Claims") which against the Releasees, Releasor ever had, now have or hereafter can, shall or may have, for, upon, or by reason of any matter, cause or thing whatsoever from the beginning of the world through the date of this General Release. + +This General Release is a broad release of any and all Claims of Releasor against any and all Releasees, including without limitation any and all causes of action, lawsuits, claims, demands, damages and liability whatsoever, and also including without limitation to the extent of their respective liability for the same, any and all such claims against any and all Releasees for contribution as to any other person or persons who may be determined to have been joint tortfeasors arising out of or in any way related to any and all known and unknown personal injuries, and also including without limitation any derivative claims for loss of consortium, under any federal, state or local law, without limitation. This General Release is all-encompassing and is specifically made and given on the premise that any and all Claims by Releasor are hereby released and extinguished, whether said Claims arose in Florida, New Mexico, New York, the United States Virgin Islands, France or any other country, state, territory, possession or jurisdiction, or otherwise. + +This General Release extends to released Claims that Releasor does not know or suspect to exist in her favor, which, if known by Releasor, would have materially affected her decision to enter into this General Release, and Releasor understands and agrees that she is releasing any and all such unknown or unsuspected Claims in Releasor's favor. Releasor acknowledges that she is familiar with Section 1542 of the California Civil Code, which provides as follows: + +A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE AND THAT, IF KNOWN BY HIM OR HER, WOULD HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR OR RELEASED PARTY. + +Releasor expressly waives and relinquishes any right or benefit that Releasor has or may have under Section 1542 of the California Civil Code and under any other statute or legal principle with similar effect. In connection with such waiver and relinquishment Releasor acknowledges that she is aware that, after executing this General Release, Releasor or Releasor's attorneys or agents may discover released Claims or facts in addition to, or different from, those which they now know or believe to exist with respect to the subject matter of this General Release, but that it is Releasor's intent hereby to fully, finally and forever settle and release all of the Claims, whether known or unknown, suspected or unsuspected, which now exist, may exist, or heretofore may have existed. In furtherance of this intent, this General Release shall be, and remain in effect as, a full and complete release of the Claims notwithstanding the discovery or existence of any such additional or different Claims or facts. + +The Administrator of the EVCP has retained to confirm that the Centers for Medicare and Medicaid Services ("CMS") and Medicaid will not assert any reimbursement claim or lien with respect to compensation awarded to any participating claimant under the EVCP; provided, however, that if either entity does assert any such interest, is hereby authorized to act on behalf of the EVCP to verify and resolve such lien or reimbursement claim. Releasor agrees to allow the Administrator to provide to certain information as to Releasor, including: (1) first name, last name and middle initial, (2) Social Security number; (3) date of birth, (4) gender and (5) basic information regarding the nature of Releasor's Claims, and hereby authorizes the Administrator and to use, exchange and report this information to Medicare, if necessary, for purposes of ensuring compliance with the Medicare Secondary Payer Act 42 U.S.C. § 1395(y)(b), and its accompanying regulations. + +Releasor represents and acknowledges that she is voluntarily and freely granting this General Release in exchange for payment of the Compensation Offer, and that she is legally competent to execute and deliver this General Release. Releasor further represents that she is represented by legal counsel and has received legal advice prior to entering into this General Release and that she has been advised by said attorney regarding the terms and conditions of this General Release, which she has completely read and fully understands, including that accepting the Compensation Offer and signing + +this General Release is a full and final compromise, adjustment and resolution of any and all Claims that Releasor may now have or ever will have against Releasees. + +Pursuant to the EVCP Protocol, the Administrator will maintain the confidentiality of all information and documentation relating to claimants who participate in the EVCP Program. This General Release does not require participating claimants to maintain such confidentiality and Releasor may — at Releasor's voluntary and sole option — disclose such information regarding the claims process and/or the Compensation Offer and any other information pertaining to her claim. + +This General Release specifically does not include as a Releasee or released party under this Agreement, and all parties expressly acknowledge, agree and understand that any and all claims that Releasor has or may have against are expressly preserved. + +Releasor represents and warrants that she has not assigned any Claims released pursuant to this General Release. + +As soon as is reasonably practicable after payment of the Compensation Offer is made, and in no event later than three (3) business days from the date thereof, Releasor will dismiss with prejudice any legal actions — whether lawsuits, probate claims or otherwise - that Releasor has filed against any of Releasees, with each party to bear her, his or its own costs and attorneys fees. + +This General Release contains the entire understanding of the Releasor and the Co-Executors of the Epstein Estate. Any modification of any of the provisions of this General Release shall be effective only if made in writing and executed by Releasor and the Co-Executors of the Epstein Estate with the same formality as this General Release. + +IN WITNESS WHEREOF, Claimant has executed this General Release on the date below her signature. + +(Signature: Claimant) + +(Date) + +STATE OF ) + +COUNTY OF + +ss: + +On , 20\_, before me personally came to me known, who, by me duly sworn, did depose and say that deponent is the Releasor who executed the foregoing General Release. + +Notary Public + +Reviewed and approved: + +Type (or print) Name of Claimant + +Attorney for Releasor: + +Type (or print) Name of Attorney: + +Signature: + +![](_page_15_Picture_3.jpeg) + +# FW: Where we are + + +Weiner, Daniel H. Fri, Apr 10, 2020 at 12:00 PM + +To: "ckroblin@kellfer.com" , Shari D'Andrade , Marjorie Whalen + +Daniel H. Weiner l Partner + +Hughes Hubbard & LLP + +One Battery Park Plaza, 15th Boor I New York, NY 10004-1482 + +Office 41 int 837-68741 Cell +1 (917) 574.34071 I Fax +1 (212) 299-6874 + +weinerahugheshubbard.com I bio + +This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mall. Please notify the sender Immediately by e-mail If you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as Information could be Intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the • 'rise as a result of e-mail transmission. If verification is required please request a hard-copy version. + +—Original Message— + +From: David Boies < -n> + +Sent: Tu ril 7, 2020 10:48 AM + +To: Brad < Litt eplIC.COM> + +Cc: Weiner, aniel H. ; Andrew Tombad«andrew.tomback@whitecase.com> + +Subject: Where we are + +CAUTION: This email was sent by someone outside of the Firm. + +I spoke with Dan and Andy (whom I am copying) this morning. I am now in agreement that we should move forward with the claims process without trying to further modify the release. I am influenced by the desirability of getting the program underway so that our clients can begin getting compensation; by the fact that the release will be limited to persons who provided services to Epstein, with the lease signed by individual victims who accept an award having a space to make clear that certain individuals (e.g., Prince Andrew or others to whom our clients were trafficked) are not released; and by the fact that the release of Epstein's employees/service providers will be taken into account by the Administrator in setting the amount of the award. And, of course, this is a voluntary process where our clients get to decide whether to be bound after learning the amount of the proposed award. + +![](_page_15_Picture_24.jpeg) + +![](_page_16_Picture_3.jpeg) + +# FW: Where we are + + +Marjorie whalen + +Weiner, Daniel H. Fri, Apr 10, 2020 at 12:02 PM + +To: "ckroblin@kelifer.com" . Shari D'Andrade . Marjorie Whalen + +Daniel H. Weiner j Partner + +Hughes Hubbard &MLLP + +One Battery Park Plaza. 151h floor I New York, NY 10004-1482 Office +1 (212) 837-6874 I Cell +1 (917) 574-3407 Fax +1 (212) 299-6874 dantel.wetnenghugheshubbard.com bio + +This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail If you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions In the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version. + +—Original + +From: Brad + +Sent: Tuesday, April 7, 2020 11:00 AM + +To: David Boies + +Cc: Weiner, Daniel H. ; Andrew Tomback + +Subject: Re: Where we are + +CAUTION: This email was sent by someone outside of the Firm. + +We are now both on the same page. I would like, with your permission, to forward that email to the AG, as I voiced a very similar position to her yesterday. + +Sent from my iPhone + +> On Apr 7, 2020, at 10:48 AM, David Boies wrote: + +> I spoke with Dan and Andy (whom I am copying) this moming. I am now in agreement that we should move forward with the claims process without trying to further modify the release. I am influenced by the desirability of getting the program underway so that our clients can begin getting compensation; by the fact that the release wig be limited to persons who provided services to Epstein, with the lease signed by individual victims who accept an award having a space to make clear that certain Individuals (e.g., Prince Andrew or others to whom our clients were trafficked) are not released; and by the fact that the release of Epstein's employees/service providers will be taken into account by the Administrator in setting the amount of the award. And, of course, this is a voluntary process where our clients get to decide whether to be bound after learning the amount of the proposed award. + +![](_page_16_Picture_25.jpeg) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751822/EFTA02751822.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751822/EFTA02751822.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..9c8ea466b9a581ddbcaa70627ad8d4af601f9ccc --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751822/EFTA02751822.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -58, + "dataset": "marker2", + "doc_id": "EFTA02751822", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 2, + "fix_ids": "[\"swarm.html-myst-whitelist\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "41a87582a94eb327ff6a8eab97590f7deb59f875aa0653a98b32390db2e380c7", + "output_sha256": "70d1e6dd786278dc47bba3f4868cefc33bd565a9704e3b0c20c5cf33fd9a31e9", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751839/EFTA02751839.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751839/EFTA02751839.md new file mode 100644 index 0000000000000000000000000000000000000000..0a2188fffb7e42bd48123a2eedbc1ebbe9b68206 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751839/EFTA02751839.md @@ -0,0 +1,43 @@ +Bennet J. Moskowitz D: 212-704-6000 bennet.moskowitz@troutman.com + +April 15, 2020 + +## VIA ECF + +Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl Street New York, New York 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-MKV-DCF + +Dear Judge Freeman: + +We represent Defendants Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein, in the above-referenced actions. We write in sa to the "Status "dated April 15, 2020, submitted by plaintiffs' counsel, Brad and Brittany, to Your Honor (ECF Doc. 27). + +Mr. letter is accurate in several important respects: + +First: The Co-Executors have — with no legal obligation to do so — worked hard for more than five months to establish an independent and voluntary claims resolution program, titled the "Epstein Victims' Compensation Program," for purposes of resolving sexual abuse claims against Mr. Epstein. If the Program fails to launch, it will be an extraordinary lost opportunity for eligible claimants to receive compensation and voluntarily resolve their claims through a confidential, non-adversarial alternative to litigation. + +Second: After interviewing several potential candidates to design and administer the Program, the Co-Executors selected the nationally acclaimed trio of Jordana , Kenneth Feinberg and Camille Biros, who have designed, implemented and administered extensive mass tort compensation programs including the September 11th Victim Compensation Fund, those involving the Roman Catholic Church sex-abuse scandals, the BP Deepwater Horizon oil spill in the Gulf of Mexico, the Agent Orange toxic chemical matter, and several others. (Mr. Feinberg in particular had been suggested by some plaintiffs' counsel for such a role in the Epstein matter.) While some plaintiffs' counsel had their own preferred candidat n n h challenged the integrity, independence or extraordinary Qualifications of , Mr. Feinberg and Ms. Biros. As Mr. themselves note, they have "gained confidence in the Estate selected Administrator, Jordana and believes + +![](_page_1_Picture_11.jpeg) + +**she is best suited to serve in the role as Program Administrator."** (ECF Doc. 27 p. 2 (emphasis added).) + +Third: The Attorney General of the United States Virgin Islands, Denise [REDACTED], is the only person who has consistently sought to defeat the Program, filing in the Superior Court of the Virgin Islands her proposed opposition to that Program on January 23, 2020 – months after the Co-Executors and plaintiffs' counsel had worked tirelessly to commence it – and later that month imposing broad liens on the Epstein Estate's bank accounts, thereby preventing the Co-Executors from funding the Program. As Mr. [REDACTED] accurately observe, **"counsel for the victims agreed with the Program moving forward as it was prior to the Attorney General's intervention."** (*Id.* (emphasis added).) Although the Epstein Estate is being probated in the Virgin Islands (where Mr. Epstein resided at his death and where he beneficially owned real property for many years before then), there are no known claimants residing there—Attorney General [REDACTED] has never suggested otherwise. + +In other respects, however, Mr. [REDACTED] omit facts important to understanding Attorney General [REDACTED] improper efforts to re-shape the Program to her own liking. As envisioned by the Program, legitimate claimants will be able to learn the Program Administrator's compensation determination in their cases – made entirely independent of the Estate, and not subject to its review – before electing whether to accept it. Only if a claimant decides to accept that compensation would she execute a release of the Estate, the Co-Executors and a defined group of individuals and entities affiliated with Mr. Epstein; importantly, **third parties unaffiliated with Mr. Epstein would not be released.** Plaintiffs' counsel has accepted that proposed release: as Mr. [REDACTED] notes, **"we have confidence and trust in the Program Administrator and her independence from the Estate and the fact that the claimants will have lawyers to advise them about the pros and cons of any settlement, including what she may be giving up.** In that sense, the Program as designed, despite a less than optimal proposed release, is better than no program at all." (*Id.* at p. 4 (emphasis added).) + +While such a third-party release is standard practice in mass tort compensation programs -- the one contemplated by the Program is in fact modeled on the release used in the Catholic Church compensation programs -- Mr. [REDACTED] clients would no doubt prefer no release at all, or one that would permit them to "double dip" by collecting from the Estate twice: once under the Program and again by suing persons who would implead the Co-Executors under theories of indemnification, contribution, respondeat superior or otherwise. The Co-Executors' fiduciary obligations to the Estate under Virgin Islands law – and, indeed, common sense – do not permit them to allow such limitless exposure. + +As another example of Mr. [REDACTED] mischaracterizations, while the Co-Executors readily accepted the suggestion of University of Pennsylvania law professor Marci [REDACTED] as a consulting resource for the Program Administrator on issues of child sexual abuse, they could not in the proper discharge of their fiduciary duties accede to Attorney General [REDACTED] insistence that [REDACTED] occupy a co-equal role with [REDACTED] as Co-Program Administrator. [REDACTED] has no experience administering mass tort compensation programs and has repeatedly publicly inveighed against those associated in any way with Mr. + +Epstein.' She is a zealous advocate, and not a neutral fact-finder to whom the Co-Executors could properly defer decision-making authority in distributing Estate funds to resolve claims against the Estate. + +Finally, there is no need for the relief that Mr. now request — i.e., this Court's intervention in the Co-Euratart ongoing efforts in the Virgin Islands to establish the Program over Attorney General repeated efforts to eviscerate it. The Co-Executors have sought the approval of the Superior Court of the Virgin Islands to establish the Program, and are awaiting a ruling from the Honorable Carolyn Hermon-Percell so that they can finally move forward wit Si• - Program as originally presented to that court in November 2019 and approved by Mr. and multiple other plaintiffs' counsel. (We attach a copy of the Co-Executors' two most recent filings on that subject with the USVI court, dated March 24 and April 10, 2020.) We will of course keep Your Honor informed of the outcome of that application. + +Respectfully submitted, + +s/Bennet J. Moskowitz Bennet J. Moskowitz + +cc: Counsel of Record (via ECF) + +{sup}`&#`x27; See, e.g., Marci A. , Jeffrey Epstein and His Enablers Are Evil, But Not Special: He's Just the Latest Example of a Toxic Culture for Children (Jul. 15, 2019) (available at: h Jlv 'cl.'ustia.com/2019/07/15/jeffrey-epstein-and-his-enablers-are-evil-but-not-special), in which states: "One person alone could not have accomplished the full scope of Epstein's scheme. You need help to successfully abuse dozens and hundreds of children, and everyone needs to pitch in to make it a success." \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751839/EFTA02751839.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751839/EFTA02751839.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1575312ca08001d408664206673ef55e54a591be --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751839/EFTA02751839.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -4, + "dataset": "marker2", + "doc_id": "EFTA02751839", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 1, + "fix_ids": "[\"swarm.html-myst-whitelist\"]", + "idempotent": true, + "input_sha256": "dec07382dc605d2ce2d34ae2ca71a2c8180c9e56481b85dae81e44bd0411bf81", + "output_sha256": "eedb6fd4878c18a7857ad55e19b004ebed50b5dca1e0e6bb5ec4cc7b0aeb2cfa", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751842/EFTA02751842.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751842/EFTA02751842.md new file mode 100644 index 0000000000000000000000000000000000000000..53ba8382143d1b56c66901f8f1f4d0caedc9b39b --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751842/EFTA02751842.md @@ -0,0 +1,25 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +ANASTASIA DOE, + +Plaintiff, + +v. DARREN . INDYKE AND RICHARD D. KAHN AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, + +Defendants. + +Case No. 1:19-cv-11869 + +## NOTICE OF APPEARANCE + +PLEASE TAKE NOTICE that the undersigned attorney hereby appears as counsel for defendants Darren,. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein in the above-captioned action. I certify that I am admitted to practice in this Court. All notices given or required to be given in this case shall be served upon the undersigned. + +Dated: New York, New York. May 12, 2020 + +By: /s/ Charles L. Glover + +Charles L. Glover TROUTMAN SANDERS LLP 875 Third Avenue New York, NY 10022 212.704.6000 Charles.Glover@troutman.com + +Attorneys for Defendants + +To: All Counsel of Record (via ECF) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751842/EFTA02751842.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751842/EFTA02751842.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..2d1ffac4171cf1a5a924ee2e7a0c7dad2382bb15 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751842/EFTA02751842.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751842", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "abd7c1c5346e54407bf5fc2cd813d72a3b7fdeca566ed676f1a511d5c70b8b6e", + "output_sha256": "abd7c1c5346e54407bf5fc2cd813d72a3b7fdeca566ed676f1a511d5c70b8b6e", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751843/EFTA02751843.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751843/EFTA02751843.md new file mode 100644 index 0000000000000000000000000000000000000000..8cf3e880cdc8ac9f8bd8ee9ba084be718b020c89 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751843/EFTA02751843.md @@ -0,0 +1,320 @@ +Bennet J. Moskowitz bennet.moskowitz@troutman.com + +June 1, 2020 + +ECF + +Hon. Debra C. Freeman Thurgood Marshall United States Courthouse 500 Pearl Street 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-MKV-DCF + +Dear Judge Freeman: + +We represent Defendants in the above-referenced actions. We write on behalf of all parties to update the Court regarding settlement and discovery. + +As the Court is aware, there have been no settlement discussions in any of the individual above-referenced cases. The parties' efforts regarding settlement have been singularly focused on the establishment of a voluntary, independent claims resolution program, the Epstein Victims' Compensation Program. We are pleased to report that, this past weekend, the Co-Executors entered into a tripartite agreement with claimants' counsel (specifically, counsel for Plaintiffs in the above-referenced actions, Brad , and counsel for plaintiffs in four other actions pending before Your Honor, David Boies) and the Attorney General of the United States Virgin Islands pursuant to which the Program may now move forward. Earlier today, the Co-Executors of the Estate of Jeffrey E. Epstein filed in the Superior Court of the Virgin Islands the status report attached hereto as Exhibit A. As stated therein, the Co-Executors, with the support of claimants' counsel and the USVI Attorney General, intend to authorize commencement of the Program on Monday, June 15, 2020. Most, if not all, of the Plaintiffs in the above-referenced actions intend to participate in the Program. + +Meanwhile, the parties continue to meet and confer in efforts to resolve various discovery disputes. + +Thank you for your attention to this matter. + +Respectfully submitted, + +s/Bennet J. Moskowitz Bennet J. Moskowitz + +# EXHIBIT A + +o c•-) - o rn •Z sr; -to A-4 V. + +# IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS %•,-) DIVISION OF ST. & ST. JOHN S + +IN THE MATTER OF THE ESTATE OF ) PROBATE NO. ST-19-PB-80 JEFFREY E. EPSTEIN, + +Deceased. + +)) + +ACTION FOR TESTATE ADMINISTRATION + +#### CO-EXECUTORS' STATUS REPORT ON VOLUNTARY COMPENSATION PROGRAM AND PRESENTATION OF PROGRAM PROTOCOL + +On November 14, 2019, the Co-Executors of the Estate of Jeffrey E. Epstein (the "Co-Executors") filed their Expedited Motion for Establishment of a Voluntary Claims Resolution Program (the "Expedited Motion") seeking to establish an independent and voluntary claims resolution program (the "Program") for purposes of resolving sexual abuse claims against Jeffrey E. Epstein, deceased. As promised in the Expedited Motion, the Co-Executors now submit to the Court the detailed Program protocol (the "Protocol," copy attached as Exhibit A hereto) designed and developed over several months by independent, nationally recognized claims administration experts with extensive input from the Co-Executors and other interested parties, including claimants and their legal representatives. Because the need for the Program has grown increasingly urgent and with the support of claimants' counsel and the Attorney General of the United States Virgin Islands, the Co-Executors intend to authorize commencement on Monday, June 15, 2020 of formal claims resolution proceedings under the Program, absent contrary direction from the Court. + +#### I. BACKGROUND + +As detailed in the Expedited Motion and the Co-Executors' subsequent filings with the Court, the Program will provide all eligible claimants an opportunity to receive compensation and voluntarily resolve their claims of sexual abuse against Mr. Epstein through a confidential, nonadversarial alternative to litigation, utilizing a process that is sensitive to the experiences and concern of claimants and treats them with compassion, dignity and respect.' + +On February 4, 2020, the Court heard extensive witness testimony concerning the Program (February 4, 2020 Hearing Tr. at 103:12-186:14); at that hearing, multiple claimants' counsel also spoke in favor of implementing the Program. (Id. 84:11-85:2; 85:6-19; 92:24-93:8.) As Your Honor recognized, the Program is not only consistent with the fiduciary duties of the Co-Executors. but in fact "...we agreed that everybody believes this program is a great program..." (Id. at 113:24-25.) That drumbeat of approval continues to swell; since the Co-Executors' most recent filing with the Court concerning the Program,2 counsel for 69 individual claimants have come forward to the Court in support of the Program.3 + +- I. Expedited Motion at I; see also Co-Executors' Request for Ruling on Expedited Motion for Establishment of a Voluntary Claims Resolution Program (filed December 4, 2019); Co-Executors Request for Immediate Hearing or Conference Regarding Expedited Motion for Establishment of a Voluntary Claims Resolution Program (filed December 13, 2019); Co-Executors' Reply to Creditor Jane Doe's Response to Co-Executors' Expedited Motion for Establishment of a Voluntary Claims Resolution Program (filed January 15, 2020); Co-Executors Reply to Government's Opposition to Estate's Motion for Establishment of a Voluntary Claims Resolution Program (filed January 31, 2020); Co-Executors' Status Report on Continuing Efforts to Establish Voluntary Compensation Program and Request for Ruling (filed March 24, 2020); Co-Executors' Corrections to Attorney General's Status Report on Voluntary Compensation Program and Renewed Request for Ruling (filed April 10, 2020). +- 2. Co-Executors' Notice of Related Filing, dated April 17. 2020 (attaching Co-Executors' correspondence with claimants' New York counsel concerning commencement of the Program). +- 3. See Status Report from Claimants dated April 20, 2020 (urging on behalf of 12 claimants that "the Program can and should proceed without delay"): Status Report from Claimants dated April 21, 2020 (stating on behalf of S claimants that "permitting the Program to proceed would be in the best interests of the victims at this time"): Motion for Status Conference Regarding the Victim Compensation Program dated April 28, 2020 (seeking on behalf of 52 claimants an Order "permitting the Program to proceed as agreed amongst the parties"). + +# U. THE PROGRAM PROTOCOL + +The Program Administrator and Designers have now finalized the Protocol for the Program, in close consultation with claimants' counsel and the Co-Executors.' As contemplated in the Expedited Motion, the Protocol sets forth the following non-exclusive guiding principles: + +- The Program is purely voluntary. It does not affect any rights a claimant may have unless and until she accepts the offered compensation and executes a release. A claimant may reject the offer of compensation and may stop participating in the Program and withdraw the claim at any time prior to execution of the release. +- The Program is independent and will in no way be administered, controlled, or overseen by the Co-Executors. The Program Administrator is responsible for all decisions relating to the review, processing and evaluation of individual claims submitted to the Program. The Administrator will have final, binding, and exclusive authority to determine claimant eligibility and the valuation of each eligible individual claim. Decisions of the Administrator made pursuant to the Protocol are not subject to review or modification in any way by the Co-Executors or any other party or entity. +- Subject to total Estate assets available, there is no cap or limitation on the aggregate amount of funds available to compensate all eligible claimants or on the amount of compensation to be made to each individual claimant. Each individual claim will be evaluated separately by the Program Administrator. The Administrator will determine, in her sole and exclusive discretion, issues of eligibility and the amount of compensation and the Estate will pay all eligible claims based on the Administrator's determination. +- All claimants will be treated with respect, dignity, and fairness without regard to race, color, sexual orientation, national origin, religion, gender, or disability. To ensure claims will be adjudicated fairly, the Program Administrator will manage the process so that all claimants can equally access the Program's claim process. Individuals with disabilities will be given the opportunity to effectively communicate their claims and to request special process accommodations. + +(See Protocol at pp. 1-2.) + +{sup}`4.` The Attorney General of the U.S. Virgin Islands also expressed her detailed views on the structure and formation of the Program, both through filings with the Court and direct communications with the Program Administrator. + +The Protocol also sets forth detailed aspects of the Program's administration, including eligibility criteria for the Program, proof requirements and claims procedures, the methodology for claims evaluation and determining compensatory awards, and timing and regular reports to the Court, as follows: + +- Eligibility. The Protocol identifies the criteria to determine whether a claimant is eligible to receive compensation under the Program. (See Protocol at pp. 3- 4.) +- Proof Requirements and Claims Procedures. The Protocol determines what types of supporting documentation or other evidence each individual will be required to submit to substantiate her claim, satisfy Program requirements, and allow the Program Administrator to review, process and evaluate that claim. (See Protocol at pp. 4-5.) +- Claims Evaluation and Determination Methodology. The Protocol defines the factors and considerations to be used to determine the amount of compensation to be offered to any eligible claimant. (See Protocol at pp. 5-6.) +- Timing. The Protocol sets forth the timeframe of the Program, including an effective commencement date and deadline for submission of all claims. (See Protocol at pp. 4-5.) +- Reporting. The Protocol reflects the Program Administrator's commitment to provide the Court with regular monthly reports regarding the aggregate number and total value of claims paid each month through the Program. (See Protocol at p. 9.) + +# III. URGENT NEED TO COMMENCE OF PROGRAM OPERATIONS + +In their fiduciary capacity, the Co-Executors engaged in extensive discussions with relevant parties in interest regarding the independent, fair, and timely resolution of the sexual abuse claims against Mr. Epstein. As noted above, many existing and potential claimants have expressed through their representatives their preference to participate in the Program rather than proceeding with litigation. Although there will be significant expense in administering the Program, the Co-Executors contemplate that the Program will substantially reduce the expenses to the Estate of litigating multiple lawsuits in numerous jurisdictions, and thus ultimately reduce expenses to the + +Estate of Jeffrey E. Epstein Co-Executors' Status Report on Voluntary Compensation Program and Presentation of Program Protocol + +Probate No. ST-19-P8-80 Page 5 + +benefit of all panics with an interest in the Estate, including claimants and creditors.s The expedited nature of the Program will also ensure resolution and compensation to claimants in a far more timely manner than through litigation. + +As described above, the Protocol is designed to ensure the proportionate restitution of approved claims for all claimants, in a manner that will provide similar compensation to similarly situated claimants. The Program is in the best interests of both claimants and the Estate because, among other things, it avoids the potential of disproportionate and inconsistent awards and should help to reduce the time, exposure and burden of handling claims through the courts, which could involve years of litigation and appeals and consume enormous resources, along with inflicting on all affected parties costs attendant to delay and uncertainty. + +# IV. FUNDING FOR THE PROGRAM + +As the Court is aware, the Attorney General on January 31, 2020 unilaterally imposed criminal activity liens on the Estate's bank account in the Virgin Islands, freezing then-available funds — funds over which this Court has exclusive jurisdiction — for administration of the Estate and implementation of the Program.6 On February 24, 2020, the Attorney General imposed similar liens against Southern Trust Company, Inc., one of the entities within the Estate. The Co-Executors have challenged the validity of the Attorney General's liens, and moved the Superior + +{sup}`5.` In the absence of the Program, litigation alleging sexual abuse by Mr. Epstein has increased in scope, pace and expense: there are now 22 separate lawsuits brought by 34 individual claimants pending against the Co-Executors, primarily in the state and federal courts of New York. Discovery proceedings in those actions including document demands, interrogatories, non-party subpoenas, and motions to compel — continue to ratchet up each passing week. + +{sup}`6.` Following the Co-Executors' resulting emergency motion for release of funds necessary for administration of the Estate, the Court directed the Attorney General to lift her liens in amounts sufficient to allow the Co-Executors to pay the Estate's operational expenses and legal fees. + +Court to vacate them in their entirety.' However, pending determination of that motion — as well as this Court's approval of the estimated budget for and expenses of designing, implementing and administering the Program, submitted by the Co-Executors on February 4, 2020 — the Co-Executors and the Attorney General have reached consensual resolution in which the latter will promptly lift those liens to pay amounts owed for the Program and to begin funding of the Program's active operations, including payment of compensation determinations to eligible claimants.° + +• • • • + +Because the need for the Program has grown increasingly urgent, and with the support of claimants' counsel and the USVI Attorney General — and because the remaining impediments have been resolved and the interested parties have consented to the Protocol attached as Exhibit A hereto — the Co-Executors intend to move forward with the Program on Monday, June 15, 2020, absent contrary direction from the Court.9 + +Dated: June I, 2020 + +Respectfully, + +in KROBLIN, ESQ. ANDREW W. HEYMANN, ESQ. WILLIAM L. BLUM, ESQ. SHARI N. D'ANDRADE, ESQ. MARJORIE WHALEN, ESQ. + +{sup}`7.` See Expedited Motion to Vacate Liens, dated March 17, 2020 (Government of the U S. Virgin Islands vs. Indylce, et al. Case No. ST-20-CV-14). The Attorney General filed no response to that expedited motion. + +{sup}`8.` As part of that resolution, th e Co-Executors agreed not to assert that the Attorney General's release of such limited funds will act as a waiver of Government's ability, if any, to object to the Program's administrative expenses, including those paid with these initial funds. + +{sup}`9.` The Co-Executors recognize the extraordinary difficulties imposed by the coronavirus pandemic on the functioning of the courts of the Virgin Islands. To the extent the Court wishes to conduct a remote conference in this matter, either telephonically or via videolink, the Co-Executors and their counsel will of course make themselves available. + +ESICI1C of Jefrey E Epstein Co-Executors' Status Report on Voluntary Compensation Program and Presentation of Program Protocol + +Probate No. ST-I9-PB-80 + +Page 7 + +V.I. Bar Nos. 136 966 1221 & R2019 + +KELLERHALS KROBLIN PLLC + +Palms Professional Building + +9053 Estate M, Suite 101 + +St. M, V.I. 00802 + +Telephone: (340) 779-2564 + +Facsimile: (888) 316-9269 + +Email: wblum@solblum.com + +ckroblin@kellfer.com + +sdandrade@kellfer.com + +mwhalen@kellfer.com + +Estate ofJeffrey E Epstein Co-Executors' Status Report on Voluntary Compensation Program and Presentation of Program Protocol + +#### CERTIFICATE OF SERVICE + +Probate No. ST-I9-PB-80 Page 8 + +I HEREBY CERTIFY that on this 1st day of June 2020, 1 caused a true and exact copy of the foregoing Co-Executors' Status Report on Voluntary Claims Resolution Program and Presentation of Program Protocol to be served via electronic mail upon: + +John H. Benham, Esq. Law Office of John H. Benham, P.C. P.O. J.1720 St. , VI 00801 john@benhamlawvi.com + +Douglas B. Chanco, Esq. ChancoSchiffer P.C. 3355 Lenox Road, Suite 750 Atlanta, GA 30326 doug@csfirm.com + +Richard Boume-Vanneck, Esq. Law Offices of Richard Bourne-Vanneck 980aimeer Mall Suite #9 St.. VI 00802 richard@rpvblmvoffices.cons + +John K. Dema Law Offices of John K. Dema 1236 Strand Street, Suite 103 St. Croix, VI jdema@demalaw.com + +Denise N.—, Esq. Attorney General Ariel M. , Esq. Chief, Civil Division Virgin Islands Department of Justice 34-38 Krondprinsdens Gade GERS Complex, 2nd Floor St. Virgin Islands 00804 + +A. Jeffrey Weiss, Esq. A.J. Weiss & Associates 69 p Lane St. VI 00802 jefirweiss@weisslaw-vi.net + +Sean Esig. Marjorie Rawls, P.C. P. .41347 St. , VI 00804 sean@rnarjorieroberispc.com + +Kevin F. D'Amour Gaylin Vogel, Esq. 51 Passage, 18b & 19b St. , VI 00802 kevin.damour@,comcastnet gaylin.vogel@,comcast.net + +Melody D. Westfall, Esq. Westfall Law PLLC 5032 Anchor Way, Suite 8 Christiansted, St. Croix 00820 mwestfall@westfaillenv.com + +Kevin Boyle, Esq. (Pro Hac Vice) Robert Glassman, Esq. (Pro Hac Vice) PANISH SHEA & BOYLE LLP 11111 Santa Monica Blvd., Ste. 700 Los Angeles, CA 90025 boyle@psblaw.com glassman@psblaw.corn + +/s/ Shari N. D'Andrade + +**Independent +Epstein Victims' Compensation Program** + +**PROTOCOL** + +**May 29, 2020** + +20 JUN - 1 AM 8:25 +SUPERIOR COURT +THE VIRGIN ISLANDS + +**I. PURPOSE AND OVERVIEW** + +The Epstein Victims' Compensation Program (the "Program") is a voluntary, independent Program that has been established to compensate and resolve the claims of victims-survivors of sexual abuse by Jeffrey Epstein ("Epstein"). + +The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims administration experts Kenneth R. Feinberg, Camille S. Biros and Jordana H. [REDACTED] to design the Program. [REDACTED] will also serve as the Administrator of the Program (the "Administrator"). This Protocol reflects input from victims-survivors, their lawyers, other potentially interested parties, and representatives of the Estate. + +Through the Program, the Estate wishes to acknowledge the wrongs endured by victims-survivors and offer them an opportunity to voluntarily resolve their individual claims for such sexual abuse. + +The Program is governed by the following non-exclusive guiding principles: + +- The Program is purely voluntary. It does not affect any rights a Claimant may have unless and until the Claimant accepts the offered compensation and executes a Release. A Claimant may reject the offer of compensation and may stop participating in the Program and withdraw the claim at any time prior to execution of the Release. +- The Program is independent and will in no way be administered, controlled or overseen by the Estate. The Administrator is responsible for all decisions relating to the review, processing and evaluation of individual claims submitted to the Program. The Administrator will have final, binding and exclusive authority to determine Claimant eligibility and the valuation of each eligible individual claim. Decisions of the Administrator made pursuant to this Protocol are not subject to review or modification in any way by the Estate or any other party or entity. +- There is no cap or limitation on the aggregate amount of funds available to compensate all eligible Claimants or on the amount of compensation to be made to each individual Claimant. Each individual claim will be evaluated separately by the Administrator. The Administrator will determine, in her sole and exclusive discretion, issues of eligibility and the amount of compensation and the Estate will pay all eligible claims based on the Administrator's determination. + +- All Claimants will be treated with respect, dignity and fairness without regard to race, color, sexual orientation, national origin, religion, gender or disability. To ensure claims will be adjudicated fairly, the Administrator will manage the process so that all Claimants can equally access the Program's claim process. Individuals with disabilities will be given the opportunity to effectively communicate their claims and to request special process accommodations. + +The Program is available to all victims-survivors regardless of where they were harmed, when they were harmed, whether the claim is time-barred by the applicable statute of limitations, and whether they have previously filed a lawsuit against or settled with Epstein and/or the Estate. + +The exclusive claims period for filing a claim pursuant to this Protocol shall commence on the to-bedetermined Effective Date and shall conclude nine (9) months after that date ("Filing Deadline"). All individual claims filed with the Program must be filed within this period. + +To complement the Program's resources, the Administrator will, at her discretion and with the consent of the Claimant, consult with Professor Marci A. a nationally recognized sexual abuse expert, leading legal academic and advocate of victims' rights. role will be to further inform the Administrator and her staff about the dynamics of sexual abuse, common responses to sexual abuse, and the impact of sexual abuse on victims; to serve as a resource for the Administrator in developing or updating policies and procedures; to advise the Administrator regarding sensitivities involved in interactions with victims; and to serve as a referral source for the Administrator in providing postdetermination information to claimants who seek guidance, counseling or other services. The Administrator may, at her discretion and with the Claimant's prior written consent, request that ME review an individual claimant file. The Administrator will determine on a case-b -case basis in her discretion, the need to anonymize individual claimants' files before sharing them with As set forth above, the Administrator is solely responsible for all decisions relating to the administration of the Program, including the review, processing, evaluation, and determination of individual claims submitted to the Program. + +During the term of the Program, will not meet or speak with a Claimant or her representatives concerning any aspect of the Program without the Administrator present. will maintain in strict confidence and will not disclose outside the Program any information she obtains through her participation in the Program, including individual Claimants' submissions. + +# II. ELIGIBIUTY REQUIREMENTS + +# A. Eligibility Criteria + +The persons eligible to participate in this Program are individuals who allege they were sexually abused by Epstein. In addition, the following criteria apply: + +- The claim of sexual abuse must be directed against Epstein. +- An individual whose claim is time-barred by the applicable statute of limitations may participate in the Program provided that other eligibility criteria are met. +- An individual who previously entered into a settlement agreement resolving a claim of sexual abuse against Epstein may participate in the Program provided that other eligibility criteria are met. +- An individual who allegedly assisted Epstein in procuring other victims-survivors may participate in the Program where there is a credible basis to determine that the individual acted under duress as a result of her own sexual abuse by Epstein, provided that other eligibility criteria are met. +- If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with prejudice any existing lawsuits, legal actions or claims filed against the Estate or related entities and/or related individuals. The Claimant must provide proof of such dismissal along with or prior to the signed acceptance of the compensation determination offer letter and executed Release in order to receive payment. + +# B. Legal Representatives of Claimants + +An individual may file a claim on a victim's behalf where that individual has been granted legal authority to act in a representative capacity pursuant to appropriate law. The "Legal Representative" of an individual Claimant shall mean: (1) in the case of a Claimant who is currently a minor, a parent or legal guardian authorized by law to serve as the minor's legal representative; (2) in the case of an incompetent or legally incapacitated Claimant, a person who has been duly appointed as the Claimant's legal representative in accordance with applicable law; (3) in the case of a deceased Claimant, a person who has been duly appointed to act as the personal representative of the Claimant's estate by a court of competent jurisdiction and is authorized to file and compromise a claim; or (4) an attorney authorized to represent the Claimant for purposes of pursuing a claim through this Program. + +Legal Representatives must provide proper documentation demonstrating representative capacity. Such proof may include a power of attorney; documentation showing the individual's appointment as guardian or guardian ad litem; documentation showing the individual's appointment as personal representative of the Claimant's estate (such as letters of administration); a copy of a retainer agreement showing legal representation signed by both the Claimant and the attorney or a signed statement by an adult Claimant and the attorney that a licensed/admitted attorney is acting on her behalf. + +# CLAIMS ADMINISTRATION - SUBMISSION, EVALUATION AND DETERMINATION + +# A. Claims Submission Process + +Individuals who have filed a lawsuit, legal action or claim against Epstein and/or the Estate or have otherwise been identified as a victim of Epstein by their attorney to the Administrator on or before the Effective Date will be sent a Claim Form and other relevant Program information, including Instructions for completion and submission of the Claim Form and a copy of this Protocol. Individuals who have filed a lawsuit need not agree to a stay of litigation or make any other concession in any pending litigation to be eligible to participate in the Program. Likewise, individuals who have not yet filed a lawsuit remain free to file a lawsuit and engage in litigation concurrently with participation in the Program. Individuals must, however, dismiss with prejudice any and all existing lawsuits, legal actions and claims prior to or at the time of acceptance of a compensation determination offer in order to receive payment. + +Individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the Estate or have not otherwise been identified as a victim of Epstein by their attorney to the Administrator on or before the Effective Date may register to participate in this Program on the Program's website at www.EpsteinVCP.com. To register, such individuals must complete a questionnaire setting forth their name, contact information, a summary description of the nature of the claim and other requested information. Upon registration, the Administrator will perform a preliminary review to consider if the individual is eligible to participate in the Program. If the Administrator deems that the individual is eligible to participate in the Program, she will then send that individual a Claim Form and other relevant Program information. + +Note: The fact that an individual is sent a Claim Form and other relevant Program information indicates that the Administrator has determined that such individual is eligible to participate in the Program. It does not indicate that the Administrator has determined that such individual is eligible to receive compensation. That determination is made only after a Claim Form and all required documentation has been submitted and evaluated by the Administrator. + +Registrations for individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the Estate or have not otherwise been identified as a victim of Jeffrey Epstein by their attorney to the Administrator on or before the Effective Date will be accepted by the Administrator from the Effective Date through a date that is 45 days prior to the Filing Deadline ("Registration Deadline"). It is important to note that the Registration Deadline is separate from, and precedes, the Filing Deadline. As explained above, all claims must be filed by the Filing Deadline. + +All Claim Forms must be completed to the best of a Claimant's ability and filed no later than the Filing Deadline. Claim Forms should be uploaded to the Program website at www.EpsteinVCP.com, or mailed via overnight courier (a pre-paid courier voucher will be included with each packet) to the Administrator at the following address: + +> Epstein Victims' Compensation Program Attn: Jordana H. S Administrator P.O. Box 65488 Washington, D.C. 20035 + +Claimants are invited to provide documentation identified in the Claim Form, and any other corroborating or supporting information sufficient to substantiate the claim, satisfy eligibility requirements, and allow the Administrator to review, process and evaluate the claim. If the claim is being presented by a Legal Representative, then the Legal Representative will be responsible for submitting the necessary documentation relating to the represented Claimant. + +Additional documentation may be requested at the discretion of the Administrator. Both the Claimant and the Estate will be afforded the opportunity to submit to the Administrator any information deemed relevant to the Administrator's evaluation and determination of the claim before the Administrator's final disposition of the claim. + +If a Claimant submits an incomplete or deficient claim, the Administrator will notify the Claimant, explain the additional information that is needed, and work with the Claimant or the Claimant's legal Representative (where applicable) to assist in submitting a complete claim. + +# B. Claims Evaluation and Determination + +Claims will be evaluated in the order in which they are received, with the Administrator evaluating each submitted individual claim in a prompt and fair manner. Claims will only be determined once all required documentation has been submitted to the Administrator, with due consideration granted to Claimant's good faith explanations for delays and/or absence of documentation. + +#### 1. Factors Considered in Evaluating Claims + +As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the information available, whether the allegations of sexual abuse are credible. The Administrator will consider appropriate factors and corroborative support, including but not limited to: + +- The level of documentation, corroboration or other circumstantial evidence regarding the nature and extent of the abuse, the frequency, location and other details of the abuse, and the age of the victim at the time of the abuse. Non-exhaustive examples of such evidence include + - (i) medical or psychiatric counseling/therapy records relevant to the abuse, and + - (ii) contemporaneous written notification or other correspondence (e.g., letters, emails) of the abuse by the Claimant to law enforcement authorities, parents, friends or others. The Administrator acknowledges that some Claimants may not be able to provide any + +documentation to corroborate their Claim based on the nature and circumstances of Epstein's conduct. If a Claimant's written and oral presentation is deemed to be credible by the Administrator, the Claimant may still be eligible for compensation under the Program. + +- Whether there exists any information and/or pertinent findings offered by the appropriate Office of the District Attorney, United States Attorney's Office, or other law enforcement agency. +- Whether the Administrator finds the claims of the individual to be credible after complete review of all relevant documentation and other evidence provided by the Claimant and the Estate. + +As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the information available, the amount of compensation that should be offered to each eligible Claimant. The Administrator will consider appropriate factors and corroborative support, including but not limited to: + +- The nature, duration and extent of the sexual abuse suffered by the Claimant. +- The age of the Claimant at the time of the sexual abuse. +- The nature and extent of the Claimant's physical or psychological damage resulting from the sexual abuse, and the effect of the sexual abuse on the Claimant. +- The credibility of the claim based upon all of the facts and circumstances, supporting documentation and corroborating evidence. +- Whether the Claimant previously entered into a settlement agreement with Epstein and received a payment pursuant to such agreement. + +The Administrator will confidentially send the Claimant a compensation determination offer letter including the following: (1) the Administrator's eligibility decision regarding the claim; (2) the amount of compensation offered; (3) a Release to be signed by the Claimant if the Claimant accepts the offered compensation; and (4) a Payment Option Form. The Administrator's offer shall be valid for 60 days from the date of the compensation determination offer letter. + +The Administrator's determinations in this Program will not be binding on any potential criminal investigation involving Claimant's claims. + +# 2. Opportunities to be Heard + +The Claimant will be afforded an opportunity to be heard, either before or after the Administrator renders her determination. Upon request by the Claimant, the Administrator will be available to meet in person (as practicable in light of the COVID-19 pandemic), by video conference, or by teleconference to further discuss the claim. These meetings are completely optional and voluntary. Requests to meet + +with the Administrator should be sent by email to ClaimantServices@EpsteinVCP.com and will be scheduled at a mutually convenient time and location. The Administrator may also request a meeting with a Claimant or her Legal Representative at a reasonable mutually convenient time and location, though the Claimant is not obligated to attend any such meeting. + +#### 3. Release + +By submitting a claim to the Program, a Claimant is seeking to resolve all claims relating to allegations of sexual abuse against Epstein and/or the Estate, and related entities and individuals as set forth in the Release. If a Claimant chooses to accept the offer of compensation pursuant to the Program, the Claimant will be required to sign and execute a full Release, in a form satisfactory to the Estate, of all past and future claims (including lis pendens, writs of attachment, etc.) relating to such allegations of sexual abuse against the Estate, related entities and/or related individuals. A Claimant may reject the offer of compensation and may stop participating in the Program and withdraw the claim at any time prior to the execution of the Release. + +The Release will waive any rights the Claimant and her heirs, descendants, legatees or beneficiaries may have to assert any claims relating to allegations of sexual abuse against the Estate, related entities and/or related individuals, to file an individual legal action relating to such allegations, or to participate in any civil legal action associated with such allegations, except as a witness. However, the Release will not operate to preclude or limit the Claimant's ability to report and discuss allegations of sexual abuse with law enforcement officials or anyone else. In other words, the Release will not impose any rules of confidentiality on claimants, who are expressly permitted to discuss their allegations without restriction, should they choose. + +Before signing a Release, the Claimant must consult with an attorney selected by the Claimant. If the Claimant is not represented by an attorney, the Program will provide an attorney to provide free legal counseling to the Claimant for the sole purpose of advising the Claimant concerning the language and binding nature of the Release. + +No one affiliated with the Program will provide tax or legal advice to those receiving payments under the Program. Claimants are urged to consult with a tax advisor concerning any questions regarding tax liability for payments pursuant to the Program. + +#### 4. Payments + +Upon the Claimant's acceptance of the Administrator's determination, the Administrator's receipt of the Claimant's executed Release and, where applicable, dismissal with prejudice of any existing lawsuit, legal actions or claims against the Estate or related entities and/or related individuals, the Administrator will initiate payment by check or electronic funds transfer to each eligible Claimant as directed by the Claimant. Checks will be sent to Claimants via overnight courier service. All payments made under the Program shall be for a Claimant's physical injuries, physical sickness and resulting emotional distress within the meaning of Section 104(a) of the Internal Revenue Code. + +# C. Program Integrity + +For the purpose of protecting both the integrity of the Program and financial resources for eligible Claimants, the Administrator will Institute all necessary measures to prevent payment of fraudulent claims, including taking steps to verify claims and analyze submissions for inconsistencies, irregularities or duplication. + +Each Claimant who signs the Claim Form at the time of submission certifies that the information provided in the Claim Form is true and accurate to the best of the Claimant's knowledge, and that the Claimant understands that false statements or claims made in connection with such submission may result in fines, imprisonment and/or any other remedy available by law. Claims that appear to be potentially fraudulent or to contain information known by the Claimant to be false when made will be forwarded to federal, state or local law enforcement agencies and/or the appropriate Office of the District Attorney and/or United States Attorney's Office for possible investigation and prosecution. + +# D. Confidentiality/Privacy + +The Program is confidential.' By filing a claim with the Program, the Claimant or her Legal Representative (where applicable) agrees that information submitted by the Claimant pursuant to the Program will be used and/or disclosed by the Administrator and her designees only for the following purposes: + +- I) Processing and evaluating the Claimant's claim; +- 2) Administering the Program and other Program-related work; and +- 3) Reports to law enforcement where appropriate, related to potentially fraudulent claims. + +When documents or other information maintained or submitted by the Estate become part of a Claimant's file for purposes of the Program, such materials will be reviewed by the Administrator to assist in processing and evaluating the claim, but will otherwise remain confidential. No information provided by Claimants will be provided to the Estate except for the Claimant's name and the date(s) and location(s) of the alleged abuse, for the sole purpose of processing and evaluating the claim and, for purposes of the Release, the names of any other individual(s) to whom or by whom the Claimant alleges she was trafficked or sexually abused. The Estate has agreed that no information obtained solely through the Program will be disclosed publicly or used by the Estate in defending itself from any claim, regardless of forum. The Program's files are not available for inspection, review or copying by the Estate or the Claimant or her representatives during or after the Program, and all pertinent mediation privileges, settlement privileges and other privileges apply. + +All parties agree that they are using the services of a third-party administrator to help reach a resolution of individual claims of sexual abuse, and that this Program is entitled to confidentiality, privileges (mediation, settlement and all other pertinent privileges), and protection from disclosure under applicable law. + +To protect the privacy of Claimants participating in the Program, all personal Information provided by the Claimant during this process will be returned or destroyed within one year after the conclusion of the Program. + +Individual Claimants are not bound through the Program by any rules of confidentiality. Claimants may, at their sole and voluntary option, disclose information in their possession regarding their claim, their compensation and their experience with the Program. + +All confidentiality requirements are subject to law, regulation and judicial process. + +#### E. Reportins + +The Administrator shall, on a monthly basis, confidentially provide reports regarding the number and total value of claims paid each month to the Probate Court of the United States Virgin Islands and the Attorney General of the United States Virgin Islands. Such reports will report on an aggregate level only. No individual Claimant information will be published or disclosed in a way that compromises Claimant confidentiality. \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751843/EFTA02751843.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751843/EFTA02751843.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..ef99b441ac23a87a553b76a27c3dd33d7f0002f7 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751843/EFTA02751843.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -36, + "dataset": "marker2", + "doc_id": "EFTA02751843", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 4, + "fix_ids": "[\"builtin.duplicate-list-marker\", \"swarm.html-myst-whitelist\"]", + "idempotent": true, + "input_sha256": "ab045e5c987b6280454defd82b4260582f29d378e98bca4c8509fe22230456fe", + "output_sha256": "35017c952c696092702875c8aa3ea407c2a7000880bb3bd28c0e23bd6e5b75c5", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751863/EFTA02751863.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751863/EFTA02751863.md new file mode 100644 index 0000000000000000000000000000000000000000..9e617263ccac78899d11136963e05eb17df34337 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751863/EFTA02751863.md @@ -0,0 +1,85 @@ +# EXHIBIT + +## IN THE SUPERIOR COURT TH VIRGIN ISLANDS District of St. /St. John + +In the Matter of the Estate of JEFFREY E. Case Number: ST-2019-PB-00080 EPSTEIN, deceased. Action: Administration of Testamentary Estates + +### NOTICE of ENTRY of ORDER + +To: MEMO= Kroblin, Esq. + +John H. Benham, Esq. + +Douglas B. Chanco, Esq. + +Richard P. Bourne-Vanneck, Esq. + +John K. Dema Esq. + +Denise N. MI Esq. + +Melody D. West all, Esq. + +Sean E al, Esq. + +Gaylin Voge , Esq. + +A. Jeffrey Weiss, Esq. + +Ariel M. III., Esq. + +Kevin F. D'amour, Esq. + +Kevin Boyle, Esq. + +Robert Glassman, Esq. + +Please take notice that on June 3, 2020 + +#### a(n) ORDER + +dated June 2, 2020 was entered + +by the Clerk in the above-titled matter. + +Dated: June 03, 2020 Tamara Charles + +By: + +Clerk of the Court + +44114 + +Edotcia Hodge Court erk + +#### IN THE SUPERIOR COURT HE VIRGIN ISLANDS DIVISION OF ST. AND ST. JOHN + +IN THE MATTER OF THE ESTATE OF: + +JEFFREY E. EPSTEIN, + +PROBATE NO. ST-19-PB-80 + +ACTION FOR TESTATE deceased. ADMINISTRATION + +#### ORDER + +THIS MATTER is before the Court on the Co-Executors' Status Report on Voluntary Compensation Program and Presentation of Program Protocol filed on June 1, 2020, wherein, in pertinent part, the Co-Executor notify that all interested parties have finalized and are in support of the protocol for the Epstein Victims' Compensation Program (hereinafter "the Program")) The Court having received testimony concerning the Program at the hearing held on February 4, 2020, and having reviewed said Status Report, it is hereby + +ORDERED that the Expedited Motion for Establishment of a Voluntary Claims Resolution Program filed on November 14, 2019, is GRANTED; and it is further + +ORDERED that the Co-Executors are AUTHORIZED to commence the Epstein Victims' Compensation Program on or about June 15, 2020. + +Dated: June , 2020 + +#### ATTEST: + +TAMARA CHARLES Clerk of the Court + +By: A EDOTCIA T MAS-HODGE Court Clerk Supervisor 6, / 3 /a + +Magistrate ROLVN P. HER ON- ERCELL dge off e Superior(Court of the Virgin Islands + +> CERTIFIEp T E COPY DATE O14,30 TAMARA CHARLES CLERK MCZR4 BY COURT CLERK + +{sup}`&#`x27;At the hearing held on February 4. 2020, while the Court did not allow the Attorney General of the U.S. Virgin Islands to intervene, the Court did request the Co-Executors and the Attorney General to resolve their differences concerning the proposed compensation program. which has garnered the support of all interested parties, including claimants' counsel. The Co-Executors now inform that Ilaecause the need for the Program has grown increasingly urgent, and with the support of claimants' counsel and the USV1 Attorney General - and because the remaining impediments have been resolved and the interested parties have consented to the Protocol.' they and the Attorney General have reached an agreement in which the latter will promptly lift previously imposed liens to pay amounts owed for the Program and to begin funding the Program's active operations, including payment of compensation determinations to eligible claimants. Co-Executors' Status Report on Voluntary Compensation Program and Presentation of Program Protocol, at 6. June 1. 2020. \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751863/EFTA02751863.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751863/EFTA02751863.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..09f3ac99260d34fa9f8359c73328221ff09880e9 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751863/EFTA02751863.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -4, + "dataset": "marker2", + "doc_id": "EFTA02751863", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 1, + "fix_ids": "[\"swarm.html-myst-whitelist\"]", + "idempotent": true, + "input_sha256": "eb5163fb22381e8b065d0b1f6fa66c0ac621ff1bb7efaf99a715ce7eb6cb7291", + "output_sha256": "57d21d7a128cc92b16fc6ea779953f64d8b34a976318fd5f352f6dae9629c664", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751866/EFTA02751866.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751866/EFTA02751866.md new file mode 100644 index 0000000000000000000000000000000000000000..699e8ee69f75f9e1eb1165659eaee8c64f37b561 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751866/EFTA02751866.md @@ -0,0 +1,19 @@ +Bennet J. Moskowitz bennet.moskowitz@troutman.com + +June 3, 2020 + +## VIA ECF + +Hon. Debra Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007 + +Re: Katlyn Doe, 1:19-cv-07771-PKC-DCF; Priscilla Doe, 1:19-cv-07772-ALC-DCF; Lisa Doe. 1:19-cv-07773 ER-DCF; VE. 1:19-cv-07625-AJN-DCF; Doe. 1:19-cv-08673-KPF-D 1:19-cv-10475-LGS-DCF; , 1:19-cv-10476-PGG-DCF: 1:19-cv-10479-ALC-DCF; . Jane Doe 1000, 1:19-cv-10577-LGS-D F- Jane Doe 15, 1:19-cv-10653-PAE-DCF; Mary Doe, 1:19-cv-10758-PAE-DCF; 1:19-cv-10788-GHW-DCF; Anastasia Doe, 1:19-cv-11869-AJN-DCF; Jane Doe, 1:20-cv-00484-JGK-DCF + +Dear Judge Freeman: + +We represent Defendants Darren,. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the above-referenced actions. We are pleased to inform the Court that, today, the Superior Court of the United States Virgin Islands entered an order granting the Co-Executors' Motion to establish the Epstein Victims' Compensation Program. A copy of the Order is attached hereto. + +Respectfully submitted, + +/s/ Bennet J. Moskowitz Bennet J. Moskowitz + +cc: Counsel of Record (via ECF) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751866/EFTA02751866.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751866/EFTA02751866.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b8645245ce0a0e2012d4b1b35d8ce49e9f7b3520 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751866/EFTA02751866.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751866", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "2d402f6fa662c562f771352c2e48ce5976cda6292a42a94b82b236ce4860b8fa", + "output_sha256": "2d402f6fa662c562f771352c2e48ce5976cda6292a42a94b82b236ce4860b8fa", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751867/EFTA02751867.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751867/EFTA02751867.md new file mode 100644 index 0000000000000000000000000000000000000000..a503bc42a0897a611b47a3f03d36f348d04cbfc7 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751867/EFTA02751867.md @@ -0,0 +1,45 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +ANASTASIA DOE, + +v. + +DARREN K. INDYKE AND RICHARD D. KAHN, AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN., + +Defendants. + +Case No. 1:19-cv- I I869-MKV-DCF + +## JOINT STIPULATION AND [PROPOSED] ORDER STAYING ACTION + +WHEREAS independent claims administration experts have designed and are implementing the Epstein Victims' Compensation Program (the "Program") to resolve sexual abuse claims against decedent Jeffrey E. Epstein ("Decedent") in a non-adversarial alternative to litigation; and + +WHEREAS Plaintiff Anastasia Doe ("Plaintiff," and together with Defendants, Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein, the "Parties"), seeks to participate in the Program; and + +WHEREAS the Parties seek to preserve their resources and judicial economy by staying this action unless and until Plaintiff elects to resume the litigation and requests the stay be lifted; and + +WHEREAS should Plaintiff resolve her claims against Defendants via the Program, the Parties will thereafter promptly discontinue this action with prejudice. + +IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel for the Parties, that: + +- 1. The captioned action is hereby stayed pending further Order of the Court. + +- 2. After the lifting of the stay, if any, the Parties will confer on a schedule for the remaining discovery in this action. + +Dated: June 12, 2020 Respectfully submitted, New York, New York + +POTTINGER LLC + +By: /s/ Brad Brad 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 brad @epllc.com + +Attorneys for Plaintiff + +TROUTMAN SANDERS LLP + +By: /s/Bennet Moskowitz Bennet J. Moskowitz 875 Third Avenue New York, NY 10022 (212) 704-6000 bennet.moskowitz@troutman.com + +Attorneys for Defendants + +Date: , 2020 + +New York, New York HON. DEBRA C. FREEMAN United States Magistrate Judge \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751867/EFTA02751867.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751867/EFTA02751867.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..f83f5f6d6b7b5cf7f00ee121c06e77083b620e0e --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751867/EFTA02751867.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751867", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "3460c35ba642f4d5ad7fb36f297ac6a560a97bc1f86803c6eb172ff3b809c474", + "output_sha256": "3460c35ba642f4d5ad7fb36f297ac6a560a97bc1f86803c6eb172ff3b809c474", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751869/EFTA02751869.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751869/EFTA02751869.md new file mode 100644 index 0000000000000000000000000000000000000000..9ca39e52a4e6a2c12376eeb1727c40d8c1f11878 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751869/EFTA02751869.md @@ -0,0 +1,52 @@ +**UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK** + +ANASTASIA DOE, + +*Plaintiff,* + +v. + +Case No. 1:19-cv-11869-MKV-DCF + +DARREN K. INDYKE AND RICHARD D. +KAHN, AS CO-EXECUTORS OF THE +ESTATE OF JEFFREY E. EPSTEIN., + +*Defendants.* + +**JOINT STIPULATION AND PROPOSED ORDER STAYING ACTION** *DF* + +WHEREAS independent claims administration experts have designed and are implementing the Epstein Victims' Compensation Program (the "Program") to resolve sexual abuse claims against decedent Jeffrey E. Epstein ("Decedent") in a non-adversarial alternative to litigation; and + +WHEREAS Plaintiff Anastasia Doe ("Plaintiff," and together with Defendants, Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein, the "Parties"), seeks to participate in the Program; and + +WHEREAS the Parties seek to preserve their resources and judicial economy by staying this action unless and until Plaintiff elects to resume the litigation and requests the stay be lifted; and + +WHEREAS should Plaintiff resolve her claims against Defendants via the Program, the Parties will thereafter promptly discontinue this action with prejudice. + +IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel for the Parties, that: + +1. 1. The captioned action is hereby stayed pending further Order of the Court. + +- 2. After the lifting of the stay, if any, the Parties will confer on a schedule for the remaining discovery in this action. + +Dated: June 12, 2020 Respectfully submitted, New York, New York + +POTTINGER LLC + +By: /s/ Brad Brad 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 brad @epllc.com + +Attorneys for Plaintiff + +TROUTMAN SANDERS LLP + +By: /s/Bennet Moskowitz Bennet J. Moskowitz 875 Third Avenue New York, NY 10022 (212) 704-6000 bennet.moskowitz@troutman.com + +Attorneys for Defendants + +Date: June 15 , 2020 New York, New York + +L n The parties are directed to submit a joint status report o later than 8/14/2020. + +HON. DEBRA G. FREEMAN United States Magistrate Judge \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751869/EFTA02751869.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751869/EFTA02751869.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b5885c1f5e6efca20acaf89b7806d052d5f12477 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751869/EFTA02751869.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751869", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "9c06938d7aa5b9d747c6f02fc3077ddd71d1aae8666bf42791eaa2e366f877ac", + "output_sha256": "9c06938d7aa5b9d747c6f02fc3077ddd71d1aae8666bf42791eaa2e366f877ac", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751871/EFTA02751871.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751871/EFTA02751871.md new file mode 100644 index 0000000000000000000000000000000000000000..1e79a0ccbcf475bda1e1f5b22fbbf55687aeb77c --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751871/EFTA02751871.md @@ -0,0 +1,45 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +ANASTASIA DOE, Plaintiff, + +-against- + +DARREN I. INDYKE and RICHARD + +D. KAHN, et al., Defendant. + +Case No. 19-CV-11869-MKV-DCF + +## NOTICE OF CHANGE OF ADDRESS + +TO: ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES + +I have cases pending I have no cases pending + +Pursuant to Local Rule 1.3 of this Court. please take notice of the following attorney information change (s) for: + +Mary "Molly" S. Dirago + +FILL IN ATTORNEY NAME + +My SDNY Bar Number is: My State Bar Number is + +lam. + +An attorney + +A Government Agency attorney + +A Pro Hac Vice attorney + +FIRM INFORMATION (Include full name of firm (OLD AND NEW), address, telephone number and fax number): + +OLD FIRM: FIRM NAME: Troutman Sanders1LP FIRM ADDRESS: 227 W. Monroe Street. Suite 3900. Chic.aao, IL 60606 FIRM TELEPHONE NUMBER: (312) 759-1920 FIRM FAX NUMBER: (31?) 759-1939 + +NEW FIRM: FIRM NAME: Troutman Pepper Sanders LLP FIRM ADDRESS: 227 W. Monroe Street. Suite 3900. Chicago. IL 6CIW FIRM TELEPHONE NUMBER: f3121759.1920 FIRM FAX NUMBER: (312) 759-1939 + +I will continue to be counsel of record on the above-entitled case at my new firm/agency. + +I am no longer counsel of record on the above-entitled case. An order withdrawing my appearance was entered on by Judge + +Dated: July 8. 2020 siMary 'Molly" S. Dirago ATTORNEY'S SIGNATURE \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751871/EFTA02751871.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751871/EFTA02751871.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..6adf7cc840484776293c90f5d8dcf3be8aef1faf --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751871/EFTA02751871.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751871", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "1094506640795ce8193c75c6ac15d64b9e38b4b22eabb5497f7f7aeae3f5487c", + "output_sha256": "1094506640795ce8193c75c6ac15d64b9e38b4b22eabb5497f7f7aeae3f5487c", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751872/EFTA02751872.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751872/EFTA02751872.md new file mode 100644 index 0000000000000000000000000000000000000000..8a5a4cbcd9ec8e0ab95d77f9ef915666b21a70ad --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751872/EFTA02751872.md @@ -0,0 +1,61 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +ANASTASIA DOE, Plaintiff, + +-against- + +DARREN I. INDYKE and RICHARD + +D. KAHN. et al., Defendant. + +Case No. 19-CV-11869-MKV-DCF + +## NOTICE OF CHANGE OF ADDRESS + +TO: ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES + +I have cases pending I have no cases pending + +Pursuant to Local Rule 1.3 of this Court. please take notice of the following attorney information change (s) for: + +Bennet J. Moskowitz + +FILL IN ATTORNEY NAME + +My SDNY Bar Number is: 6M1024 + +I am. + +My State Bar Number is 4693842 + +An attorney + +A Government Agency attorney + +A Pro Hac Vice attorney + +FIRM INFORMATION (Include full name of finn (OLD AND NEW), address, telephone number and fax number): + +OLD FIRM: FIRM NAME: Troutman Sanders LLP + +FIRM ADDRESS: 875 Third Avenue New YodcNY 10022 + +FIRM TELEPHONE NUMBER:1212) 704-6000 + +FIRM FAX NUMBER:\_(22)704-6288 + +NEW FIRM: FIRM NAME: Troutman Pepper Sanders LLP + +FIRM ADDRESS: 875 Third Avenue New York NY 10022 + +FIRM TELEPHONE NUMBER: (212) 704-6000 + +FIRM FAX NUMBER: (212) 704-6288 + +I will continue to be counsel of record on the above-entitled case at my new firm/agency. + +I am no longer counsel of record on the above-entitled case. An order withdrawing my appearance was entered on by Judge + +Dated: July 8, 2020 sitien net J. Moskowitz + +ATTORNEY'S SIGNATURE \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751872/EFTA02751872.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751872/EFTA02751872.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d5e4fb3735c63c089c9b89c5f03ec7daec3fb90f --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751872/EFTA02751872.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751872", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "eeeb619e871457343dec3d3d86309b015b240f611e1122a1d1fe2a30f348e83f", + "output_sha256": "eeeb619e871457343dec3d3d86309b015b240f611e1122a1d1fe2a30f348e83f", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751873/EFTA02751873.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751873/EFTA02751873.md new file mode 100644 index 0000000000000000000000000000000000000000..d21a271abfb1a576c1d46e9593a8cebc822a6f90 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751873/EFTA02751873.md @@ -0,0 +1,35 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +ANASTASIA DOE, Plaintiff, + +-against- + +DARREN I. INDYKE and RICHARD D. KAHN, et al., Defendant. Case No. 19-CV-11869-MKV-DCF + +## NOTICE OF CHANGE OF ADDRESS + +TO: ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES + +I have cases pending I have no cases pending + +Pursuant to Local Rule 1.3 of this Court. please take notice of the following attorney information change (s) for: + +## Charles L. Glover + +My SDNY Bar Number is: CG0117 My State Bar Number is 5329909 + +I am. + +## FILL IN ATTORNEY NAME + +An attorney A Government Agency attorney A Pro Hac Vice attorney + +FIRM INFORMATION (Include full name of firm (OLD AND NEW), address, telephone number and fax number): + +OLD FIRM: FIRM NAME: Troutman Sanders LLP FIRM ADDRESS: 875 Third Avenue New Yod(sNY 10022 FIRM TELEPHONE NUMBER:1212) 704-6000 FIRM FAX NUMBER:SI?)704-6288 + +NEW FIRM: FIRM NAME: Troutman Pepper Sanders LLP FIRM ADDRESS: 875 Third Avenue New York NY 10022\_\_\_\_\_\_\_ FIRM TELEPHONE NUMBER: (212) 704-6000 FIRM FAX NUMBER: (212) 704-6288 + +I will continue to be counsel of record on the above-entitled case at my new firm/agency. I am no longer counsel of record on the above-entitled case. An order withdrawing my appearance was entered on by Judge + +Dated: July 8, 2020 s/Charles L Glover ATTORNEY'S SIGNATURE \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751873/EFTA02751873.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751873/EFTA02751873.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b621f9d792347b03b384b9e1b83644ff62e94b4e --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751873/EFTA02751873.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751873", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "0c88271a7e849c62059864e8f1f124f216f6d6c09c3aeaf9d65a7bfb213d1d26", + "output_sha256": "0c88271a7e849c62059864e8f1f124f216f6d6c09c3aeaf9d65a7bfb213d1d26", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751874/EFTA02751874.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751874/EFTA02751874.md new file mode 100644 index 0000000000000000000000000000000000000000..cbdb86fc6f40cd35088e3514b872ee50c70fd281 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751874/EFTA02751874.md @@ -0,0 +1,21 @@ +Bennet J. Moskowitz bennelmoskowitz@troutman.com + +August 14, 2020 + +## VIA ECF + +Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007 + +Re: Katlyn Doe, 1:19-cv-07771-PKC-DCF; Priscilla Doe, 1:19-cv-07772-ALC-DCF; Lisa Doe, 1:19-cv-07773 ER-DCF; VE., 1:19-cv-07625-AJN-DCF; Anastasia Doe, 1:19-cv-11869-AJN-DCF + +Dear Judge Freeman: + +We represent Defendants Darren'. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, in the above-referenced actions. With Plaintiffs' consent, we write pursuant to Your Honor's June 22, 2020 Order to provide the Court with a joint status report. + +Plaintiffs' counsel has advised us that all Plaintiffs are currently working to formally submit their claims to the Epstein Victims' Compensation Program. Accordingly, the parties request that the stays entered in these actions continue in accordance with the respective stay orders. + +Respectfully submitted, + +/s/ Bennet J. Moskowitz Bennet J. Moskowitz + +cc: Counsel of Record (via ECF) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751874/EFTA02751874.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751874/EFTA02751874.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..1128f258243d31413e84074c72a6e49afdae6d9f --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751874/EFTA02751874.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751874", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "8793e3cce81d1093d748aee1fa328450d61b33b3fda72a270618e20e53d1d4c0", + "output_sha256": "8793e3cce81d1093d748aee1fa328450d61b33b3fda72a270618e20e53d1d4c0", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751875/EFTA02751875.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751875/EFTA02751875.md new file mode 100644 index 0000000000000000000000000000000000000000..cbd9581745cbdad86946cd6a979a22166a6b490a --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751875/EFTA02751875.md @@ -0,0 +1,15 @@ +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 at, No. 1:19-cv-07625 (MN) (DF) Doe I et at v. lndyke et at, No. 1:19-cv-7675 (GBD) (DF) Katlyn Doe v. Indyke et at, No. 1:19-cv-0777 I (PKC) (DF) Priscilla Doe v. Indyke et at, No. 1:19-cv-07772 (ALC) (DF) Lisa Doe v. Indyke et at, No. 1:19-cv-07773 (ER) (DF) Jane Doe v. Indyke a at, No. 1:19-cv-08673 (KPF) (DF) Doe 17 v. Indyke et at, No. 1:19-cv-09610 (PAE) (DF) 11v. Indyke a at, No. 1:19-cv-10475 (LOS) (DF) v. Indyke a at, No. 1:19-cv- 10476 (PGG) (DF) v. Indyke et at, No. 1:19-cv-10479 (ALC) (DF) Jane Doe 1000 v. Indyke a at, No. 1:19-cv-10577 (LOS) (DF) Jane Doe 15 v. Indyke et at, No. 1:19-cv-10653 (PAE) (DF) Ma{sup}`e`v. Indyke et at, No. 1:19-cv-10758 (ME) (DF) v. Indyke et at, No. 1:19-cv-10788 (GI-IW) (DF) Anastasia Doe v. Indyke a at, No. 1:19-cv-11869 (MN) (DF) Doe v. hulyke et al., No. 1:20-cv-02365 (LIL) (DF) Doe v. Indyke a at, No. 1:20-cv-2365 (LJL) (DF) + +## DEBRA FREEMAN, United States Magistrate Judge: + +This Court, at the joint request of the parties in each of the above-referenced cases, having issued stays of the proceedings in those cases so that the plaintiffs may pursue the potential settlement of their claims through the Epstein Victims' Compensation Program, it is hereby ORDERED that the parties to each of the referenced cases shall provide this Court with a status report by October 1, 2020, and then, if the matter remains unresolved, by the first day of each month thereafter (or, if the first of the month falls on a weekend or Court holiday, then by the next business day). + +Dated: New York, New York September 4, 2020 + +SO ORDERED + +%de DEBRA FREEMAN United States Magistrate Judge + +Copies to: All counsel in the above-referenced cases (via ECF) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751875/EFTA02751875.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751875/EFTA02751875.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..dab01080aae01ec1c9e51f3c341bccd029ac3815 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751875/EFTA02751875.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -4, + "dataset": "marker2", + "doc_id": "EFTA02751875", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 1, + "fix_ids": "[\"swarm.html-myst-whitelist\"]", + "idempotent": true, + "input_sha256": "16e4ee4f9f3e39ac544f4b5e0fcf3a2bc96b34b92e9b8700c94dba4895802a9d", + "output_sha256": "001483b12409cc4d3a410eccad784c1a08b948ef3fdaff10e5a33bb96cee23f9", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751876/EFTA02751876.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751876/EFTA02751876.md new file mode 100644 index 0000000000000000000000000000000000000000..0b576f0c1e14876902372026416538d8f3a7e41c --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751876/EFTA02751876.md @@ -0,0 +1,23 @@ +Bennet J. Moskowitz bennelmoskowitz©Iroutman.com + +October 1, 2020 + +## VIA ECF + +Hon. Debra C. Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007 + +Re: Anastasia Doe v. Darren Indyke and Richard D. Kahn as co-executors of the Estate of Jeffrey E. Epstein No.1:19-cv-11869-MKV-DCF + +Dear Judge Freeman: + +Pursuant to the Court's September 4, 2020 Order (ECF No. 38), Plaintiff and Defendants Darren'. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein jointly submit this status report. + +Plaintiff has submitted her claim to the Epstein Victims' Compensation Program; it is currently under review. + +To preserve the parties' resources and in the interests of judicial economy, the parties respectfully request that this case remain stayed at this time. + +Respectfully submitted, + +/s/ Bennet J. Moskowitz Bennet J. Moskowitz + +cc: Counsel of Record (via ECF) \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751876/EFTA02751876.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751876/EFTA02751876.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..89226441b5376c44eee9724c663a4493a82ea306 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751876/EFTA02751876.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751876", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "3f194f970850e1a865031b5b372930729ad036a454c931156a91a19f11effa95", + "output_sha256": "3f194f970850e1a865031b5b372930729ad036a454c931156a91a19f11effa95", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751877/EFTA02751877.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751877/EFTA02751877.md new file mode 100644 index 0000000000000000000000000000000000000000..b3592d64579791e581f70c456a2601475d0a2b4c --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751877/EFTA02751877.md @@ -0,0 +1,27 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +ANASTASIA DOE, + +Plaintiff, + +vs. + +DARREN K. INDYKE AND RICHARD D. KAHN AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, + +Defendant. + +CASE NO.: 1:19-CV-11869 + +## JOINT STIPULATION FOR DISMISSAL + +Plaintiff, ANASTASIA DOE, and Defendants, Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein, by and through their undersigned counsel, hereby stipulate and agree that due to Plaintiff's resolution of her claim(s) against Defendants via the Epstein Victims' Compensation Program, this action shall be DISMISSED WITH PREJUDICE, with each party to bear its own attorneys' fees and costs. + +Dated: November 2, 2020 Respectfully Submitted, + +POTTINGER LLC + +B:/s/ J. J. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Brad@eplIc.com Brittany@eplIc.com Attorneys for Plaintiff + +TROUTMAN PEPPER SANDERS LLP + +By: /s/Bennet J. Moskowitz Bennet J. Moskowitz 875 Third Avenue New York, NY 10022 (212) 704-6000 bennet.moskowitz@troutman.com Attorneys for Defendants \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751877/EFTA02751877.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751877/EFTA02751877.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c11ba2d021458f5aa2e6a9bb8a45c4525468bb65 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751877/EFTA02751877.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751877", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "2349bd109682e2cd6a59ca6c02d37a51e60b58ab294de6fccea716b380eb4636", + "output_sha256": "2349bd109682e2cd6a59ca6c02d37a51e60b58ab294de6fccea716b380eb4636", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751878/EFTA02751878.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751878/EFTA02751878.md new file mode 100644 index 0000000000000000000000000000000000000000..fb14868af186527423d16367344930eccbb5479d --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751878/EFTA02751878.md @@ -0,0 +1,23 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +ANASTASIA DOE, + +Plaintiff, CASE NO.: 1:19-CV- I 1869 + +vs. + +DARREN K. INDYKE AND RICHARD D. KAHN AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, + +Defendant. + +## JOINT STIPULATION FOR DISMISSAL + +Plaintiff, ANASTASIA DOE, and Defendants, Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein, by and through their undersigned counsel, hereby stipulate and agree that due to Plaintiff's resolution of her claim(s) against Defendants via the Epstein Victims' Compensation Program, this action shall be DISMISSED WITH PREJUDICE, with each party to bear its own attorneys' fees and costs. + +Dated: November 2, 2020 + +POTTINGER LLC B J. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Brad®eplk.com Brittany@eplIc.com Attorneys for Plaintiff + +Respectfully Submitted, + +TROUTMAN PEPPER SANDERS LLP By: Molly S. DiRago 875 Third Avenue New York, NY 10022 (212) 704-6000 bennet.moskowitz@troutman.com Attorneys for Defendants 4f1 6(if6-S Nkitio \ No newline at end of file diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751878/EFTA02751878.receipt.json b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751878/EFTA02751878.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d95aac7bc1ed3f49129c50285bfe79aef75e2d4e --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751878/EFTA02751878.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": 0, + "dataset": "marker2", + "doc_id": "EFTA02751878", + "engine": "marker-pdf-2.0.0+surya-0.22.1", + "event_count": 0, + "fix_ids": "[]", + "idempotent": true, + "input_sha256": "b5ded854d0d91f60f734765b14ab8cd30b4c67c95fe88fa764d92dc19fdc4270", + "output_sha256": "b5ded854d0d91f60f734765b14ab8cd30b4c67c95fe88fa764d92dc19fdc4270", + "page_markers": false, + "source_id": "marker2-court-doe-v-indyke-11869", + "text_format": "markdown" +} diff --git a/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751879/EFTA02751879.md b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751879/EFTA02751879.md new file mode 100644 index 0000000000000000000000000000000000000000..1087d2958f040a654c542602b1e08f9e8db90405 --- /dev/null +++ b/marker2-fixhub/court-doe-v-indyke-11869/EFTA02751879/EFTA02751879.md @@ -0,0 +1,33 @@ +ANASTASIA DOE, + +Plaintiff, + +vs. + +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +DARREN K. INDYKE AND RICHARD D. KAHN AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, + +Defendant. + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 11/9/2020 + +CASE NO.: 1:19-CV-11869 + +## JOINT STIPULATION FOR DISMISSAL + +Plaintiff, ANASTASIA DOE, and Defendants, Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein, by and through their undersigned counsel, hereby stipulate and agree that due to Plaintiff's resolution of her claim(s) against Defendants via the Epstein Victims' Compensation Program, this action shall be DISMISSED WITH PREJUDICE, with each party to bear its own attorneys' fees and costs. + +Dated: November 2, 2020 + +POTTINGER LLC + +B J. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Brad®eplk.com Brittany®eplIc.com Attorneys for Plaintiff + +Respectfully Submitted, + +TROUTMAN PEPPER + +SANDERS LLP By: Molly S. DiRago 875 Third Avenue New York, NY 10022 (212) 704-6000 bennet.moskowitz@troutman.com Attorneys for Defendants 4nctit .5 Uo-io + +Granted. SO ORDERED. 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